August 2015

National Park Service

U.S. Department of the Interior

Honouliuli Gulch and Associated Sites 

Final Special Resource Study and 

Environmental Assessment
We are pleased to provide you with this copy of the Honouliuli Gulch and Associated Sites Final Special 

Resource Study and Environmental Assessment. 

This report has been prepared to provide Congress and the public with information about the resources in 

the study area and how they relate to criteria for inclusion within the national park system. Publication and 

transmittal of this report should not be considered an endorsement for a commitment by the National Park 

Service to seek or support either specific legislative authorization for the project or appropriation for its 

implementation. The Finding of No Significant Impact (FONSI) for this document was signed on October 15, 

2014.

Photo credits

Front and back covers: Barracks and tents at Honouliuli, c. 1945, by R. H. Lodge. Courtesy of Hawai'i’s Plantation Village.

Front inside cover: Remaining World War II-era structure, Honouliuli Internment Camp. Photo: Valentino Valdez.

Back inside cover: Extant fence post with barbed wire, Honouliuli Internment Camp. Photo: Valentino Valdez.
HONOULIULI GULCH AND ASSOCIATED SITES

Final Special Resource Study and Environmental Assessment

AUGUST 2015

Produced by the Pacific West Regional Office

Park Planning and Environmental Compliance

San Francisco, CA and Seattle, WA

National Park Service

U.S. Department of the Interior

Washington, DC

Final Special Resource Study and Environmental Assessment for

HONOULIULI GULCH AND ASSOCIATED SITES

August 2015

The National Park Service (NPS) prepared the Honouliuli Gulch and Associated Sites Special Resource Study 

and Environmental Assessment to determine whether the Honouliuli Internment Camp and associated 

World War II internment sites in Hawai‘i are nationally significant, suitable, and feasible for inclusion in the 

national park system. Congress authorized this study in 2009. The study evaluates 17 sites.

Through the special resource study process, the NPS made the following determinations about the study 

sites:

ŐThe Honouliuli Internment Camp and the U.S. Immigration Station on the island of O‘ahu are 

nationally significant for their central role as internment sites in Hawai‘i during World War II. They 

meet all four of the NPS criteria for national significance. The other 15 sites associated were used for 

shorter periods of time, interned fewer numbers of people, or have been substantially changed since 

the period of significance. As such, they do not meet the criteria for national significance. Many of 

these sites are, however, listed or eligible for listing in the National Register of Historic Places and/or 

provide opportunities to further interpret the history of internment in Hawai‘i during World War II.

ŐThe Honouliuli Internment Camp and the U.S. Immigration Station depict a distinct and important 

aspect of American history associated with civil liberties in times of conflict that is not adequately 

represented or protected elsewhere, and are therefore suitable for inclusion in the national park 

system.

ŐThe Honouliuli Internment Camp historic site is a feasible addition to the national park system 

conditional upon securing public access to the site. The U.S. Immigration Station complex is not 

a feasible addition to the national park system because the complex is currently used by the U.S. 

Department of Homeland Security and the State of Hawai‘i Department of Health.

ŐThere is a need for NPS management of the Honouliuli Internment Camp historic site in partnership 

with others to fully protect resources and to enhance visitor appreciation of the nationally significant 

resources and important stories associated with it.

The NPS evaluated two alternatives in the study. One includes a role for the NPS.

Alternative A: Continuation of Management. This is the “no action” alternative. Sites, organizations, 

and programs significant to the internment history in Hawaiʻi would continue to operate independently by 

existing landowners, agencies, or organizations without additional NPS management or assistance other 

than what is currently available through existing authorities and grant programs.

Alternative B: Honouliuli National Historic Site or Monument–A Unit of the National Park System. 

Congress would establish Honouliuli National Historic Site as a new unit of the national park system. 

Alternatively, a national monument managed by the NPS could be established. The national historic site 

or national monument would include the historic site of the Honouliuli Internment Camp and adjacent 

lands that provide access and opportunities for visitor facilities. The NPS would preserve the site and 

interpret the internment of Japanese Americans and European Americans in Hawaiʻi during World War 

II. The national historic site or monument would be supported by operational capacity at World War II 

Valor in the Pacific National Monument, Pearl Harbor. The NPS could provide technical assistance for the 

preservation and interpretation of other sites, features, and stories related to internment in Hawaiʻi during 

World War II. 

The NPS prepared an environmental assessment to identify and analyze the potential environmental and 

socioeconomic consequences of the two alternatives. The NPS concluded that alternative B would be the 

environmentally preferable alternative because it would protect nationally significant resources, provide 

opportunities for visitors to learn about the internment history in Hawai‘i during World War II, provide 

greater socioeconomic benefits, and apply long-standing NPS policies and actions to the Honouliuli 

Internment Camp historic site. 

View west from the bottom of Honouliuli Gulch. The landforms comprising the gulch create a strong sense of enclosure. Photo: NPS, 2013.

 Table of Contents i

TABLE OF CONTENTS

Terminology v

Acronyms and Abbreviations vii

Executive Summary xi

Chapter 1: Introduction 1

PURPOSE AND NEED 1

STUDY SITES 1

STUDY PROCESS 2

RELATED STUDIES 4

Chapter 2: Historical Overview 

and Resources 5

PART I: HISTORICAL OVERVIEW 5

PART II: SITES ASSOCIATED WITH 

THE INTERNMENT IN HAWAI‘I 17

Chapter 3: Resource 

Significance 41

CRITERIA FOR NATIONAL SIGNIFICANCE 41

SIGNIFICANCE OF THE EVENTS: 

INCARCERATION OF CIVILIANS IN THE 

UNITED STATES DURING WORLD WAR II 42

NATIONAL HISTORIC LANDMARK 

CRITERIA ANALYSIS 46

SPECIAL RESOURCE STUDY CRITERIA 

ANALYSIS 50

SIGNIFICANCE OF ADDITIONAL SITES 

ASSOCIATED WITH CIVILIAN INTERNMENT 

DURING WORLD WAR II 62

NATIONAL SIGNIFICANCE CONCLUSION 63

Chapter 4: Suitability 69

INTRODUCTION 69

COMPARATIVE ANALYSIS OF U.S. MAINLAND 

AND HAWAI‘I INCARCERATION SITES 69

NPS THEMATIC FRAMEWORK— 

CULTURAL THEMES 81

CONCLUSION—FINDING OF SUITABILITY 89

Chapter 5: Feasibility and the 

Need for NPS Management 91

INTRODUCTION 91

EVALUATION OF FEASIBILITY FACTORS 91

FEASIBILITY CONCLUSION 113

DETERMINATION OF NEED FOR NPS 

MANAGEMENT 115

Chapter 6: Alternatives 117

INTRODUCTION 117

OVERVIEW OF THE ALTERNATIVES 117

THE SELECTED ALTERNATIVE 117

MANAGEMENT ALTERNATIVES NO LONGER 

UNDER CONSIDERATION 117

DESCRIPTION OF THE ALTERNATIVES 118

Alternative A: Continuation of 

Current Management 

(No Action Alternative) 118

Alternative B (Selected Alternative): 

Honouliuli National Historic Site 

or National Monument— 

A New Unit of the National 

Park System 122

Chapter 7: Environmental 

Consequences 127

INTRODUCTION 127

IMPACT TOPICS 129

LAND USE 137

WATER RESOURCES 141

BIOLOGICAL RESOURCES 143

CULTURAL RESOURCES 145

VISITOR USE AND EXPERIENCE 150

SOCIOECONOMICS 153

ENVIRONMENTALLY PREFERABLE ALTERNATIVE 155

Chapter 8: Consultation and 

Coordination 159

PUBLIC INVOLVEMENT 159

AGENCY CONSULTATION 161

LIST OF DRAFT STUDY RECIPIENTS 162

PUBLIC REVIEW OF DRAFT 

STUDY REPORT 163
ii Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

SUMMARY OF PUBLIC COMMENTS 164

RESPONSE TO SUBSTANTIVE COMMENTS 

ON THE DRAFT STUDY REPORT 170

Appendices 175

APPENDIX A: STUDY LEGISLATION 175

APPENDIX B: 2006 NPS MANAGEMENT 

POLICIES (SECTIONS 1.2 AND 1.3) 176

APPENDIX C: NATIONAL HISTORIC 

LANDMARK CRITERIA SEC 65.4 179

APPENDIX D: JAPANESE AMERICAN 

WARTIME INCARCERATION PROPERTIES 181

APPENDIX E: FINDING OF NO 

SIGNIFICANT IMPACT 186

APPENDIX F: ERRATA 199 

References 227

LIST OF HISTORICAL IMAGES 227

SELECTED BIBLIOGRAPHY 229

Study Team and Preparers 236

Tables

Table 1: Existing Management of Sites 

Evaluated in the Study xxiii

Table 2-1: Number of Persons of 

Japanese Ethnicity Confined in 

Internment Camps in Hawai‘i 

during World War II (adapted 

from Okihiro 1992, 267) 15

Table 2-2: Sites Associated with the 

Internment in Hawai‘i 

during World War II 16

Table 3-1: Nationally Significant Sites 64

Table 3-2: Sites Listed in the National 

Register of Historic Places, where 

Internment History Enhances or 

May Enhance Their Significance 65

Table 3-3: Sites Associated with 

World War II Internment in Hawai'i 

Recommended for Nomination to the 

National Register of Historic Places 65

Table 3-4: Sites Needing Additional 

Research 66

Table 3-5: Other Sites 67

Table 5-1: Operating Budgets for 

Comparable and Related National 

Park Units (FY 2012) 113

 Table 5-2: Feasibility Analysis, 

Summary Table 114

Table 6-1: Existing Management of 

Sites Evaluated in the Study 121

Table 7-1: Impact Topics Analyzed 130

Table 7-2: Impact Topics Dismissed 133

Table 7-3: Crosswalk for NEPA and 

Section 106 Effects 146

Table 7-4: Comparison of Impacts 156

Table 8-1: Public Scoping 

Workshops, 2011 160

Table 8-2: Public Meeting 

Attendance, Draft Study Review 163

Maps

Confinement Sites in Hawai‘i during 

World War II ix

Mainland Sites Associated with the 

Incarceration of Persons of Japanese 

Descent During World War II 11 

Map of Internment Sites on the 

Island of O‘ahu 18

Honouliuli Internment Camp— 

Historic Layout and Modern 

Features 27

Map of Internment Sites on the 

Island of Hawai‘i 29

Map of Internment Sites on the 

Island of Kaua‘i 34

Map of Internment Sites on the 

Islands of Maui, Lāna‘i, and Moloka‘i 37

Nationally Significant Sites, 

Island of O‘ahu 47

Land Ownership—Honouliuli 

Internment Camp 92

Zoning—Honouliuli Internment 

Camp 96
State Land Use Districts, Island of 

Oʻahu 97 

Land Ownership—U.S. Immigration 

Station 98 

Zoning—U.S. Immigration Station 99

Urban Land Use Map, ʻEwa 

Development Plan 100

Access and Circulation—Honouliuli 

Internment Camp 101

Access and Circulation—U.S. 

Immigration Station 104 

Alternative A: Continuation of 

Current Management (No Action) 119

Alternative B: Proposed Boundary, 

Honouliuli National Historic 

Site or Monument 123

Prime and Unique Farmland 139 

Water Resources 142 

 Table of Contents iii
iv Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 
 Terminology v

TERMINOLOGY

Many different words have been used and 

continue to be used to describe the U.S. 

government’s wartime policies toward Japanese 

Americans and legal resident aliens of Japanese 

ancestry. Highly charged debates over words 

and terminology continue to reflect intense 

feelings and diverse perspectives about what 

occurred during World War II. To fulfill its 

responsibilities to the public, the National 

Park Service acknowledges the diversity of 

perspectives and opinions about the meaning 

and significance of this varied terminology and 

encourages education, reflection, and discussion 

about this aspect of American history. 

Words used to describe the forced removal 

of people from their homes and communities 

and their subsequent imprisonment include: 

exclusion, evacuation, relocation, detention, 

confinement, incarceration, and internment. 

The people themselves have been referred to as 

evacuees, detainees, inmates, internees, nonaliens, prisoners, and incarcerees. The people 

have also been described as Japanese, Japanese 

Americans, Japanese legal resident aliens, 

Nikkei, and by their generation in the United 

States—Issei (first generation) and Nisei (second 

generation). Finally, the facilities used to 

implement the government’s policies have been 

called assembly centers, camps, concentration 

camps, incarceration camps, internment camps, 

prisons, relocation centers, and War Relocation 

Authority centers. Although these various terms 

exist today, it is now widely accepted that the 

U.S. government purposefully used euphemistic 

terminology to mislead the American public 

about the severity of and justifications for its 

actions during World War II. 

Differences also exist in the terminology used 

both historically and currently to describe what 

occurred on the U.S. mainland in comparison 

with Hawai‘i. On the mainland, Executive 

Order 9066 was the legal authority for the mass 

removal and imprisonment of 120,000 people 

of Japanese ancestry. The term “internment” is 

commonly used to describe this history, though 

“internment” is misleading in this context. 

“Internment” refers to the legally permissible 

detention of enemy aliens in wartime. It is 

problematic because two-thirds of those 

incarcerated under Executive Order 9066 were 

American citizens by birth and the remaining 

one-third were Japanese nationals ineligible 

for citizenship because of a discriminatory law 

that prevented their naturalization. In addition, 

the vast majority of Japanese Americans who 

were incarcerated were not legally processed 

through hearings or trials as enemy aliens. For 

these reasons, there has been support for using 

terms without a legal connotation, such as 

incarceration, imprisonment, and detention. 

In Hawai‘i, discussions have begun about 

terminology to describe the events, locations, 

and people who were forcibly detained and 

imprisoned during World War II. “Internment” 

and “detention” (and their derivatives: 

internment camp, internee, detention camp, 

and detainee) are the most frequently used 

terms. These words are generally accurate 

when used in the context of martial law, which 

was the legal mechanism for removing and 

imprisoning American citizens and resident 

aliens of Japanese and European ancestry in 

Hawai‘i. Martial law gave the military authority 

over the civilian population. This resulted in the 

closing of civilian courts and the establishment 

of military-run courts. Each incarcerated 

individual, whether an American citizen or 

foreign national, received a legal hearing first 

by a civilian court and then, if warranted, 

by a military review board. Those identified 

as enemy aliens, potentially dangerous, and 

suspicious of disloyalty were interned. 

During World War II, the Honouliuli site 

was referred to by various names in army 

documents and consular reports. It was called 

“Camp Honouliuli,” “Internees Compound 

#6,” “Honouliuli Internment Camp,” “Alien 

Internment Camp,” and “Honouliuli Camp.” 

While the military interned both American 

citizens and civilians of Japanese and European 

ancestry at Honouliuli, the larger population 

was composed of prisoners of war. According 

to the Convention of 1929 relative to the 

Treatment of Prisoners of War, 118 L.N.T.S. 

343, entered into force June 19, 1931, prisoners 

of war were subject to “internment” and may 

“be interned in fenced camps.” The Geneva 

Convention of 1949 also used “internment” as 

the definition for incarcerating prisoners of war. 
vi Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

For the purposes of this study, the National 

Park Service uses “internment” to describe 

the process by which civilians were removed 

and imprisoned in Hawai‘i. “Incarceration” is 

used when describing the mass removal and 

imprisonment on the mainland and to describe 

this process as a concept or series of events. 

This document also uses historically used terms, 

depending on the specific context and the 

sources used and cited. 

We acknowledge that readers may not always 

agree with the use of certain words in specific 

contexts. 
 Abbreviations vii

ACHP – Advisory Council on Historic 

Preservation

ACOE – U.S. Army Corps of Engineers

ALISH – Agricultural Lands of Importance to 

the State of Hawai‘i

BLM – Bureau of Land Management

BWS – City and County of Honolulu Board of 

Water Supply

CAA – Clean Air Act

CEQ – Council of Environmental Quality

CFR – Code of Federal Regulations

CWA – Clean Water Act

CWRIC – Commission on Wartime Relocation 

and Internment of Civilians

DO – Director’s Order

DOJ – Department of Justice

EA – Environmental Assessment

EIS – Environmental Impact Statement

EO– Executive Order

EPA– U.S. Environmental Protection Agency

ESA– Endangered Species Act

FBI – Federal Bureau of Investigation

FEMA– Federal Emergency Management 

Agency

FHA – Federal Highway Administration

FR – Federal Register

HRT – Hawai‘i Rail Transit

JACS – Japanese American Confinement Sites

JCCH – Japanese Cultural Center of Hawai‘i 

NEPA – National Environmental Policy Act

NHL – National Historic Landmark

NPS – National Park Service

NRHP – National Register of Historic Places

POW – prisoner of war

PEPC – National Park Service Planning, 

Environment and Public Comment Website

PL – Public Law

SHPO – state historic preservation officer

SRS – Special Resource Study

T & E species – threatened and engangered 

species

UHWO – University of Hawai‘i–West O‘ahu

USDA – U.S. Department of Agriculture

WRA – War Relocation Authority

WWII – World War II

ACRONYMS AND ABBREVIATIONS
viii Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 
 ix Confinement sites in Hawai‘i during World War II.
x Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 
 Executive Summary  Background and Study Process xi

EXECUTIVE SUMMARY

Background and Study Process

The Department of the Interior, Environment, 

and Related Agencies Appropriations Act of 

2010, Title 1, Section 125 (123 Stat. 2932), 

October 30, 2009) authorized the National Park 

Service (NPS) to “conduct a special resource 

study of the national significance, suitability, and 

feasibility of including the Honouliuli Gulch 

and associated sites within the State of Hawai‘i 

in the National Park System.” The legislation 

stated, “The study shall evaluate the Honouliuli 

Gulch, associated sites located on O‘ahu, and 

other islands located in the State of Hawai‘i with 

respect to—

1. the significance of the site as a component 

of World War II;

2. the significance of the site as related to the 

forcible internment of Japanese Americans, 

European Americans, and other individuals; 

and

3. historic resources at the site.”

This legislation was introduced in the Senate 

by Senator Daniel Inouye and Senator 

Daniel Akaka of Hawaiʻi, and in the House 

by Representative Mazie Hirono and former 

Representative and current Hawaiʻi Governor, 

Neil Abercrombie, with numerous co-sponsors 

from across the United States and the Pacific 

territories (American Samoa, Guam, and the 

Northern Mariana Islands). 

This study provides information to aid the 

National Park Service in determining whether 

the study sites meet eligibility, suitability, and 

feasibility criteria for designation as units of 

the national park system. The study follows 

the process established by the National Park 

System New Area Studies Act (P.L. 105-391, 16 

U.S.C. Sec. 1a-5) and addresses the criteria for 

new areas outlined in NPS Management Policies 

2006. 

Legislative and Policy Direction

The National Park System New Area Studies 

Act requires that special resource studies be 

prepared in compliance with the National 

Environmental Policy Act (NEPA). The NPS 

determined that an environmental assessment 

(EA) is a sufficient level of environmental 

analysis for this study. This study complies with 

the National Historic Preservation Act, Section 

106 and 110 requirements. Section 106 requires 

federal agencies to take into account the effects 

of their undertakings on historic properties. The 

Section 106 process is being coordinated with 

the National Environmental Policy Act process 

for this special resource study. No significant 

impacts or effects are anticipated from the 

findings and recommendations of this study.

According to NPS management policies, a 

proposed addition to the national park system 

will receive a favorable recommendation from 

the NPS only if it meets all of the following four 

criteria for inclusion:

Őit possesses nationally significant natural or 

cultural resources;

Őit is a suitable addition to the system;

Őit is a feasible addition to the system; and

Őit requires direct NPS management, instead 

of alternative protection by other public 

agencies or the private sector.

These criteria are designed to ensure that the 

national park system includes only the most 

outstanding examples of the nation’s natural 

and cultural resources, while recognizing that 

there are other management alternatives for 

preserving the nation’s outstanding resources.

Alternatives for NPS management are developed 

for sites that meet all four of the criteria for 

inclusion.

Public Involvement

PUBLIC SCOPING

The NPS launched public scoping for this 

study in February 2011. A notice of scoping 

was published in the Federal Register on May 

2, 2011 (Vol. 76, No. 83, 24514–15). The study 

team produced and distributed an informational 

newsletter and press releases to the media, 

individuals, organizations, and government 

officials. Public information was made available 

on the National Park Service’s Planning, 

Environment and Public Comment (PEPC) 

website and project website at www.nps.gov/

pwro/honouliuli. 
xii Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

In February and March 2011, the study team 

held eight public scoping meetings on the 

six main islands in Hawaiʻi. Over 100 people 

attended the public meetings. Local, state, and 

federal government officials and stakeholders 

were also consulted. During this time, 

numerous articles and opinion pieces about the 

study appeared in area newspapers. 

The comment period for public scoping 

extended to June 1, 2011, thirty days after 

publication of the notice of scoping in the 

Federal Register.

Historical Background

Shortly after the surprise bombing of Pearl 

Harbor on December 7, 1941 by the Japanese 

Navy, the United States imposed martial law on 

the territory of Hawai‘i and formally entered 

into World War II. The U.S. military and FBI 

began rounding up and imprisoning persons of 

Japanese and European ancestry in Hawai‘i on 

suspicion of disloyalty to the United States. The 

legal authority in Hawai‘i for the internment 

was martial law, which began on December 7, 

1941 and lasted until October 24, 1944. Initially 

internees were confined in local areas, mostly 

prisons, courthouses, and similar facilities 

throughout the Hawaiian Islands. Most were 

then sent to the U.S. Immigration Station on 

O‘ahu before being transferred to mainland 

internment camps. Of the 158,000 people of 

Japanese ancestry in Hawai‘i at the beginning 

of World War II, approximately 2,000 were 

interned.

On the mainland, all individuals of Japanese 

ancestry living in California, southern Arizona, 

the western halves of Washington and Oregon, 

and the territory of Alaska were forced from 

their homes by military exclusion orders 

following Executive Order 9066, issued on 

February 19, 1942. They were rounded up and 

sent to temporary detention centers and then to 

isolated large-scale camps located throughout 

the western states and Arkansas, where most 

would spend the duration of the war years. 

The mass incarceration of 120,000 persons 

of Japanese ancestry was the largest forced 

removal of people in the history of the United 

States.

In Hawai‘i, by March 1943, Honouliuli 

Internment Camp had been constructed on 

O‘ahu to intern citizens, resident aliens, and 

prisoners of war. The camp held approximately 

400 internees and became the largest 

Administration building, U.S. Immigration Station. Photo: NPS, 2013.
 Executive Summary  Study Sites xiii

ŐIt offers superlative opportunities for public 

enjoyment, or for scientific study.

ŐIt retains a high degree of integrity as a true, 

accurate, and relatively unspoiled example 

of a resource.

The NPS evaluates national significance for 

cultural resources by applying the national 

historic landmarks (NHL) criteria contained in 

36 CFR Part 65. 

National Park Service professionals consult 

with subject matter experts, scholars, and 

scientists in determining whether a study area 

is nationally significant. Resource experts 

and scholars within and beyond the NPS 

contributed expertise, research, and technical 

review of the statement of significance.

NATIONALLY SIGNIFICANT SITES

The internment and incarceration of Japanese 

Americans and others during World War II 

on the mainland and in Hawai‘i are nationally 

significant events that shape our understanding 

and commitment to civil liberties and the fair 

treatment of all citizens, regardless of race. By 

identifying the commonalities and distinctions 

between mainland and Hawai‘i stories, this 

study concludes that the internment in Hawai‘i 

is of national significance, distinct from 

mainland incarceration. Through it, we are 

prisoner-of-war camp in Hawai‘i with nearly 

4,000 individuals from Korea, Okinawa, Taiwan, 

Japan, and Italy. Honouliuli was the last, largest, 

and longest-used World War II confinement 

site in Hawai‘i; it closed in 1945 for civilian 

internees and may have been used into 1946 for 

prisoners-of-war.

More than 40 years after World War II, the Civil 

Liberties Act of 1988 was signed into law by 

President Ronald Reagan. It acknowledged the 

fundamental injustice of the mass incarceration 

based on race and formally apologized on 

behalf of the people of the United States. The 

act stated the World War II mass incarceration 

of Japanese Americans was the result of “racial 

prejudice, wartime hysteria and a lack of 

political leadership.” 

Study Sites

The study evaluates 17 sites associated with 

the history of internment in Hawaiʻi (See Map: 

Confinement sites in Hawai‘i during World War 

II). A preliminary list of 13 sites was developed 

based on information obtained through 

personal interviews, declassified documents 

from the Federal Bureau of Investigation 

and Department of Justice, military files, 

newspapers, photographs, and numerous books 

and essays. The University of Hawaiʻi, Japanese 

Cultural Center of Hawaiʻi, and Trans-Sierran 

Archaeological Research provided information 

about internment sites in Hawaiʻi. Site visits by 

the study team were conducted where possible 

to determine current conditions and integrity 

of the sites. Four additional sites were recorded 

during the preparation of this report.

Study Findings 

NATIONAL SIGNIFICANCE

The National Park Service (NPS) uses four basic 

criteria to evaluate the significance of proposed 

areas. These criteria, listed in the National Park 

Service Management Policies 2006, state that a 

resource is nationally significant if it meets all of 

the following conditions:

ŐIt is an outstanding example of a particular 

type of resource.

ŐIt possesses exceptional value or quality in 

illustrating or interpreting the natural or 

cultural themes of our nation’s heritage.

Internees and others inscribed names and dates into cement 

features at Honouliuli Internment Camp during World War II. 

Inscription in the guard camp area. Photo: Burton and Farrell 

2011.
xiv Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

able to more fully understand the abrogation of 

civil liberties that occurred in the U.S. and its 

territories. 

More than 2,000 residents of Japanese and 

European ancestry living in Hawai‘i were 

incarcerated in at least seventeen locations 

in Hawai‘i during World War II, including 

Honouliuli Internment Camp, Sand Island, 

the U.S. Immigration Station, Honolulu Police 

Department, and Honolulu Military Police 

Station on O‘ahu; the Kilauea Military Camp, 

Waiākea Prison, and the Hilo Independent 

Japanese Language School on the island of 

Hawaiʻi; Ha‘ikū Camp and Maui County Jail 

on Maui; the Kaunakakai Jail on Moloka‘i; 

the Lāna‘i City Jail on Lāna‘i; and the Kalāheo 

Stockade, Waimea Jail, Waialua Jail, Līhu‘e 

Plantation Gymnasium, and Kaua‘i County 

Courthouse on Kaua‘i.

The 17 internment sites in Hawai‘i were 

evaluated for their role and importance in 

telling the internment story. Based on the 

findings and analysis in this study, two sites, 

Honouliuli Internment Camp and the U.S. 

Immigration Station, are found to be nationally 

significant as defined in the NHL guidelines. 

Honouliuli Internment Camp (Waipahu, 

O‘ahu)

The Honouliuli Interment Camp was located 

in Honouliuli Gulch, west of Waipahu, on the 

island of O‘ahu. Opened in 1943, the Honouliuli 

Internment Camp was the last, largest, and 

longest-used World War II confinement site in 

Hawai‘i. The camp was built to intern Japanese 

and European Americans, Japanese and 

European resident aliens, and POWs captured 

in military operations during World War II. 

Honouliuli Internment Camp, protected by 

its isolated location amidst agricultural lands 

and nearly hidden by dense vegetation for 60 

years, appears to offer the greatest potential to 

preserve resources and interpret the history of 

the WWII internment. 

The internment camp held approximately 400 

internees, mostly second-generation Japanese 

Americans, but also Japanese, German, and 

Italian nationals. It was also the largest prisoner 

of war camp in Hawai‘i, incarcerating nearly 

4,000 individuals. Recent archeological surveys 

have resulted in the identification of over 130 

archeological features. 

U.S. Immigration Station (Honolulu, 

O‘ahu) 

The U.S. Immigration Station, located on Ala 

Moana Boulevard in Honolulu, is nationally 

significant as the location where all Hawai‘i 

internees were processed or temporarily 

incarcerated after the attack on Pearl Harbor 

on December 7, 1941. Unlike most of the other 

internment sites in Hawai‘i that only served 

local, short-term needs, the U.S. Immigration 

Station had a broad, statewide role over an 

extended period. It served as a temporary 

internment location, but also as a center of legal 

administration.

Other Internment Sites in Hawai‘i

The other 15 sites associated with internment 

considered in this study were used for shorter 

periods of time, interned fewer numbers of 

people, or have been substantially changed 

since the period of significance. As such, they 

do not meet the criteria for national significance 

as defined in the special resource study and 

national historic landmark criteria. Many of 

Sand Island Internment Camp opened immediately after the 

attack on Pearl Harbor and detained internees until March 1, 

1943. Photos: source unknown.
 Executive Summary  Study Findings xv

these sites are, however, listed or eligible for 

listing in the National Register of Historic 

Places (NRHP) and/or provide opportunities 

to further interpret the story of internment and 

incarceration in the U.S. during World War II.

SUITABILITY 

To be considered suitable for addition to the 

national park system, an area must represent 

a natural or cultural resource type that is 

not already adequately represented in the 

national park system, or is not comparably 

represented and protected for public enjoyment 

by other federal agencies; tribal, state, or local 

governments; or the private sector. 

Adequacy of representation is determined for 

nationally significant sites on a case-by-case 

basis by comparing the potential addition to 

other comparably managed areas representing 

the same resource type, while considering 

differences or similarities in the character, 

quality, quantity, or combination of resource 

values. The comparative analysis also addresses 

rarity of the resources, interpretive and 

educational potential, and similar resources 

already protected in the national park system 

or in other public or private ownership. The 

analysis results in a determination of whether 

the proposed new area would expand, enhance, 

or duplicate resource protection or visitor 

use opportunities found in other comparably 

managed areas. 

Honouliuli Internment Camp and the U.S. 

Immigration Station offer a special opportunity 

to expand our nation’s history of incarceration 

of civilians during World War II. The 

educational potential of these sites is enhanced 

by their quality, or high level of integrity, as 

well as the quantity of their extant resources. 

Based on the analysis of comparable resources 

and interpretation already represented in units 

of the national park system, or protected and 

interpreted by others, this study concludes 

that Honouliuli Internment Camp and the 

U.S. Immigration Station associated with the 

incarceration of civilians and prisoners of 

war in Hawaiʻi during World War II depict a 

distinct and important aspect of American 

Kaunakakai County Courthouse on Moloka‘i was moved offsite in the years following its use as a temporary detention center for 

Moloka‘i residents of Japanese heritage. After detention in this building and the nearby Kaunakakai County Jail, internees were 

transferred to the Wailuku County Jail on Maui and later sent to O‘ahu. Photo: NPS, 2011.
xvi Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

history associated with civil liberties in times of 

conflict that is not adequately represented or 

protected elsewhere, and are therefore suitable 

for inclusion in the national park system.

FEASIBILITY 

To be feasible as a new unit of the national park 

system, an area must be: (1) of sufficient size and 

appropriate configuration to ensure sustainable 

resource protection and visitor enjoyment 

(taking into account current and potential 

impacts from sources beyond proposed park 

boundaries), and (2) capable of efficient 

administration by the National Park Service at a 

reasonable cost. 

In evaluating feasibility, the NPS considers a 

variety of factors for a study area, such as the 

following:

ŐLand use, current and potential site uses, 

ownership patterns, planning and zoning

ŐAccess and public enjoyment potential

ŐBoundary size and configuration

ŐExisting resource degradation and threats to 

resources

ŐPublic interest and support

ŐSocial and economic impact 

ŐCosts associated with operation, 

acquisition, development, and restoration

The feasibility evaluation also considers 

the ability of the NPS to undertake new 

management responsibilities in light of current 

and projected availability of funding and 

personnel. An overall evaluation of feasibility is 

made after taking into account all of the above 

factors. 

Some management options are more feasible 

than others. The national park system includes 

many types of sites, and a range of ownership 

and management approaches. The NPS also 

offers grant and technical assistance programs 

that help local communities achieve their goals 

for conservation and recreation.

The feasibility analysis focuses on the two sites 

that have been found nationally significant, 

Honouliuli Internment Camp and the U.S. 

Immigration Station. 

The NPS finds that Honouliuli Internment 

Camp is feasible as an addition to the national 

park system as long as public access to the site 

Foundation of former mess hall, Honouliuli Internment Camp. Photo: NPS, 2013.
 Executive Summary  Study Findings xvii

can be secured. Current land use, ownership 

patterns, and zoning associated with Honouliuli 

Internment Camp would not conflict with 

management of a national park unit. Primary 

resources associated with the camp are located 

on property owned by the Monsanto Company, 

which has expressed interest in donating the 

property to the NPS for establishment of a 

national park unit. Surrounding lands are 

currently in agricultural use which is compatible 

with the camp’s historic setting. However, 

feasibility is conditional on securing public 

access to the site. As current access is primarily 

over unpaved agricultural roads, improvements 

would be needed to accommodate access by 

the general public. An appropriate boundary 

configuration would include the historic site 

and lands sufficient to provide access and visitor 

facilities such as parking areas.

There are no current threats to Honouliuli 

Internment Camp that would preclude 

management as a unit of the national park 

system. Honouliuli Internment Camp contains 

resources with integrity sufficient for national 

historic landmark designation and NPS 

designation.

Outreach for this study has demonstrated 

significant public interest and support for 

an NPS park unit at Honouliuli Gulch in 

partnership with other organizations and 

local communities. The social and economic 

impacts of NPS designation or other support/

coordination roles appear to be largely 

beneficial and would support the feasibility of 

NPS designation.

With operational support from World War II 

Valor in the Pacific National Monument at Pearl 

Harbor, operational costs for establishing a 

national park unit appear to be feasible. Land 

acquisition costs would be minimal and limited 

to the administrative costs associated with a 

land transfer to the National Park Service. 

The NPS finds that the U.S. Immigration 

Station is not feasible as an addition to the 

national park system because of existing uses 

by the U.S. Department of Homeland Security 

and the Hawai‘i State Department of Health. 

If the facilities were no longer needed by 

federal or state agencies, additional analysis 

would be needed to determine the feasibility 

of management options and associated costs. 

Photos (top to bottom): 1. Post-World War II chicken shed built 

of scrap materials on Honuliuli Internment Camp-era concrete 

slab. 2. Participant, Honouliuli Internment Camp Field Study, 

University of Hawai‘i–West O‘ahu, July 2010. Photos: Valentino 

Valdez.
xviii Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Given the size and scale of the facilities, costs 

for maintenance and preservation of the historic 

structures would be a primary consideration. 

NEED FOR NPS MANAGEMENT 

The need for direct NPS management is 

the final criterion for evaluating resources 

for potential designation as a new unit of 

the national park system. The criterion 

requires a finding that NPS management 

would be superior to alternative management 

arrangements by other entities.

Evaluation of the need for NPS management 

pertains to those resources that are determined 

to be nationally significant, suitable, and feasible 

for inclusion in the national park system. Based 

on these findings the need for NPS management 

focuses on Honouliuli Internment Camp. 

Associated sites would continue to be owned 

and operated by nonprofit organizations, 

private property owners, and other government 

agencies. 

The owner of the Honouliuli site, the Monsanto 

Company, has expressed interest in donating 

the site to the United States for its long-term 

preservation. Other organizations have not 

been identified that would be willing to take 

on direct ownership and management of the 

site for public use, or to which the Monsanto 

Company would be willing to transfer the site. 

NPS planning and research capabilities, as 

well as historic preservation, cultural resource 

management, and interpretive and educational 

programming expertise would offer superior 

opportunities for the site to be preserved and 

interpreted. 

NPS partnerships with organizations and 

private property owners of the associated 

sites would provide enhanced opportunities 

for interpretation and coordinated site 

management. Development and cooperative 

management of interpretive programs and 

comprehensive visitor services with the NPS 

would be beneficial. 

The NPS finds that there is a need for NPS 

management in partnership with others to 

fully protect resources and to enhance visitor 

appreciation of the nationally significant 

resources and important stories associated 

with the Honouliuli Internment Camp. The 

incorporation of Honouliuli Internment 

Camp into the national park system would 

offer a visitor experience that allows the 

broadest understanding of the resources and 

stories relating to the internment of Japanese 

Americans and European Americans in Hawai‘i 

during World War II.

Alternatives

The following section describes a range 

of management alternatives that are being 

considered by the National Park Service as part 

of the special resource study.

OVERVIEW OF THE ALTERNATIVES 

The study team developed two alternatives 

for the draft study/environmental assessment 

(EA), based on information gathered from 

public and stakeholder input, internal NPS 

discussions, evaluation of special resource 

study criteria, historical research, and NPS 

management models. The two alternatives 

considered are a “No Action” alternative, which 

serves as a baseline for comparison, and an 

“action” alternative, which is also the preferred 

alternative. 

ŐAlternative A: Continuation of Current 

Management (No Action)

ŐAlternative B: Honouliuli National Historic 

Site or Monument—A Unit of the National 

Park System

For each alternative there is a description of 

the overall concept and key elements of the 

alternative, including management approaches, 

resource protection, visitor services, and the 

role of organizations and public agencies. Maps 

of the alternatives are included in Chapter 6 to 

illustrate the proposed recommendation.

The Selected Alternative

NATIONAL HISTORIC SITE OR 

NATIONAL MONUMENT—A NEW UNIT 

OF THE NATIONAL PARK SYSTEM

The recommendations encompassed in the 

selected alternative are the same as those 

identified and analyzed in alternative B in the 

draft study report/EA, with the exception of 

modifications made as a result of information 

and comments derived from public review of 

the draft study report/EA, as follows:
 Executive Summary  The Selected Alternative xix

ŐThe proposed national historic site or 

monument boundary has been reduced at 

the request of the University of Hawaiʻi. 

Discussions between the NPS and the 

University of Hawaiʻi have identified 

approaches to public access that do not 

require inclusion of University of Hawaiʻi 

lands in an NPS boundary at this time. 

The University of Hawaiʻi is committed to 

working with the NPS on granting access 

to the site over university lands should a 

national park unit be established. Future 

road access could be added to the national 

historic site or monument boundary once a 

more permanent road alignment has been 

determined. 

ŐMinor modifications have also been made 

to address concerns regarding universal 

access to the site, potential partnerships, 

and technical assistance opportunities.

The above modifications would not constitute a 

change in environmental impacts beyond what 

was analyzed in the environmental assessment.

ALTERNATIVE A: CONTINUATION OF 

CURRENT MANAGEMENT (NO ACTION 

ALTERNATIVE)

Concept

Sites, organizations, and programs significant 

to the internment history in Hawaiʻi would 

continue to operate independently by existing 

landowners, agencies, or organizations without 

additional NPS management or assistance other 

than what is currently available through existing 

authorities and grant programs.

Management of Sites Related to 

Internment 

Local organizations and institutions have been 

active in documentation, preservation, and 

interpretation efforts for Honouliuli Internment 

Camp. The Japanese Cultural Center of Hawaiʻi 

(JCCH) has conducted extensive research 

and uncovered the location of Honouliuli 

Internment Camp and other related sites. 

The JCCH maintains the largest repository 

of archives and collection items related to 

Honouliuli and the internment history in 

Hawai‘i. University of Hawai‘i—West O‘ahu 

(UHWO) faculty and students have also played 

a significant role in researching the history 

of Honouliuli and conducting archeological 

Photos (top to bottom): 1. 2011 Day of Remembrance 

Pilgrimage to Honouliuli Internment Camp. Photo: Brian Niiya, 

Japanese Cultural Center of Hawai‘i. 2. Existing conditions, 

remaining World War II-era structure, Honouliuli Internment 

Camp, 2010. Photo: Valentino Valdez.
xx Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

surveys. In 2012, the Hawaiʻi State legislature 

commissioned an advisory group, called the 

Honouliuli Park Site Advisory Committee, to 

support preservation of the Honouliuli site. The 

advisory group was directed to: 1) provide state 

support toward preservation of the Honouliuli 

site; 2) establish a mechanism to leverage 

county, state, federal, and private funding for 

an educational resource center at the site; and 

3) memorialize the struggle for civil rights by 

Hawaiʻi’s people.

Sites related to World War II internment 

in Hawai‘i would continue to be managed 

separately by their public and private 

landowners. With the exception of the Kilauea 

Military Camp at Hawaiʻi Volcanoes National 

Park, there would be no NPS staffing or 

operational support at sites identified in the 

study other than technical assistance under 

existing authorities if requested. Organizations 

and programs devoted to commemorating and 

preserving Hawaiʻi’s internment history would 

continue to operate independently without 

NPS management or assistance other than that 

available through existing authorities. Table 

1: Existing Management of Sites Evaluated 

in the Study includes a summary of current 

management and visitor opportunities for each 

of the sites evaluated in the study.

HONOULIULI INTERNMENT CAMP

Under the no action alternative, Honouliuli 

Internment Camp would remain in private 

ownership and would continue to be 

inaccessible to the general public. Interest by the 

existing landowner, public agencies, educational 

institutions, nonprofit organizations, 

and individuals may result in additional 

opportunities to interpret the site. 

Although the site would not be managed 

expressly to provide visitor opportunities, 

existing landowners may continue to allow the 

JCCH site tours and educational activities on 

occasion when permission is expressly granted 

Archeological field school, University of Hawai‘i–West O‘ahu, 2010. Photo: Valentino Valdez.
 Executive Summary  The Selected Alternative xxi

by the landowner. UHWO would continue to 

conduct field schools at Honouliuli Internment 

Camp, as allowed by the current landowner.

OTHER ASSOCIATED SITES

Sites identified as potentially eligible for 

national historic landmark (NHL) nomination 

or nomination to the National Register of 

Historic Places (NRHP) would continue to be 

owned by various public and private entities. 

These sites would continue to function for 

private and public uses, most of which are not 

related to World War II internment history. 

Interpretation and conservation of such sites 

would be uncoordinated and at the discretion 

of the current landowner. Partner organizations 

and agencies would take the lead in developing 

interpretation and education materials and 

visitor opportunities. Such opportunities would 

occur at locations such as the JCCH.

Resource Protection

The primary responsibility for preserving 

nationally significant and associated sites would 

fall to the current owners and managers of those 

sites. Resource protection would be voluntary 

and dependent upon property owners’ 

initiative. Sites in federal ownership would 

be managed in compliance with the National 

Historic Preservation Act (U.S. Immigration 

Station, Kilauea Military Camp). Sites not in 

federal ownership and currently listed in the 

National Register of Historic Places, such as the 

Honolulu Police Department, Yokohama Specie 

Bank, Kauaʻi County Courthouse, and Maui 

County Courthouse and Police Station, would 

have some opportunities for technical assistance 

and grants for preservation.

For sites not listed in the NRHP nor protected 

by local preservation ordinances, any efforts 

for preservation would be at the discretion of 

existing landowners. Resources could suffer 

from a loss of integrity due to changes in use or 

ownership in accordance with local planning 

and zoning ordinances over time. Existing 

owners may also lack funding to maintain or 

preserve sites. 

Visitor Experience

Organizations that provide visitor opportunities 

to learn about the internment history could 

continue to provide such opportunities. 

The JCCH could continue to provide visitor 

Concrete slab foundation of the latrine and shower room 

located in the final reduced-size civilian compound at Honouliuli. 

Photo: Valentino Valdez.

opportunities at the annual pilgrimage to 

Honouliuli, if the property owner was willing. 

Hawaiʻi Volcanoes National Park could provide 

interpretation at Kilauea Military Camp in 

coordination with the U.S. Army. World War 

II Valor in the Pacific National Monument 

at Pearl Harbor would continue to interpret 

the internment experience in Hawaiʻi as one 

component of the larger Pacific War story that it 

is mandated to convey. 

Most other associated sites identified as 

significant to internment in Hawai‘i are 

not managed expressly to provide visitor 

opportunities to learn about or experience 

these sites. 

Japanese American Confinement Sites 

(JACS) Grant Program 

Honouliuli Internment Camp and other 

associated sites would continue to be eligible 

for grants through the Japanese American 

Confinement Sites (JACS) Grant Program. 

Public Law 109-441 (16 USC 461) established 
xxii Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

the JACS Grant Program for the preservation 

and interpretation of U.S. confinement sites 

where Japanese Americans were incarcerated 

during World War II. The law authorized up to 

$38 million for the life of the grant program to 

identify, research, evaluate, interpret, protect, 

restore, repair, and acquire historic confinement 

sites in order that present and future generations 

may learn and gain inspiration from these sites 

and that these sites will demonstrate the nation’s 

commitment to equal justice under the law. 

Grants are awarded to organizations and entities 

working to preserve historic Japanese American 

confinement sites and their history, including 

private nonprofit organizations; educational 

institutions; state, local, and tribal governments; 

and other public entities. Grants are awarded 

through a competitive process and require 

a two-to-one federal to non-federal match 

($2 federal to $1 non-federal match).Since its 

establishment in 2006, the JACS program has 

awarded more than $15 million in grants as of 

fiscal year 2014. To date, JCCH has received 

Participant, Honouliuli Internment Camp Field Study, July 2010. Photo: Valentino Valdez.

five grants totaling $375,700. Projects funded 

include a documentary film, educational 

tours, a youth program, traveling exhibits, and 

multimedia virtual tours. The University of 

Hawai‘i has received four grants to date, totaling 

$168,700. Projects funded include collection 

of oral histories, archival research, and 

archeological field schools. California-based 

CyArk received a grant of $39,020 to digitally 

document Honouliuli. Under the no action 

alternative, organizations would continue to 

obtain assistance from the JACS Grant Program.

Operations 

Operation and maintenance of existing sites 

would be assumed to remain at existing levels. 

With the exception of Kilauea Military Camp 

at Hawai‘i Volcanoes National Park, there 

would be no NPS staffing or operational 

responsibilities at the other nationally 

significant or potential NHL or NRHP sites 

associated with internment in Hawai‘i. 
 Executive Summary  The Selected Alternative xxiii

Table 1: Existing Management of Sites Evaluated in the Study

Site Site Type and 

Location

Ownership and 

Management

Current Visitor 

Opportunities or 

Interpretation 

Nationally Significant Sites

Honouliuli Internment 

Camp

Primary, O‘ahu Private Currently not accessible to 

the general public. Site tours 

and use for educational 

purposes occur on occasion 

with landowner permission.

U.S. Immigration Station Primary, O‘ahu Public, Department 

of Homeland Security 

and Hawaiʻi State 

Department of Health

None. Currently not 

accessible to the general 

public.

Sites Listed or Potentially Eligible for Listing in the National Register of Historic Places

Honolulu Police 

Department

Secondary, O‘ahu Public, City and County 

of Honolulu

None

Kauaʻi County 

Courthouse

Secondary, Kauaʻi Public, County of Kauaʻi None

Kilauea Military Camp Primary, Island of 

Hawaiʻi

Public, National Park 

Service

Active military recreation 

camp. Opportunities for 

interpretation exist.

Yokohama Specie Bank Private None

Lānaʻi City Jail and 

Courthouse

Secondary, Lānaʻi Private None

Potentially Significant Sites—Additional Research Needed

Waiākea Prison Camp Secondary, Island of 

Hawaiʻi

Private None

Hilo Independent 

Japanese Language School

Secondary, Island of 

Hawaiʻi

Unknown None

Līhu‘e Plantation 

Gymnasium 

Secondary, Kauaʻi Privately owned 

structure adjacent to 

Isenberg Park

None

Kalāheo Stockade Primary, Kauaʻi Private None

Ha‘ikū Military Camp Secondary, Maui Private None

Maui County Courthouse 

and Police Station

Secondary, Maui Public, Maui County None

Other Related Sites—No Integrity Remaining

Sand Island Detention 

Camp

Primary, O‘ahu Public, State of Hawaiʻi None/Non-Extant

Wailua Jail Primary, Kaua‘i Public None/Non-Extant

Waimea Jail Primary, Kaua‘i Public None/Non-Extant

Kaunakakai Jail and 

Courthouse

Secondary, Moloka‘i Public None/Non-Extant

Maui County Jail Primary, Maui Public, Maui County None/Non-Extant

“Primary” sites are those that housed at least 10 prisoners, generally for more than several weeks. “Secondary” sites are those that 

were used as prisons for fewer prisoners, usually for shorter periods of time. Also included in the “secondary” category are sites 

where no internees were imprisoned, but where activities related to the internment occurred, such as hearings. Note: The Honolulu 

Police Department was inadvertently omitted from the printed versions of this table in the newsletter and draft report.
xxiv Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

ALTERNATIVE B (SELECTED 

ALTERNATIVE): HONOULIULI NATIONAL 

HISTORIC SITE OR NATIONAL 

MONUMENT—A NEW UNIT OF THE 

NATIONAL PARK SYSTEM

Concept

Congress would establish Honouliuli National 

Historic Site as a new unit of the national park 

system. Alternatively, a national monument 

managed by the National Park Service could 

be established. The national historic site or 

national monument would include the historic 

site of the Honouliuli Internment Camp and 

adjacent lands that would allow for access and 

visitor facilities. In collaboration with partners, 

the National Park Service would preserve the 

site and interpret the internment of Japanese 

Americans and European Americans in Hawaiʻi 

during World War II. The national historic 

site or monument would be supported by 

operational capacity at World War II Valor in 

the Pacific National Monument, Pearl Harbor. 

The National Park Service could respond to 

requests to provide technical assistance for the 

preservation and interpretation of other sites, 

features, and stories related to internment in 

Hawaiʻi during World War II. 

Proposed Area

The Honoululi National Historic Site or 

National Monument would total approximately 

155 acres. The historic Honouliuli Internment 

Camp and the adjacent overlook parcel (totaling 

approximately 123 acres) would be acquired by 

the NPS through a donation by the Monsanto 

Company. Additional Monsanto-owned lands 

(31.5 acres) with related resources could be 

protected through conservation easements, 

land transfer, or other measures, at Monsanto's 

discretion. All private property rights would be 

respected. 

The University of Hawaiʻi has committed to 

providing NPS with public access to Honouliuli, 

initially through granting the NPS a right of 

entry over existing roads from the west. The 

University of Hawaiʻi is currently undergoing 

planning efforts for its lands adjacent to 

Honouliuli. This process and subsequent 

planning by the NPS should a national park 

unit be established may identify a new road 

alignment for public access. Once a desired 

road alignment for public access has been 

determined, this road alignment could be 

included in the national historic site or national 

monument through a boundary adjustment. 

This would allow the National Park Service 

to expend funds on the development and 

maintenance of the access road.

Three parcels owned by the City and County 

of Honolulu Board of Water Supply (totaling 

0.6 acres) would be inholdings within the 

proposed area and would remain under 

current ownership and management. The 

communications facilities, non-contributing 

features within the historic site, would not be 

included in the proposed boundary.

Management

The NPS would have direct management 

responsibility for the Honouliuli National 

Historic Site or National Monument including: 

1) interpretation and education associated 

with the Honouliuli Internment Camp and 

its resources, including the development 

of interpretive media and programs; 2) 

preservation and resource management for the 

historic site; and 3) operational facilities and 

infrastructure such as roads, restrooms, and 

trails.

Resource Protection

NPS staff would protect and preserve resources 

related to Honouliuli Internment Camp. 

Management plans would guide appropriate 

historic preservation documentation and 

treatments. As described below, there are 

opportunities to partner with local institutions 

and organizations in the protection of 

resources. 

Visitor Experience 

Visitors would have the opportunity to learn 

about Honouliuli Internment Camp, World 

War II internment in Hawaiʻi, martial law, civil 

liberties, and peace and reconciliation through 

a wide variety of interpretive and educational 

programs onsite and at offsite locations. 

Interpretation would be accessible and relevant 

to diverse audiences and multiple generations. 

Virtual visitor experiences would be explored 

so that people could learn about and experience 

Honouliuli and related sites without actually 

visiting the sites. Programs could be provided 

by NPS rangers, partners, and volunteers. 

Information could be presented in multiple 

languages.
 Executive Summary  The Selected Alternative xxv

Partnerships

Other entities, specifically the University of 

Hawaiʻi—West O’ahu and the Japanese Cultural 

Center of Hawaiʻi, have done significant work 

to document, preserve, and interpret the 

Honouliuli Internment Camp and the larger 

history of internment in Hawai‘i during World 

War II. The NPS would seek to maintain these 

partnerships for future management of the 

Honouliuli National Historic Site or Monument. 

In addition, the NPS would explore, develop, 

and maintain new partnerships for the 

preservation and interpretation of Honouliuli 

Internment Camp and related sites, features, 

and stories in Hawaiʻi. 

There are substantial opportunities for 

partnerships related to Honouliuli National 

Historic Site or Monument with public agencies, 

educational institutions, nonprofit entities, 

and individuals. Potential partnership projects 

could include the development of educational 

programs, development of facilities, resource 

stewardship activities such as preservation of 

historic features and vegetation clearing, and 

research projects. Partnerships could also 

include shared facilities for interpretation, 

curatorial storage, operations, and maintenance. 

Technical Assistance

Internment sites in Hawai‘i other than 

Honouliuli Internment Camp would continue 

to be owned and managed by their respective 

public and private owners. Any recognition or 

technical assistance related to the associated 

sites would be voluntary on the part of the 

landowner. The associated sites illustrate the 

broad-reaching effects of internment on the 

six major islands in Hawai‘i and are valuable in 

accurately interpreting this history. 

Upon request, the NPS could work 

cooperatively with associated site owners 

and managers to explore opportunities for 

interpretation and/or preservation of the 

associated sites. Where appropriate, the NPS 

could also conduct research and provide 

assistance to related sites that have yet to be 

identified.

Operations 

STAFFING

Honouliuli National Historic Site or Monument 

would be managed through World War II 

Valor in the Pacific National Monument at 

Pearl Harbor, given its close proximity and 

Collapsed roof in extant World War II-era structure, Honouliuli Internment Camp, July 2010. Photo: Valentino Valdez.
xxvi Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

related history. Some staff positions at World 

War II Valor in the Pacific National Monument 

would be shared. However, management of the 

site would require additional staff as funding 

became available. A management plan would 

identify priorities, management emphases, and 

required staffing for a 15 to 20 year timeframe. 

Based on comparisons of staffing levels for 

existing national historic sites of similar scale 

and management models, the following types of 

staff would be recommended:

ŐSite manager

ŐCultural resource specialist 

ŐInterpretive specialist 

ŐInterpretive ranger (2)

ŐLaw enforcement ranger

ŐMaintenance (2)

ŐExotic plant management technician

Positions could be permanent, temporary, or 

seasonal. In addition, partner organizations 

could provide staff or volunteers, with types 

and numbers dependent upon the functions 

provided. 

OPERATIONAL AND VISITOR FACILITIES

Comprehensive management planning 

would guide the development of facilities for 

Honouliuli National Historic Site or National 

Monument. Facilities would be needed to 

support public access, circulation, orientation, 

and learning about the history of internment in 

Hawaiʻi. The 7-acre overlook site could serve 

as a visitor staging area with ample space to 

provide for parking, visitor drop-off, interpretive 

features, and restrooms. The site is located 

just outside of the historic camp and offers 

views to Pearl Harbor, downtown Honolulu, 

and Diamond Head. Within the gulch, visitor 

facilities would be minimal to preserve the site’s 

historic integrity. Facilities might include trails, 

interpretive waysides, primitive roads, and vault 

toilets. Implementation planning would also 

explore opportunities for persons of all abilities 

to access and experience Honouliuli Internment 

Camp.

Currently there is no public access to 

Honouliuli Internment Camp. Rights of access 

would be required to provide public access 

to the 7-acre overlook parcel and the historic 

site. Existing roads would require considerable 

improvement to accommodate visitor access. 

As noted above, the University of Hawaiʻi has 

indicated its commitment to working with the 

National Park Service with regard to providing 

public access on existing and future roads 

through its lands.

The Federal Highway Administration (FHA) 

estimated construction costs for public and 

administrative access using existing road 

alignments would range from $3 to 20 million. 

This dollar amount would also include parking 

and turnaround areas for buses. The higher end 

of the range would be incurred if additional 

reconstruction or realignment is necessary 

for road improvements. Costs would need 

to be reevaluated after a formal site survey 

and through completion of a comprehensive 

management plan. 

Shuttle or bus service from either World War 

II Valor in the Pacific National Monument or 

UHWO was also evaluated by the FHA. Costs 

to operate a bus connection from World War 

II Valor in the Pacific National Monument 

three times per week were estimated at $25,000 

to 30,000 annually. Costs to operate a bus or 

shuttle from University of Hawaiʻi—West O‘ahu 

twice daily were estimated at $91,000 to 112,000 

annually.

NPS management of a national historic site at 

Honouliuli Gulch would be funded through 

federal appropriations as part of the annual 

NPS budget and through potential partners 

and grants. The national historic site or 

monument could share administrative, visitor, 

and operational facilities with World War II 

Valor in the Pacific National Monument or 

partner entities. Non-federal entities would 

continue to be eligible for the grants through 

the Japanese American Confinement Sites 

Grant Program for preservation, interpretation, 

and documentation projects associated with 

Honouliuli Internment Camp.

Based on the size and scope of this site, and the 

types of services and assistance proposed, the 

annual cost of NPS operations for the national 

historic site could be expected to be $400,000 

to $750,000. The estimated operational budget 

would primarily fund NPS staff, programs, 

projects, and outreach. 
 Executive Summary  Environmental Assessment xxvii

Specific costs would be reevaluated in 

subsequent, more detailed planning for the unit. 

Planning would consider facility and site design, 

detailed identification of resource protection 

needs, and changing visitor expectations. Actual 

costs to the NPS would vary depending on 

timing and implementation and contributions 

by partners and volunteers. It is assumed that 

the long-range financial needs of Honouliuli 

National Historic Site or Monument would not 

just rely upon federally appropriated funds. 

A variety of other public and private funding 

sources could be sought by the NPS to assist in 

implementation efforts. Other NPS units have 

successfully found partners to help with funding 

major projects, and some of the costs associated 

with actions in the alternatives may prove to be 

less expensive if donated materials, labor, and 

other support can be secured.

Environmental Assessment

BACKGROUND

Before taking an action, the National 

Environmental Policy Act (NEPA) requires 

federal agencies to identify a range of 

alternatives for that action and to analyze the 

potential environmental impacts of that action, 

including any potential adverse environmental 

effects that cannot be avoided if the proposed 

action is implemented. The NPS prepared 

an environmental assessment (EA) for the 

Honouliuli Gulch and Associated Sites Special 

Resource Study to identify and analyze the 

potential environmental and socioeconomic 

consequences of each of the alternatives 

considered in the study. 

IMPACTS 

Consequences are determined by comparing 

likely future conditions under each alternative 

with the existing baseline conditions as 

described in the “no action” alternative. The 

analysis includes consideration of the context, 

intensity, and duration of direct and indirect 

effects of all the alternatives. 

The NPS based analysis and conclusions on 

a review of existing literature, information 

provided by experts within the NPS as well 

as outside organizations, analysis of case 

studies of existing programs in other locations, 

and the professional judgment of the team 

members. The findings of this study will inform 

a recommendation by the Secretary of the 

Interior to Congress. If Congress takes action, 

then new environmental analysis would be 

undertaken prior to implementation actions. 

This new analysis would propose specific 

actions whose specific impacts would be 

assessed prior to implementation.

The NPS evaluated the environmental 

consequences of each alternative on the 

following topics: land use, water resources, 

vegetation, prehistoric and historic 

archeological resources, historic structures / 

cultural landscapes, museum collections, visitor 

experience, and socioeconomics.

The NPS finds that there would be no 

significant impacts associated with the proposed 

alternatives.

ENVIRONMENTALLY PREFERRED 

ALTERNATIVE

The NPS is required to identify an 

“environmentally preferred alternative” in an 

EA. The environmentally preferable alternative 

is determined by applying the criteria suggested 

in the National Environmental Policy Act 

(NEPA) of 1969 and is further guided by the 

Council on Environmental Quality (CEQ). The 

CEQ (46 FR 18026 - 46 FR 18038) provides 

direction that the “environmentally preferable 

alternative is the alternative that would promote 

the national environmental policy as expressed 

in NEPA’s Section 101,” including: 

1. Fulfill the responsibilities of each generation 

as trustee of the environment for succeeding 

generations;

2. Assure for all Americans safe, healthful, 

productive, and aesthetically 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;
xxviii Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

5. Achieve a balance between population 

and resource use which will 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 (NEPA 

Section 101(b)).

Generally, these criteria mean the 

environmentally preferable alternative is the 

alternative that causes the least damage to the 

biological and physical environment and that 

best protects, preserves, and enhances historic, 

cultural, and natural resources (46 FR 18026 – 

46 FR 18038).

Alternative B would protect nationally 

significant resources, including opportunities 

for protecting the Honouliuli site in perpetuity 

should the Monsanto Company donate it to 

the NPS, meeting criterion 1 above. Alternative 

B would also best meet the intent embodied 

in criteria 2, 3, and 4, through providing 

opportunities for protection of the historic 

Honouliuli Internment Camp with more 

opportunities for visitors to learn about the 

history and experience of Japanese American 

and European American incarceration during 

World War II. All alternatives would likely meet 

the principles identified in criteria 5 and 6. 

Although there are no specific actions related 

to these currently in the alternatives associated 

with these criteria, long-standing NPS policies 

and actions would apply. Based on this analysis, 

alternative B best meets the six criteria and 

is therefore the environmentally preferable 

alternative.

The analysis and findings contained in this 

study do not guarantee the future funding, 

support, or any subsequent action by the NPS, 

the Department of the Interior, or Congress. 

Identification of an environmentally preferred 

alternative should not be viewed as a positive or 

negative recommendation by the NPS for any 

future management strategy or action.
1INTRODUCTION
2011 Day of Remembrance Pilgrimage to Honouliuli Internment Camp. Photo: Brian Niiya, Japanese Cultural Center 

of Hawai‘i.
 Chapter 1: Introduction  Purpose and Need 1

CHAPTER 1: INTRODUCTION

This section provides an overview of the purpose 

and scope of the study and describes the study 

process.

Purpose and Need

The Department of the Interior, Environment, 

and Related Agencies Appropriations Act of 

2010, Title 1, Section 125 (123 Stat. 2932), 

October 30, 2009) (See Appendix A) authorized 

the National Park Service (NPS) to “conduct 

a special resource study of the national 

significance, suitability, and feasibility of 

including the Honouliuli Gulch and associated 

sites within the State of Hawai‘i in the National 

Park System.” The legislation stated, “The study 

shall evaluate the Honouliuli Gulch, associated 

sites located on O‘ahu, and other islands located 

in the State of Hawai‘i with respect to—

1. the significance of the site as a component 

of World War II;

2. the significance of the site as the site related 

to the forcible internment of Japanese 

Americans, European Americans, and other 

individuals; and

3. historic resources at the site.”

This legislation was introduced in the Senate 

by Senator Daniel Inouye and Senator 

Daniel Akaka of Hawaiʻi, and in the House 

by Representative Mazie Hirono and former 

Representative and current Hawaiʻi Governor, 

Neil Abercrombie, with numerous cosponsors 

from across the United States and the Pacific 

territories (American Samoa, Guam, and the 

Northern Mariana Islands). 

This study provides information to aid the 

National Park Service in determining whether 

the study areas meet eligibility, suitability, and 

feasibility criteria for designation as units of 

the national park system. The study follows the 

process established by the National Park System 

New Area Studies Act (P.L. 105-391, 16 U.S.C. 

Sec. 1a-5) and addresses the criteria for new 

areas outlined in NPS Management Policies 2006 

(See Appendix B). 

The study evaluates 17 sites associated with 

the history of internment in Hawaiʻi. In this 

study, the NPS ascertained the public’s level of 

interest in nationally recognizing this part of 

United States history and evaluated whether 

one or more of the sites would be appropriate 

for designation as a national park system unit. 

The NPS identified alternative strategies to 

manage and protect the resources, and to 

provide or enhance public understanding, use 

and enjoyment of the sites. Cost estimates for 

operations, acquisition and development are 

also included.

The National Park System New Area Studies 

Act requires that these studies be prepared in 

compliance with the National Environmental 

Policy Act (NEPA). Special resource studies that 

consider a national park unit as an alternative 

are required to complete an environmental 

impact statement (EIS). The NPS determined 

that an environmental assessment (EA) is a 

sufficient level of environmental analysis for this 

study. No significant impacts are anticipated 

from the findings and recommendations of this 

study.

Study Sites

A preliminary list of 13 sites was developed 

based on information obtained through 

personal interviews, declassified documents 

from the Federal Bureau of Investigation 

and Department of Justice, military files, 

newspapers, photographs, and numerous books 

and essays. The University of Hawaiʻi, Japanese 

Cultural Center of Hawaiʻi, and Trans-Sierran 

Archaeological Research provided information 

about internment sites in Hawaiʻi. Site visits by 

the study team were conducted where possible 

to determine current conditions and integrity 

of the sites. Four additional sites were recorded 

during the preparation of this report.

The Honouliuli Internment Camp is the best 

documented of the known sites. Trans-Sierran 

Archaeological Research in cooperation 

with the Japanese Cultural Center of Hawaiʻi 

provided site documentation in Jigoku-Dani: An 

Archaeological Reconnaissance of the Honouliuli 

Internment Camp of O‘ahu, Hawaiʻi. A National 

Register nomination was also prepared for 

Honouliuli Internment Camp by TransSierran Archaeological Research for submittal 

to the National Park Service and Keeper of 

the National Register of Historic Places. The 

nomination assesses the property’s significance, 

age and integrity using criteria for National 
2 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Register designation. Honouliuli Internment 

Camp was listed in the National Register of 

Historic Places in February 21, 2012 (Burton 

and Farrell 2011a). 

Chapters 2 and 3 provide information on the 

study sites and an analysis of their significance.

Study Process

LEGISLATIVE AND POLICY DIRECTION

Several laws and policies outline the criteria for 

units of the national park system. The National 

Park System New Area Studies Act (P.L. 105-

391, 16 U.S.C. Sec. 1a-5) establishes the basic 

process for NPS studies of potential new 

national park areas. NPS management policies 

provide further guidance. 

According to NPS Management Policies 2006, a 

proposed addition to the national park system 

will receive a favorable recommendation from 

the NPS only if it meets all of the following four 

criteria for inclusion:

1. It possesses nationally significant natural or 

cultural resources;

2. It is a suitable addition to the system;

3. It is a feasible addition to the system; 

4. It requires direct NPS management, instead 

of alternative protection by other public 

agencies or the private sector.

These criteria are designed to ensure that the 

national park system includes only the most 

outstanding examples of the nation’s natural 

and cultural resources. The NPS also recognizes 

that there are other management alternatives for 

preserving the nation’s outstanding resources.

NPS management alternatives are developed 

for sites that meet all four of the criteria for 

inclusion listed above. Further definition of 

each of these criteria is provided in the related 

sections of this study.

PUBLIC INVOLVEMENT

The NPS launched public scoping for this 

study in February 2011. A notice of scoping 

was published in the Federal Register on May 2, 

2011 (Vol.76, No. 83, 24514–15). The study team 

produced and distributed an informational 

newsletter and press releases to the media, 

individuals, organizations, and government 

officials. Public information was made available 

on the National Park Service’s Planning, 

Environment and Public Comment (PEPC) 

website and project website at www.nps.gov/

pwro/honouliuli. 

In February and March 2011, the study team 

held eight public scoping meetings on the 

six main islands in Hawaiʻi. Over 100 people 

attended the public meetings. Local, state, and 

federal government officials and stakeholders 

were also consulted. During this time, 

numerous articles and opinion pieces about the 

study appeared in area newspapers. 

The comment period for public scoping 

extended to June 1, 2011, thirty days after 

publication of the notice of scoping in the 

Federal Register. See Chapter 8 for a full 

description of public involvement, consultation, 

and coordination conducted for the study.

Descendants of former internees at Honouliuli in 2011. Liane 

Sumida (left), Mari Aipa (second from left), and Sarah Sumida 

(right) are the granddaughters and great-granddaughter of Sam 

Masao Nishimura, who was incarcerated at Honouliuli. Photo: 

Jeffery Burton.
 Chapter 1: Introduction  Study Process 3

DEVELOPMENT OF ALTERNATIVES

The NPS study team considered alternatives 

based on information gathered from the public 

and stakeholders, internal NPS discussions, 

site research, and management models within 

the national park system. The alternatives were 

narrowed down to two feasible alternatives 

contained in this study report. These 

alternatives are based upon the suitability and 

feasibility analysis of all 17 sites and include 

those sites that meet the criteria for national 

park system additions cited above. 

The first alternative is the “No Action” 

alternative. It would continue existing 

management of the internment sites and serves 

as a baseline for comparison to the action 

alternative. The action alternative includes 

designation of Honouliuli Internment Camp 

as a unit of the national park system. The 

action alternative explores federal recognition 

of significant resources and opportunities 

for technical assistance and cooperative 

management with the NPS.

See Chapter 6 for a full description of the 

alternatives.

THE SELECTED ALTERNATIVE

The National Park Service special resource 

study process requires that the study identify the 

alternative or combination of alternatives that in 

the professional judgment of the NPS Director 

is most effective and efficient in protecting 

significant resources and providing for visitor 

enjoyment. Based on public and stakeholder 

input and professional judgment, the NPS 

selected alternative B, the action alternative, 

which would provide for the establishment of a 

national historic site or national monument. The 

National Park Service has determined this to 

be the most effective and efficient alternative in 

protecting significant resources and providing 

for visitor enjoyment.

REPORT PUBLICATION, REVIEW, 

AND TRANSMITTAL OF FINAL 

RECOMMENDATIONS

Chapter 8: Consultation and Coordination 

describes the public involvement and agency 

consultation that took place during the 

special resource study process. The public 

comment period for the Honouliuli Gulch and 

Associated Sites Draft Special Resource Study 

and Environmental Assessment was open from 

May 8 to July 15, 2014. Comments received 

have been incorporated into this final study 

report. A Finding of No Significant Impact 

(Appendix E) and errata to the draft study 

report (Appendix F) were completed by the 

NPS study team, which will transmit them with 

the report to the Secretary of the Interior. The 

Secretary will submit the final special resource 

study to Congress, along with the Secretary’s 

recommendations for the area.

Photos (top to bottom): 1. The NPS study team on site at 

Honouliuli. 2. Following the now-overgrown path that once led 

to the guard towers, Honouliuli Internment Camp. Photos: NPS, 

2013.
4 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

RELATED STUDIES

Other efforts have recently been completed 

which provided guidance and resource 

information for the study.

Japanese Americans in World War II: 

A National Historic Landmark Theme 

Study (2012)

This study was authorized by Public Law 

102-248 to identify key sites related to the 

incarceration of Japanese Americans during 

World War II. It was completed by the NPS in 

2012. The study outlines the historic context 

of the period from 1941–46 and identifies sites 

potentially eligible for designation as national 

historic landmarks. 

World War II Japanese American 

Internment Sites in Hawai‘i (2007)

This study was completed in 2007 by Jeffrey 

F. Burton and Mary M. Farrell (Trans-Sierran 

Archaeological Research) for the Japanese 

Cultural Center of Hawai‘i. It documents 

the locations and conditions of eight sites 

associated with the internment of Japanese 

civilians in Hawai‘i during World War II. The 

study provides recommendations for future 

research, interpretation, and management of 

these sites.
2HISTORICAL OVERVIEW AND RESOURCES
Aerial view of Coast Guard Station and Internment Camp at Sand Island. The Coast Guard Station is in the foreground. Compound 

#3 is in the background, with tents and barracks surrounded by barbed wire fence. Japanese and Japanese Americans were interned

there until 1943. Photo: courtesy of the Japanese Cultural Center of Hawai‘i, U.S. Coast Guard Collection.
Chapter 2: Historical Overview and Resources  Part I: Historical Overview 5

CHAPTER 2: HISTORICAL 

OVERVIEW AND RESOURCES

This chapter describes the history and sites 

associated with the internment experience 

in Hawai‘i. Part I describes the context and 

significant events in the history of the internment 

in Hawai‘i. Part II describes the primary places 

associated with the internment in Hawai‘i.

Part I: Historical Overview 

The historical context provides the background 

necessary for identifying resources associated 

with the internment experience in Hawaiʻi, 

and for assessing the significance of these 

resources as described in Chapter 3 of this study 

(Resource Significance).

The information in this chapter is largely 

derived from World War II Japanese American 

Internment Sites in Hawaiʻi (Burton and Farrell 

2007) and Jigoku-Dani: An Archaeological 

Reconnaissance of the Honouliuli Internment 

Camp, O‘ahu, Hawaiʻi, prepared for the 

Japanese Cultural Center of Hawai‘i by TransSierran Archaeological Research principals 

Jeff Burton and Mary Farrell (Burton and 

Farrell 2011). Other information came from the 

National Register of Historic Places (Burton 

and Farrell 2008), and the Japanese Americans 

in World War II National Historic Landmark 

Theme Study (NPS 2012). A more detailed 

narrative can be found in those documents.

IMMIGRATION AND PRE-WAR HAWAI‘I 

(1852–1941)

Looking for cheap, dependable labor, plantation 

owners encouraged immigration to Hawai‘i as 

early as 1852, with the importation of laborers 

from China to work on sugar plantations (Daws 

1968, 179). Immigrants from Portugal, Norway, 

Sweden, and Germany were welcomed as 

laborers and potential citizens (ibid., 211–12). 

Large-scale Japanese immigration to Hawai‘i 

began in 1868 when approximately 150 

Japanese citizens were recruited for work on 

sugar plantations. Between 1885 and 1894, 

nearly 30,000 Japanese contract laborers came 

to the islands, most staying on after their 

original contracts expired. Japanese immigrant 

businessmen and professionals followed. 

To circumvent an anticipated ban on future 

recruitment, plantations brought in more than 

26,000 Japanese after Hawai‘i was annexed by 

the United States in 1899, and before it was 

designated a territory in 1900 (Commission on 

Wartime Relocation and Internment of Civilians 

[CWRIC] 1982, 262–63). With the passage of 

 Japanese store, Honolulu, c. 1895–1910. Photo: Library of Congress.
6 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

the Immigration Act of 1924, immigration from 

Japan (and other countries and territories in the 

Asia Pacific) was terminated. The ban remained 

with few alterations until the Immigration and 

Nationality Act of 1965.

On the international front, relations between 

the Japan and the U.S. were increasingly tense in 

the lead up to Pearl Harbor. Japan’s seizure of 

Manchuria in 1931, its alignment with Germany 

and Italy in 1936, and its undeclared war with 

China beginning in 1937 were statements of 

its expansionist intentions. In Europe, the U.S. 

allied with Britain against the Axis nations and 

readied itself for possible war in the Pacific.

In Hawai‘i, partly because of their large 

numbers, Japanese Americans and Japanese 

nationals had opportunities beyond the 

plantation fields as professionals, entrepreneurs, 

and skilled workers (Odo 2004, 24). By 1940, 

race relations on Hawai‘i were far better than 

on the mainland, with Japanese immigrants 

integrated into the economy and represented 

in government, education, medicine, and law 

(CWRIC 1982, 263). However, they were not 

immune from racism or discrimination. As 

on the mainland, those born in Japan were 

prohibited from becoming naturalized citizens 

on the basis of race (Niiya 2001, 331). 

Japanese in Hawai‘i were also seen as potentially 

dangerous if the United States and Japan were 

to go to war. Tetsuden Kashima, a scholar of 

Japanese American imprisonment during World 

War II, found evidence that both the Army 

and the Federal Bureau of Investigation (FBI) 

gathered data on Nikkei (Japanese and Japanese 

American) residents in the late 1930s through 

World War II. The Army recommended the 

arrest of 128 Nikkei individuals, the closing of 

60 amateur radio stations, and the confiscation 

of 23 businesses under a regime of imposed 

martial law (Kotani quoted in Kashima 2003, 

68). From 1939 to the beginning of World War 

II, the FBI designated 338 Issei (immigrants 

born in Japan) and nine Nisei (American-born 

children of Issei) in Hawai‘i as candidates for 

custodial detention (Kashima 2003, 68). 

A separate effort to document aliens of Japanese 

and European heritage in Hawai‘i began in 

August of 1940 under provisions of the federal 

Alien Registration Act (Allen 1950, 430). Aliens 

in the islands were fingerprinted and registered. 

By the start of World War II, the Nikkei, as 

Japanese immigrants and their descendants are 

called, numbered almost 160,000, comprising 

the largest single ethnic group and nearly 40 

percent of the total population of Hawaiʻi 

(Kashima 2003, 67).

THE START OF WORLD WAR II AND 

MARTIAL LAW IN THE TERRITORY OF 

HAWAI‘I (1941–44)

The bombing of Pearl Harbor on December 

7, 1941 resulted in the deaths of more than 

2,340 military personnel and more than 60 

civilians (Grant 2010, 4). Shortly after noon 

on December 7, Lieutenant General Walter 

Japanese emigrants on sisal plantation, Hawai‘i, c. 1910–15. Photo: Library of Congress.
Chapter 2: Historical Overview and Resources  Part I: Historical Overview 7

C. Short of the Army visited the Governor of 

Hawaiʻi, Joseph Poindexter, and requested 

that the governor declare martial law. Both 

General Short and Governor Poindexter issued 

proclamations declaring martial law, both of 

which had been prepared months in advance 

(Allen 1950, 37–38; Anthony 1975, 5–6). Under 

martial law, Hawai‘i was governed by Army 

generals Walter Short, Delos Emmons, and 

Robert C. Richardson, Jr. 

Poindexter’s proclamation on December 7, 

1941 placed the territory of Hawai‘i under 

martial law, suspended the writ of habeas corpus

(the requirement for a person under arrest to 

be brought before a judge or into court), and 

placed the judicial branch of the government 

in the hands of the military (Allen 1950, 38). 

The military closed the civilian courts and 

established its own courts with authority over 

civilians (Kashima 2003, 69). The military 

enforced ordinary civil and criminal law dealing 

with everything from disorderly conduct 

to murder, and military control in Hawaiʻi 

restricted nearly every aspect of daily life. 

The General Orders promulgated under martial 

law covered not just military functions like 

curfew and blackout rules, but also aspects 

of daily life and recreation. This included 

regulation of traffic, firearms, gasoline, food 

and liquor, radios, the press, telephone use, 

wages and employment, the possession of 

currency, the collection of garbage, rent control, 

restaurants and bars, bowling alleys, and the 

chlorination of water. 

The Army-controlled military courts considered 

cases ranging from the most serious criminal 

cases to dog-leash violations. The military 

conducted some 50,000 trials of civilians 

throughout the islands during the war, with a 

99 percent conviction rate in the 22,000 cases 

on the island of O‘ahu in 1942 and 1943. The 

average trial lasted five minutes, and legal 

counsel was seldom at hand once it became 

common knowledge that the presence of a 

defense lawyer would ensure a harsh sentence 

(Scheiber and Scheiber 2003).Initially intended 

to last for only several months, martial law was 

maintained for nearly three years until October 

1944 (Grant 2010, 5). 

INTERNMENT IN HAWAI‘I (1941–45)

Martial law was the legal authority for the 

incarceration of hundreds of individuals on 

suspicion of disloyalty to the United States. In 

the months following the Pearl Harbor attack, 

President Roosevelt and Secretary of the Navy 

William Franklin Knox pressured the appointed 

military governor, General Delos C. Emmons, 

to imprison all residents of Japanese ancestry in 

Hawai‘i, confine them to one island, or remove 

them to the mainland (Kashima 2003, 75). 

However, mass incarceration of all Japanese 

and Americans of Japanese ancestry in Hawaiʻi 

was not a possibility with more than 35,000 

resident aliens and 124,000 American citizens 

forming nearly half of Hawai’i’s population. 

General Emmons took a measured approach 

to mass incarceration, believing that it was not 

necessary, feasible, or useful in Hawai‘i and 

could potentially do more harm than good 

(Kashima 2003, 72–78). 

The round-up and imprisonment of aliens 

and civilians began on December 7th while the 

bombing of Pearl Harbor was still in progress, 

even before martial law had been declared. 

The War Department ordered the internment 

of all individuals who had been identified on 

the custodial detention list (Kashima 2003, 

69). These included leaders in the Japanese 

community who had significant community 

influence, were educated, were teachers, or had 

access to transportation or communications. 

They included members of the Japanese 

Pearl Harbor Naval Base and the U.S.S. Shaw ablaze following 

the Japanese attack, December 7, 1941. Photo: Library of 

Congress.
8 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

consulate, and community members who served 

in an unofficial consular capacity for those 

wanting to communicate officially with Japan 

on legal issues of births, deaths, marriage, and 

other business. They also included Shinto and 

Buddhist priests, Japanese language teachers, 

those with radios, and farmers and fishermen 

with access to boats and other transport. 

Martial arts instructors, travel agents, those 

with access to the press, and Kibei (American 

citizens of Japanese ancestry who had been 

educated in Japan) were also targeted. In some 

cases, those arrested were considered “guilty by 

association” or were identified by informants, 

some without just cause.

Beginning on December 8, others not on the 

custodial detention list were also arrested. By 

December 9, the FBI and military had arrested 

345 Japanese nationals, 22 U.S. citizens of 

Japanese ancestry, 74 German nationals, 11 

Italian nationals, 19 U.S. citizens of German 

ancestry, and 2 U.S. citizens of Italian ancestry 

(ibid, 72). 

On O‘ahu, the FBI and the Army carried out 

the arrests together. The FBI handed the 

prisoners over to the military police at the U.S. 

Immigration Station at Honolulu, which was 

then used as a temporary detention station. 

Some individuals were taken to the downtown 

Honolulu Police Department Headquarters 

or the Military Police Headquarters (formerly 

the Yokohama Specie Bank) before being 

transferred to the Immigration Station. On the 

other Hawaiian Islands, the FBI, the army’s 

military intelligence personnel, and local police 

collaborated to make the arrests (Kashima 2003, 

69–71). 

On Hawai‘i Island, internees were held 

temporarily at Kilauea Military Camp, Waiākea 

Prison Camp near the Hilo Airport, and the 

Hilo Independent Japanese Language School. 

On Kaua‘i, the Wailua County Jail, Waimea Jail, 

and Kalāheo Stockade were used as temporary 

detention centers, and one internee was held 

in the shower room at the Līhu‘e Plantation 

gymnasium (Saiki 1982, 62). On Lāna‘i, those 

arrested were held at the Lāna‘i City Jail. On 

Molokaʻi, an old jail at Kaunakakai was used 

for temporary detention. Detainees from Maui, 

Molokaʻi, and Lāna‘i were later taken to the 

Maui County Jail and a detention center at 

Ha‘ikū, also on Maui. 

At the temporary detention centers, the fate 

of detainees varied: some were questioned 

and released; some were sent to the U.S. 

Immigration Station in Honolulu for further 

interrogation; and some were held for as long as 

six months before being sent to an internment 

camp (Kashima 2003, 74). Those arrested 

were to have two hearings, one with a military 

intelligence board, and the other with a review 

board consisting of three civilians and two army 

officers (ibid, 73–74). 

After the hearings, those who were not released 

were sent from the U.S. Immigration Station 

across Honolulu Harbor to the Sand Island 

Detention Station. The facility was set up on 

December 8, 1941, and operated until March 1, 

1943. Most of the internees sent to Sand Island 

were later transferred to mainland camps. 

Ten ships departed Hawai‘i transferring 

internees and their family members to the 

mainland between February 17, 1942 and 

December 2, 1943. The first several ships 

removed internees from Sand Island and 

transferred them to Department of Justice 

internment camps at Bismarck, North Dakota; 

Lordsburg, New Mexico, Santa Fe, New 

Mexico; and Crystal City, Texas (Kashima 

86). In 1942, family members of interned men 

were given the option to join them on the 

mainland. Many family members chose this 

voluntary incarceration because they didn't 

have any financial support without their head 

of household. The War Department also 

selectively removed Japanese American citizens 

and sent them to the mainland. These family 

members and selectively removed Japanese 

Americans were sent to centers run by the War 

Relocation Authority where mainland Japanese 

Americans were confined for the duration of the 

war (Kashima 86). Locations where they were 

sent included Jerome, Arkansas; Topaz, Utah; 

and Tule Lake, California.

Beginning March 2, 1943, internees remaining 

at Sand Island were transferred to the 

Honouliuli Internment Camp also on the island 

of O‘ahu, which had been constructed to house 

both internees and prisoners of war. Historical 

records suggest Honouliuli Internment Camp 

was built to allow expansion of the Honolulu 

Embarkation Port facilities on Sand Island 

(U.S. Army 1945, 10), and because the camp’s 

location on Sand Island was subject to direct 

attack or landings by enemy forces, it was in 

violation of international law (Springer 1943). 

Honouliuli was markedly different from the 

other detention facilities in Hawai‘i. While 
Chapter 2: Historical Overview and Resources  Part I: Historical Overview 9

the other locations were ad-hoc places to 

keep internees temporarily, Honouliuli was 

sited and constructed for the express purpose 

of confining internees and prisoners of war 

during World War II. Honouliuli illustrates 

the government’s clear thinking on policy 

implementation; it was a place that the 

government could build where, when, and what 

it needed. 

Honouliuli Internment Camp held 

approximately 400 internees. Of these, three 

hundred sixty-four were Nikkei, including 

six women (JCCH, pers. comm. 2014 and 

Soga 2007, Appendix 4). Most of the Nikkei 

interned were American citizens of Japanese 

ancestry who had been educated in Japan, 

some of whom held dual citizenship (JCCH, 

pers. comm. 2014). In addition, 33 of the 36 

remaining internees—described as being of 

“German” or “Italian” heritage—were American 

citizens, including seven women (Rosenfeld 

2014).

Some of the Honouliuli internees were later 

transferred to mainland Department of Justice 

internment camps or War Relocation Authority 

centers. Other Honouliuli internees were 

eligible for parole; however, if an internee 

wished to leave the camp and was eligible 

to do so, that person was required to sign a 

statement promising they would not contest the 

imprisonment in court. Failure to sign would 

result in continued imprisonment.

It is difficult to confirm the precise numbers of 

internees from Hawai‘i because civilians were 

arrested, transferred, and released throughout 

the war. For example, although no Irish are 

listed in the known compilations, Suzanne 

Falgout of the University of Hawai‘i—West 

O‘ahu has found records indicating a woman 

from Ireland was interned at Honouliuli 

because her anti-British attitude was considered 

potentially pro-Nazi. A useful table (adapted 

for this report as Table 2-1) shows the number 

of internees of Japanese ethnicity confined on 

each island at different time periods, but the 

author Gary Okihiro makes clear that the totals 

were fluid, reflecting transfers, new arrests, and 

releases. Further research will likely refine the 

estimates of the number of people interned.

Drawing of the women’s internee compound at Honouliuli by Dan T. Nishikawa, April 10, 1943. Image courtesy of the Japanese Cultural 

Center of Hawai‘i, Dan Toru Nishikawa Family Collection.
10 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

The best estimate for the number of people of 

Japanese ancestry incarcerated from Hawai‘i 

is approximately 2,456. This number included 

875 predominantly Issei males arrested and 

transferred to Department of Justice internment 

camps on the mainland; 1,217 individuals 

of Japanese ancestry in Hawaiʻi sent to War 

Relocation Authority camps on the mainland; 

and approximately 364 Nikkei imprisoned in 

Hawai‘i (Kashima 2003, 86). 

In addition, there were 139 Caucasion internees 

from Hawai‘i (Rosenfeld 2014). One hundred 

twenty-five of them were listed in an FBI 

memo at the end of March 1942, which cited 

67 German aliens, 40 U.S. citizens of German 

ancestry, 15 Italian aliens, two U.S. citizens 

of Italian ancestry, and one Norwegian alien 

(Shivers 1942). New research indicates that 

some internees reported to be “German” and 

“Italian” were of other nationalities or cultural 

affiliations. In summary, individuals who were 

interned in Hawai’i included people of Filipino, 

Okinawan, Japanese, German, Italian, Danish, 

Finnish, Irish, Lithuanian, Korean, Norwegian, 

and Swedish descent, as well as European Jews 

who had escaped persecution by the Nazis 

(Rosenfeld 2014).

INCARCERATION OF NIKKEI ON THE 

MAINLAND (1941–45)

As in Hawai‘i, immediately after the attack on 

Pearl Harbor leaders in the Japanese American 

community on the West Coast were arrested, 

bank accounts were frozen, and short-wave 

radios, cameras, and other items deemed 

contraband were seized. Those arrested on the 

mainland and those from Hawai‘i who were 

brought to the mainland were initially interned 

in temporary detention centers run by the 

Department of Justice, such as Angel Island in 

San Francisco Bay. Internees were later sent to 

permanent internment centers, first under the 

Army at sites such as Lordsburg, New Mexico, 

and then back to Department of Justice centers 

such as Santa Fe, New Mexico. Much later—

after June 11, 1943—many of the internees 

from the Santa Fe camp were able to reunite 

with their families at the Department of Justice 

Family Internment Camp in Crystal City, Texas. 

Conditions for the incarceration of people of 

Japanese ethnicity were significantly different on 

the mainland. On the mainland, incarceration 

soon included the entire Japanese American 

population of the West Coast. The “relocation,” 

as the mass incarceration was called, was 

authorized by Executive Order No. 9066, and 

signed by President Franklin D. Roosevelt on 

February 19, 1942. Although the Executive 

Order empowered the Army to designate 

areas from which “any or all persons may be 

excluded” the Army enforced its provisions 

almost completely against individuals of 

Japanese ancestry, of whom two thirds were 

American born citizens (NPS 2005, 2). Those 

incarcerated included people from all walks 

of life: native-born citizens, the elderly, World 

War I veterans given citizenship by an act of 

Congress, Japanese Alaskans, children, and 

even babies of half-Japanese ancestry living in 

Caucasian foster homes and orphanages.

By June 2, 1942, all Nikkei on the West Coast, 

except for a few left behind in hospitals, were in 

temporary detention camps, called “assembly 

centers,” located at fairgrounds and racetracks 

near major metropolitan areas along the West 

Photos (left to right): 1. Civilian Exclusion Order demanding the removal of all persons of Japanese ancestry, San Francisco, April 1942. 

2. In response to Civilian Exclusion Order No. 20, San Francisco residents of Japanese ancestry wait to register with the Civil Control 

Station. Photos by Dorothea Lange, courtesy Bancroft Library, University of California, Berkeley.
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Chapter 2: Historical Overview and Resources  Part I: Historical Overview 11

Mainland sites associated with the incarceration of persons of Japanese descent during World War II. 
12 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Photos (clockwise from top left): 1. Families 

board a bus in Centerville, CA that will take 

them to a temporary detention camp known 

as an “assembly center.” Photo by Dorothea 

Lange, May 1942. 2. A grandfather and 

grandchildren await transportation, Hayward, 

CA. Photo by Dorothea Lange, May 1942. 

3. Families arrive at the WRA center at Heart 

Mountain, WY, September 1943. Photo 

by Bud Aoyama. 4. Arrivals at the Salinas 

Assembly Center, California, March 1942. 

Photo by Clem Albers. All photos:courtesy 

Bancroft Library, University of California, 

Berkeley.
Chapter 2: Historical Overview and Resources  Part I: Historical Overview 13

were transferred to the Tule Lake Segregation 

Center in California (Ogawa and Fox 1991, 

135). During 1945, an additional 12 American 

citizens of Japanese ancestry were arrested and 

detained pending exclusion. In fact, Ogawa and 

Fox report that citizens remained prisoners 

even after the last Issei were released: 18 alien 

internees were released from the Honouliuli 

Internment Camp on September 14, 1945, 

leaving only three citizens in custody (ibid, 138). 

The civilian prison compound at Honouliuli 

was closed in 1945 (Kashima 2003, 86) but the 

camp may have been used into 1946 for the 

transfer of prisoners of war or other military 

activities.

The mass exodus of Nikkei from the WRA 

centers occurred during the spring, summer, 

and fall of 1945. The last War Relocation 

Authority center, Tule Lake, closed on 

March 19, 1946. The last Justice Department 

internment camp, Crystal City, closed on 

February 27, 1948.

REDRESS (1960S–1980S)

During the 1960s, a group of Japanese 

Americans, inspired by the Civil Rights 

movement, began an effort to bring awareness 

and justice to what had occurred to their 

parents and grandparents during World War II. 

This effort is known as the “redress movement.” 

Initially, their efforts led to a proclamation by 

President Gerald R. Ford in 1976, stating that 

the incarceration had been wrong and was a 

national mistake, never to be repeated. 

On July 31, 1980, President Jimmy Carter 

signed Public Law 96-317, establishing the 

Commission on Wartime Relocation and 

Internment of Civilians (CWRIC) and initiating 

the investigation of these wartime events. The 

Commission held hearings nationwide with 

over 750 witnesses, the majority of whom 

were Nikkei who experienced incarceration. 

On February 22, 1983 the Commission made 

public its report, Personal Justice Denied. Their 

conclusion after 18 months of research was that 

“the promulgation of Executive Order 9066 

was not justified by military necessity, and the 

decisions which followed from it-detention, 

ending detention, and ending exclusion-were 

not driven by analysis of military conditions. 

The broad historical causes which shaped these 

decisions were race prejudice, war hysteria, and 

a failure of political leadership.” (CWRIC1997: 

194). 

Coast. From the temporary detention facilities 

they were moved to ten inland centers run by 

the War Relocation Authority (WRA). 

Four U.S. Supreme Court cases challenged the 

mass incarceration of American citizens and 

aliens of Japanese ancestry during World War II. 

In three cases, the United States Supreme Court 

upheld the convictions of Fred Korematsu, 

Gordon Hirabayashi and Minoru Yasui, testing 

the constitutionality of the curfew imposed on 

Japanese Americans and the government’s right 

to exclude people of Japanese ancestry from the 

West Coast based on “military necessity.” 

But in the fourth case, decided by the Supreme 

Court on December 18, 1944, the justices 

ruled unanimously that Mitsuye Endo 

should be released unconditionally, that is 

without having to follow the indefinite leave 

procedure established by the WRA. The 

court stated that the WRA “has no authority 

to subject citizens who are concededly loyal 

to its leave procedure.” While sidestepping 

the constitutional question of the right of the 

government to hold citizens without cause in 

wartime, it did in effect free all loyal Japanese 

Americans still held in the WRA centers. 

Anticipating the Supreme Court decision, 

on December 17, 1944, the War Department 

announced the lifting of the West Coast 

exclusion orders, and the WRA simultaneously 

announced that the centers would be closed 

within one year.

END OF THE WAR AND RELEASE (1944–

1960S)

In Hawai‘i, martial law had been the legal 

authority for incarcerating U.S. citizens as 

well as resident aliens. When martial law was 

lifted in Hawaiʻi on October 24, 1944, there 

was no longer a legal authority to hold citizens. 

However, six days before martial law ended, 

President Roosevelt signed Executive Order 

9489, modeled after Executive Order 9066. This 

executive order authorized Hawai‘i’s military 

commander not only to intern enemy aliens, but 

also to expel from the islands any U.S. citizen 

who was considered a security threat. Citizens 

could be arrested and detained, pending their 

exclusion from the territory of Hawaiʻi (Okihiro 

1992, 268–69). 

Under the authority of Executive Order 9489, 

on November 11, 1944, the 67 remaining 

Japanese American citizens held at Honouliuli 
14 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Evidence discovered following the war from 

FBI and Office of Naval Intelligence reports 

led to retrials in the early 1980s overturning 

convictions of Fred Korematsu, Gordon 

Hirabayashi, and Minoru Yasui on charges 

related to their refusal to submit to curfews and 

incarceration based on race. The courts found 

that the government had intentionally withheld 

reports and other critical evidence at trials all 

the way up to the Supreme Court, which would 

have proved that there was no military necessity 

for the exclusion, and thus, for the incarceration 

of Japanese Americans.

On August 10, 1988, President Ronald 

Reagan signed the Civil Liberties Act of 1988, 

which wrote into law the U.S. CWRIC’s 

recommendations. When President George 

H. W. Bush signed the appropriation bill on 

November 21, 1989, payments were set to 

begin on October 9, 1990. The oldest survivors 

received their redress checks of $20,000 

first, along with a letter of apology signed by 

President Bush. The Civil Liberties Act also 

established a fund for educational programs, 

called the Civil Liberties Public Education 

Fund.

COMMEMORATION (1980S–PRESENT)

Since 1988 four sites have been set aside by the 

federal government to provide opportunities 

for public education and interpretation of the 

incarceration of Japanese Americans during 

World War II.All four sites are on the mainland: 

Manzanar National Historic Site, California, 

designated in 1992; Minidoka Internment 

National Monument, Idaho, designated in 2001 

and renamed Minidoka National Historic Site 

in 2008; Bainbridge Island Japanese American 

Memorial called Nidoto Nai Yoni (Let it not 

happen again) Memorial, Bainbridge Island, 

Washington, 2008; and the Tule Lake Unit of 

World War II Valor in the Pacific National 

Monument, California, designated in 2008. In 

2007, Congress authorized a $38 million grant 

program for the preservation and interpretation 

of related historic sites called the Japanese 

American Confinement Sites Grant Program. 

Through this grant program, the NPS has 

awarded $9.5 million to nonprofit organizations; 

educational institutions, state, local, and 

tribal governments; and other public entities 

throughout the United States.
Chapter 2: Historical Overview and Resources  Part I: Historical Overview 15

Table 2-1: Number of Persons of Japanese Ethnicity Confined in Internment Camps in Hawai‘i 

during World War II (adapted from Okihiro 1992, 267)

Date

Internment Sites*

O‘ahu† Kaua‘i Maui Molokaʻi Lāna‘i Hawai‘i Total

1942

Jan. 190 41 51 4 2 85 373

Feb. 292 53 56 4 3 110 518

Sept. 319 9 9 6 343

1943

June 238 238

Aug. 229 1 4 234

Dec. 169 1 170

1944

Jan. 324 324

June 184 2 2 188

Oct. 117 117

1945

Sept. 25 25

* Internment Sites: O‘ahu—Honolulu Immigration Station, Sand Island Detention Camp, Honouliuli 

Internment Camp; Kaua‘i—Wailua County Jail, Waimea undetermined location, Kalāheo Stockade; Maui—

Maui County Jail, Ha‘ikū Camp; Molokaʻi and Lāna‘i—county jails; Hawai‘i—Kilauea Military Camp, Waiākea 

Prison Camp.

† O‘ahu counts include those transferred from other islands.
16 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Table 2-2: Sites Associated with the Internment in Hawai‘i during World War II

Site Primary (Used for at 

least 10 prisoners)

Secondary (Used 

for fewer than 10 

prisioners)

Oʻahu

Honolulu Military Police Station (Yokohama Specie Bank) √

Honolulu Police Department √

Honouliuli Internment Camp √

Sand Island Detention Camp √

U.S. Immigration Station √

Island of Hawai‘i 

Kilauea Military Camp (KMC) Detention Camp and 

Prisoner of War Camp √

Hilo Independent Japanese Language School √

Waiākea Prison Camp √

Kaua‘ì

Kalāheo Stockade √

Kauaʻi County Courthouse—Līhu‘e √

Līhu‘e Plantation Gymnasium √

Wailua County Jail √

Waimea Jail √

Maui

Maui County Jail √

Ha‘ikū Military Camp √

Molokaʻi

Kaunakakai Jail and Courthouse √

Lāna‘i

Lānaʻi City Jail and Courthouse √

The data in this table is based on best reliable sources and may be updated as more research is acquired.
Chapter 2: Historical Overview and Resources  Part II: Sites Associated with the Internment in Hawai‘i 17

Part II: Sites Associated with the 

Internment in Hawai‘i

GEOGRAPHIC SCOPE

Based on the legislation passed by Congress 

authorizing this study, its geographical scope is 

focused broadly on sites in the state of Hawaiʻi 

that are associated with the internment of 

American citizens and aliens of Japanese and 

European heritage during World War II. 

IDENTIFICATION OF RESOURCES

Research on sites associated with the 

incarceration was formally undertaken 

for this study in December 2010, and all 

other contributing research was completed 

separately outside the scope of this study. The 

identification of resources resulted primarily 

from the work of Trans-Sierran Archaeological 

Resources, the staff and volunteers of 

the Japanese Cultural Center of Hawaiʻi, 

the University of Hawaiʻi, and interested 

individuals. Studies include interviews, oral 

histories, and document reviews conducted 

during the past several decades, research at the 

National Archives, and additional archival and 

archeological field research by the University of 

Hawaiʻi faculty and students. 

Thirteen sites related to the internment in 

Hawai‘i were originally identified in December 

2010 based on work completed by TransSierran Archaeological Resources for the 

Japanese Cultural Center of Hawai‘i. Over the 

course of one year, the list of sites rose from 

13 to 17. The four additional sites identified 

include the downtown Honolulu Police 

Station, the Yokohama Specie Bank (across 

the street from the Police Station) (Mori, pers. 

comm. 2011), the Hilo Independent Japanese 

Language School where individuals were 

detained pending transfer to Oʻahu (NunesAtabaki and Nunes 1999, 41), and the Kaua‘i 

County Courthouse, where Kauaʻi internee 

hearings were held. Given the breadth of the 

geographic area and complexity of the history, it 

is likely that additional sites associated with the 

internment will emerge over time. 

Sites or locations associated with the 

internment in Hawaiʻi correspond to Table 2-2. 

“Primary” sites are those that housed at least 

10 prisoners, generally for more than several 

weeks. “Secondary” sites are those that were 

used as prisons for fewer prisoners, usually 

for shorter periods of time. Also included in 

the “secondary” category are sites where no 

internees were imprisoned, but where activities 

related to the internment occurred, such as 

hearings. Each of these properties may include 

buildings such as houses, courthouses, jails, 

and/or sites such as detention locations and 

military camps. 

Historic resources associated with internment 

in Hawai‘i include eight primary sites where 

at least ten internees were confined, and eight 

secondary sites, where fewer internees were 

confined. The secondary sites also include the 

Kauaʻi County Courthouse in Līhu‘e, where 

internee hearings were held. In most cases, 

because of the immediacy of the roundup and 

arrests, existing facilities, including jails, schools, 

immigration stations, and military installations 

were used to confine the internees. 

O‘AHU INTERNMENT SITES

Five sites were used on the island of Oʻahu: the 

Honolulu Police Department Headquarters, 

the Honolulu Military Police Station, the U.S. 

Immigration Station, Sand Island Detention 

Camp, and Honouliuli Internment Camp. 

Honolulu Police Department 

Headquarters and Yokohama Specie 

Bank / U.S. Army Police Station, 

Downtown Honolulu

The downtown Honolulu Police Department 

Headquarters at 842 Bethel Street was a 

location where some individuals were taken 

on December 7, 1941, before being transferred 

to the U.S. Immigration Station on Ala Moana 

Boulevard (Mori 2011). During the war, it 

became the location of the Alien Property 

Custodian office, which confiscated property 

owned by foreign citizens. Across the street, at 

36 Merchant Street, was the Yokohama Specie 

Bank, which was originally a bank for Japanese 

nationals living in Hawaiʻi. After the attack on 

Pearl Harbor, the building was seized by the 

Army and used as the military police station. 

It housed a jail in the basement where it is 

reported that Hawaiian residents of Japanese 

ancestry were kept prior to transfer to the U.S. 

Immigration Station. 

PHYSICAL REMAINS

The Honolulu Police Department and the 

Yokohama Specie structures have been 

preserved and the exteriors have been restored. 

Both structures are part of the Merchant Street 

Historic District, listed in the National Register 

of Historic Places in 1973.
18 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

U.S. Immigration Station

The U.S. Immigration Station, located at 595 

Ala Moana Boulevard in Honolulu, was the 

place individuals from Oʻahu were taken on 

December 7th and in the days following when 

they were arrested by the Army and the FBI. The 

FBI’s custodial detention index of December 4, 

1941, listed 149 people on Oʻahu to be arrested 

in the event of war (Kashima 2003, 69–71). By 

day’s end on December 7, more than 200 people 

had been taken to the U.S. Immigration Station. 

By December 10, that number rose to 400, of 

which 75 percent were Nikkei (ibid, 43). 

Internees from all of the Hawaiian Islands 

who were sent to Honouliuli, Sand Island, 

and permanent mainland internment and 

incarceration centers also passed through 

the U.S. Immigration Station. Italian and 

German aliens and U.S. citizens of Italian and 

German ancestry were also held at the U.S. 

Immigration Station. A fountain in the southern 

part of the courtyard was reportedly made by 

Alfredo Guisti, an Italian prisoner of war from 

Pietrasanta, Italy.

Unlike most of the other internment sites in 

Hawai‘i that only served local, short term needs, 

the U.S. Immigration Station had a broad, 

statewide role over an extended period. It 

served as a temporary internment location, but 

also as a center of legal administration. 

PHYSICAL REMAINS

The U.S. Immigration Station building is 

currently used for offices of the Department 

of Homeland Security and the Hawaiʻi State 

Department of Health. The four buildings 

and associated grounds of the three-acre 

complex were listed in the National Register of 

Historic Places on August 14, 1973. The areas 

of significance include “architecture,” “social/

humanitarian,” and “Pacific Bridge.” The 

date of construction is 1934. The building was 

designed by Charles W. Dickey, the first person 

raised in Hawaiʻi to have formal training as an 

architect.

All of the buildings at the site were present 

during World War II: the administration 

building; a two-story detention building now 

used by the Hawaiʻi State Department of 

Health; a long, one-story annex; and the garage/

waiting shed. Several of the structures were 

likely used, as the U.S. Immigration Station 

reportedly could hold up to 400 prisoners. 

Map of internment sites on the island of O‘ahu.
Chapter 2: Historical Overview and Resources  Part II: Sites Associated with the Internment in Hawai‘i 19

Photos (clockwise from top left): 1. Honolulu Police Department, c. 1973. Photographer unknown, provided as part of National Register 

nomination form. 2. Honolulu Police Department at Bethel and Merchant Streets, 2007. Photo: James Rosenthal, Library of Congress. 3.

Yokohama Specie Bank (Honolulu Military Police Station), 2007. Photo: James Rosenthal, Library of Congress.
20 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Photos (clockwise from top 

left): 1. U.S. Immigration 

Station, c. 1973, photographer 

unknown, provided as part of 

National Register nomination 

form. 2. Fountain reported 

sculpted by Alfredo Guisti, an 

Italian prisoner of war, U.S. 

Immigration Station, 2006. 

Photo: Burton and Farrell 

2007. 3. Gate at Sand Island 

Internment Camp. Photographer 

unknown, c. 1942, U.S. 

Army Museum of Hawai‘i. 

4. Detainees at Sand Island 

Internment Camp lived in tents 

for six months until barracks 

were constructed. Photographer 

unknown, c. 1942, U.S. Army 

Museum of Hawai‘i.
Chapter 2: Historical Overview and Resources  Part II: Sites Associated with the Internment in Hawai‘i 21

Italian nationals and U.S. citizens of German 

and Italian ancestry. Each fenced area had its 

own mess hall, showers, and latrines. Between 

the compounds were pathways for workers and 

guards. Twenty-five detainees were assigned to 

each barracks. They reported twice daily to be 

counted (U.S. Army 1945). 

The first commanding officer of Sand Island was 

Captain Carl F. Eifler followed by Lt. Louis F. 

Springer. Approximately $500,000 was spent to 

improve and maintain the facilities during the 18 

months the camp was used. The improvements 

included the construction of eight guard towers 

and four two-story barracks. The guard towers 

were prefabricated and erected in two weeks: 

each was 20 feet tall with welded legs and 

platforms crafted from halfinch thick metal 

plates (Ching, interview 2004). 

Yasutaro Soga, a journalist and leader interned 

at Sand Island, remembers that there was a 

dining room and shower/toilet room, both 

of concrete, and that tents were used for the 

internees for the first six months (Soga 2007, 

29–65). He recalls that four 30-foot by 60-foot 

two-story barracks were built in May 1942. 

These undoubtedly correspond to the four 

barracks listed as part of the Sand Island 

improvements. Oral history, historic maps and 

photographs, and a 1962 aerial photograph 

indicate that the civilian internee compound 

was located near the center of the island. 

In a report to the Swedish Consul during the 

first year of the war, J. R. Sulzer described the 

facilities he saw at Sand Island on September 9, 

1942: 

The camp consists of several wooden 

barracks of excellent construction, 

well ventilated, well lighted and having 

shuttered windows. Large spaces are 

left between the beds and in several 

of the barracks the beds are tiered . 

. . Electricity is installed in all of the 

barracks . . . Married couples are 

authorized to live in well-constructed 

tents, which are laid out on the grounds 

of the camp (Sulzer 1942).

Sulzer’s tally of prisoners and civilian internees 

included those at Sand Island and at the U.S. 

Immigration Station in Honolulu. He lists 48 

male and four female Japanese citizens, two 

German male citizens, two Italian male and 

one Italian female citizen, and 252 American 

male citizens and 15 females. Given the other 

Japanese immigrants and American citizens of 

Japanese ancestry stayed in the courtyard and 

in holding cells in back of the main building; the 

holding cells are still present at the northwest 

end of the building. Although some minor 

adaptations have been made to the interior of 

the structures to accommodate current uses, 

the complex appears to retain a high degree of 

integrity.

Sand Island Detention Camp

The Sand Island Detention Camp, located on 

Sand Island in Honolulu Harbor, was opened on 

December 8, 1941 and operated for 15 months 

until March 1, 1943. It was an internment camp 

run by the U.S. Army. The location was chosen 

because it was near Honolulu and because the 

buildings of the former Territorial Quarantine 

Hospital were available for use. Early maps 

show the quarantine area as an irregular ellipse 

within Sand Island; this same configuration is on 

WW II-era maps. The island location provided 

a measure of geographic isolation and security 

from Honolulu. The bridge that now connects 

Honolulu to Sand Island was constructed after 

World War II. 

A week after the outbreak of war, approximately 

three hundred internees had been transferred 

from the Immigration Station to the Sand Island 

Detention Camp. The first Japanese prisoner of 

war, Ensign Kazuo Sakamaki, was also held at 

Sand Island, in a separate enclosure. Captured 

on the windward side of O‘ahu near Bellows 

Field before dawn on December 8, Sakamaki 

had been skipper of one of five two-man midget 

submarines assigned to breach Pearl Harbor’s 

defenses, and he was the only one of the ten 

to survive the suicide mission. Sakamaki was 

kept at Sand Island eight weeks before being 

transferred to a prisoner of war facility at Camp 

McCoy in Wisconsin (Straus 2003, 8–14).

Kumaji Furuya, one of the civilian internees 

taken to Sand Island on December 9, 1941, 

remembered being marched through a thicket of 

kiawe trees to a large Spanish-style building and 

then to a tiled building with showers, latrines, 

and a kitchen. He and his fellow prisoners were 

given tents and cots to set up for their quarters 

(Saiki 1982, 29–31).

At one point there were four separately fenced 

enclosures for internees within the original 

quarantine hospital station, two for male Nikkei 

with 250 persons each, one for 40 females “of 

mixed races,” and one for 25 male German and 
22 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Chikai Odate, Higashi Hongwanji, Kaua‘i; Ryuichi Murata, 

principal, Manoa Heiwa gakko, Honolulu

Sawaichi Fujita, tinsmith, Hilo, Hawai‘i; Keizo Takata, store owner, 

Hawi, Hawai‘i

Kodo Fujitani, Reverend, Honolulu Moiliili Nishi Hongwanji, 

O‘ahu; Ryuten Kashiwa, Reverend, Waialua Hongwanji, O‘ahu

Kenichi Maehara, photographer, Hawai‘i National Park; Kinzaemon 

Odachi, President of Tenrikyo, Hilo, Hawai‘i

Gentaro Arita, farmer, Papaikou, Hawai‘i; Shigeru Ando, farmer, 

Papaikou, Hawai‘i

Segaku Takezono, monk, Wailuku Hongwanji, Maui

PORTRAITS OF INTERNEES BY 

GEORGE HOSHIDA

George Hoshida, from Hilo, Hawai‘i, documented his 

incarceration experience in World War II through hundreds 

of drawings and watercolors. Hoshida was transferred from 

Kilauea Military Camp to Sand Island, then to Department 

of Justice camps at Lordsburg and Santa Fe, New Mexico, 

and WRA camps in Jerome, Arkansas and Gila River, Arizona. 

These portraits were drawn at Lordsburg and depict internees 

of Japanese descent from Hawai‘i. Images: George Hoshida 

Collection, Japanese American National Museum. Gift of 

June Hoshida Honma, Sandra Hoshida, and Carole Hoshida 

Kanada. 
Chapter 2: Historical Overview and Resources  Part II: Sites Associated with the Internment in Hawai‘i 23 1962 aerial photograph of Sand Island indicating the location of areas of the former detention camp. Photo: Burton and Farrell 2007.
24 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

documented counts, the great majority of the 

252 American male citizens were likely Japanese 

Americans, but German Americans were also 

present (Nye 2005). 

PHYSICAL REMAINS

Today, no evidence of the internment camp, or 

of the Territorial Quarantine Hospital remains. 

Most of Sand Island has been developed with 

modern warehouses and Coast Guard facilities, 

and a wastewater treatment plant has been 

constructed in the western part of the island. 

There are only three areas that have not been 

paved over and built upon: the 14-acre Sand 

Island State Recreation Area along the southern 

edge of the island, parts of the Coast Guard 

Station in the northeastern part of the island, 

and a small area of vegetation at the Sand Island 

Treatment Center. The Treatment Center 

includes the only in situ standing building from 

the World War II era; it is a chapel built by 

Italian prisoners of war (POWs). 

Honouliuli Internment Camp

Honouliuli is a longstanding place name, 

translated as “dark bay,” that marks the areas 

between ‘Ewa villages and Waipahu. Prior to 

the construction of the Honouliuli Internment 

Camp, Honouliuli Gulch was part of the James 

Campbell Estate and included an agricultural 

irrigation system dated to 1920. It was 

surrounded by sugar cane fields that produced 

an important agricultural export central to the 

economy of Hawai‘i.

Honouliuli Internment Camp, which opened 

on March 2, 1943, was located in Honouliuli 

Gulch on the ‘Ewa Plain, west of the city of 

Waipahu, on the western part of Oʻahu. First 

known as the Honouliuli Internment Camp, 

its name was later changed to Honouliuli Alien 

Internment Camp, and still later it became POW 

Compound Number 6 (U.S. Army 1945, 10). 

The term “Honouliuli Internment Camp” is 

most commonly used now to describe it, and 

that term is used in this study.

Built on 160 acres, Honouliuli Internment 

Camp had facilities for approximately 3,000 

prisoners (Springer 1943). The Army cleared 

trees and grass in the densely vegetated valley to 

provide clear views from guard towers and thus 

enhance security (Gordon 2005). The camp was 

divided into seven compounds: one compound 

for administration and guards, one for civilian 

internees, and eventually five compounds 

for prisoners of war. The civilian compound 

was further divided into compounds for male 

civilian internees of Japanese ethnicity, female 

civilian internees of Japanese ethnicity, and 

civilian internees of European ancestry (Nye 

2005). A 1943 report of the Office of Military 

Governor (Springer 1943) described the camp:

The kitchen and mess hall for Japanese 

internees is equipped to feed up to one 

thousand internees. The internees live in 

prefabricated sixteenman demountable 

barracks. All latrines have modern 

plumbing with hot and cold showers. 

A post exchange is available for the 

purchase of cigarettes, tobacco, and 

miscellaneous items for sale. There is 

also a tailor shop, an equipped dental 

office, and a dispensary for necessary 

medical treatment. A recreation field has 

been cleared and fenced in for the use of 

the internees...

The prisoner of war section of 

the Camp has been divided into 

separate enclosures to take care of 

Japanese officers, enlisted men, and 

noncombatant Japanese prisoners of 

Photos (top to bottom): 1. Sand Island, 2006: observation 

tower and beach defenses. 2. Italian Chapel, Sand Island. Built 

by Italian prisoners of war, this historic chapel is the last of the 

WWII-era buildings to stand on Sand Island. Photos: Burton and 

Farrell 2007.
Chapter 2: Historical Overview and Resources  Part II: Sites Associated with the Internment in Hawai‘i 25

of tents, closely spaced barracks, fences, guard 

towers, and other structures taken by R. H. 

Lodge, a former division overseer of the Oʻahu 

Sugar Company who became an official Army 

photographer. 

Honouliuli was the largest prisoner of war camp 

in Hawai‘i and held nearly 4,000 individuals 

during its operation. The POW population 

was composed of soldiers and labor conscripts 

from Korea, Okinawa, Taiwan, Japan, and Italy. 

Honouliuli also held women and 10 children 

who were Japanese civilians displaced from the 

Pacific, including Saipan and Rota, as well as 

four men from the Philippines (Adler 2014 and 

Falgout 2014).

Combined, the blueprint information and 

historic photographs indicate there were about 

175 buildings (more than 60 of them in the 

administration area), 14 guard towers, and 

over 400 tents (including single pyramidal and 

double tents) at the camp. Discrepancies in the 

historic information suggest that the number 

and locations of buildings and tents changed 

war. As a result of the Gilbert Island 

operation and the capture of Korean 

noncombatant prisoners of war, it has 

been found necessary to construct an 

additional enclosure to separate the 

Japanese from the Koreans. 

There are two large prisoner of war 

kitchens and mess halls, each with 

facilities to feed one thousand or 

more prisoners. In the prisoner of war 

section there are cold water showers 

and pit latrines. Prisoners of war live in 

pyramidal tents, usually six to eight men 

in a tent.

Other historic records from the military 

and internees provide insights into different 

aspects of the Honouliuli Internment Camp. 

Historic records include Army memoranda 

and blueprints, oral histories, internee art, 

and reports by the Swedish Vice-Consul, 

who inspected the camp as the authorized 

representative of a neutral power. There are 

also several historic photographs showing a sea 

View of tents in Compound #4 for POWs at Honouliuli Internment Camp, c. 1945, by R. H. Lodge. Photo: Hawai‘i’s Plantation Village.
26 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

through time, likely to meet changing needs as 

the camp population grew. 

The closure of the Honouliuli detention facility 

has not been well documented. More research 

on the departure of internees and prisoners of 

war, closure of the facility, and later uses will 

benefit collective understanding of Honouliuli. 

PHYSICAL REMAINS

Honouliuli Internment Camp was listed 

in the National Register of Historic 

Places on February 21, 2012. The areas of 

significance include “Asian and European 

ethnic heritage,” “military and social 

history,” politics, government, and law,” and 

“archeology-historic/non-aboriginal.”

The site of the Honouliuli Internment Camp 

is located roughly seven miles inland from 

the south and west coasts of Oʻahu, north of 

the H-1 Freeway and west of Kunia Road. 

The 122.5-acre area identified in the National 

Register of Historic Places is wholly owned by 

Monsanto Hawaiʻi. The University of Hawai‘i—

West O‘ahu owns the western bluff above 

Honouliuli Gulch.

As it was during its occupation, the site is set 

in a hidden gulch surrounded by agricultural 

fields. The gulch is about 500 to 700 feet wide at 

the camp location, with steep slopes rising on 

both sides. In contrast to the plowed farm fields 

above, the gulch is currently overgrown with 

vegetation, most notably invasive species such 

as Guinea grass and haole koa, with Chinese 

banyan trees near Honouliuli Stream, which 

runs north to south through roughly the center 

of the site.

Archeological investigations conducted 

between 2008 and 2011 have documented 

more than 140 features at Honouliuli including 

slab foundations for mess halls, latrines, 

showers, and administrative buildings, guard 

tower footings, sidewalks, rock walls, small 

foundations for steps or porches, and remnants 

of the security fence (Burton and Farrell 2007). 

Portions of the water and wastewater systems 

and utility building foundations indicate the 

substantial infrastructure required to house the 

internees and prisoners. Rock-lined pathways 

and remains of a small pond appear to reflect 

the civilian internees’ attempts to ameliorate 

the prison atmosphere. Dense vegetation and 

shallow sediments over much of the gulch, 

however, hinder visibility of the World War II 

era ground surface. Many more features and 

artifacts are likely present. 

ISLAND OF HAWAI‘I INTERNMENT SITES

On the island of Hawaiʻi, those arrested were 

sent to the Kilauea Military Camp (KMC), a 

military installation located within Hawaiʻi 

Volcanoes National Park, Waiākea Prison 

Camp, and the Hilo Independent Japanese 

Language School. The FBI’s custodial detention 

Looking west across Honouliuli Gulch. Photo: NPS, 2011.
Chapter 2: Historical Overview and Resources  Part II: Sites Associated with the Internment in Hawai‘i 27
28 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Photos (clockwise from top): 1. This large concrete slab in the northern section of the gulch marks the site of a World War II-era building. 

Photo: Burton and Farrell 2007. 2. Inscription on the base of a former guard tower, Honouliuli Internment Camp. Photo: NPS, 2013. 

3. Dense vegetation obscures and displaces original slab foundations, Honouliuli Internment Camp. Photo: Burton and Farrell 2007. 

4. Numerous remnants of concrete troughs, aqueducts, sidewalks, roads, and other hardscape features have been surveyed. Honouliuli 

Internment Camp. Photo: NPS, 2011.
Chapter 2: Historical Overview and Resources  Part II: Sites Associated with the Internment in Hawai‘i 29

list included 82 persons to be arrested at the 

outbreak of war on the island (Kashima 2003, 

69–71). An FBI memo states that on March 

26, 1942, 59 aliens and 20 citizens were being 

held at Kilauea Military Camp (Shivers 1942). 

However, the total number of arrests must 

have been much higher than the 79 people 

these figures indicate, since 106 individuals had 

already been transferred from Kilauea Military 

Camp to Sand Island on March 6, 1942. Another 

25 internees were transferred to Sand Island on 

May 12, 1942 (Soga 2007). It is not known how 

many were temporarily detained and released. 

A few internees were held at the Waiākea 

Prison Camp, located near the Hilo Airport. 

Participants at the Hilo public meeting on June 

4, 2014 indicated that a place near the U.S. 

Post Office at the Hilo Airport was used by the 

Army National Guard and FBI for interrogation 

and detaining internees. It was suggested that 

it could have been a location where internees 

were first taken before being transferred to 

other internment locations. Additional research 

is needed to verify the location and confirm that 

it was used for internment during World War II.

Kilauea Military Camp (KMC)

Kilauea Military Camp continues to operate 

as a military recreation area within Hawaiʻi 

Volcanoes National Park. The most intact 

internment camp structures found in the 

Hawaiian Islands are at KMC, which occupies 

approximately 50 acres within Hawaiʻi 

Volcanoes National Park. A comprehensive 

overview of the history and cultural resources 

of Kilauea Military Camp was drafted for 

the U.S. Army Corps of Engineers in 1998 

(Tomonari-Tuggle and Bouthillier 1998), and 

the report provides much of the background 

information summarized here.

Kilauea Military Camp was established in 1916, 

the same year as the park, as a training ground 

for the National Guard and an Army vacation 

station. By 1937, Kilauea Military Camp had 

vacation accommodations for 20 officers and 

their families, three noncommissioned officers 

and their families, and about 200 enlisted men, 

as well as the 14 officers and 100 enlisted men of 

the permanent detachment. But on December 

7, 1941, “KMC changed from a recreation camp 

to an armed camp overnight” (ibid, iii 49). A 

Map of internment sites on the island of Hawai‘i.
30 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

description of internee life is provided by the 

Japanese American National Museum on their 

website:

At Kilauea, internees had to walk among 

soldiers armed with bayonets. While 

food was plentiful and nutritious, the 

dignity of the people was taken away. 

Internees were constantly accompanied 

by soldiers, even to the latrine (Hoshida 

n.d., 255–59).

In George Hoshida’s autobiography, he notes 

that the internees’ barrack was about 100 ft. 

long and 50 ft. wide, set about 5 or 6 ft. above 

the gravel-covered ground, with a long verandah 

enclosed by wire mesh. Opposite the entrance 

door was a door leading to the shower and the 

latrine, which were extensions off the back of 

the building. Hoshida notes that “a portion of 

the west end was partitioned off and a doorway 

led into a spacious lounge with fireplace, 

lounging chairs, and couches.” Hoshida 

estimated there were about 100 internees at 

Kilauea Military Camp (255–59). 

On Feb 15, 1942, it was announced that 

immediate families could visit the detainees 

at KMC. But it was also announced that many 

of the detainees were to be sent to the U.S. 

mainland in the near future. Each detainee 

was entitled to have $50 in his possession, and 

families and friends were instructed to furnish 

that amount and to provide warm clothes. The 

military authorities stated that interned aliens 

could not, under international law, be kept in 

a combat zone and must be taken to an area 

where hostilities were unlikely (TomonariTuggle and Bouthillier 1998). By summer, all 

detainees had been sent to Sand Island on 

O‘ahu or to the U.S. mainland, thus freeing the 

barrack for military use. 

The precise date of closure is unclear. 

Tomonari-Tuggle and Bouthillier indicate 

the detainees were gone “by summer,” and 

that from March to October of 1942, Kilauea 

Military Camp served as Headquarters for the 

27th Division of the Army. Internee George 

Hoshida reportedly left Kilauea Military 

Camp on May 23, 1942, suggesting that Nikkei 

internees may have been present for several 

weeks after the 27th Division arrived (iii–47).

Kilauea Military Camp housed both civilian 

internees and prisoners of war, but not at the 

same time. The prisoner of war camp at Kilauea 

Military Camp, where Okinawan and possibly 

Korean POWs were held, was added in 1944, 

on the west side of the camp. Well outside the 

area used for civilian internees, the POW area 

was surveyed only cursorily for TomonariTuggle and Bouthillier’s Kilauea Military Camp 

overview, as modern disturbance and vegetation 

limited visibility of the site. 

PHYSICAL REMAINS

A drawing by George Hoshida from World War 

II can be matched up with existing buildings 

to a remarkable extent. The drawing’s view 

appears to have been from a point just east of 

the current café and post office, but Hoshida’s 

perspective is looking down on the buildings, an 

imagined bird’s-eye view. The drawing shows 

the buildings used by internees with great detail 

and in the same locations and proportions as 

today. Three guards with rifles are patrolling 

on foot, and there is a soldier manning a guard 

tower. 

By combining information from Hoshida’s 

drawing and his written account, it appears 

that the internee barrack was the building that 

now houses the café, post office, and Lava 

Lounge, (Building 34) and the internee mess 

hall is now the recreation lodge (Building 35). 

The guard tower depicted in Hoshida’s drawing 

was just south of what is now Building 34. Now 

there is an anchor from a nineteenth century 

whaling ship displayed in that area. The current 

dormitory/laundromat (Building 36) and a row 

of guest cottages to the west and part of the row 

of guest cottages to the south are also depicted 

in Hoshida’s drawing.

Most of the discrepancies between the drawing 

and the current condition of the camp reflect 

remodeling. Windows and siding have been 

replaced. The anchor exhibit south of Building 

34 may have been installed over the guard 

tower’s foundations. The large cisterns in the 

drawing to collect water from the building 

roofs are no longer present. Hoshida’s drawing 

depicts the rooflines of the internment buildings 

as hipped, while the current recreation lodge 

and café roofs are gabled. One might suppose 

that the roofs were remodeled, too, but a 

1935 photograph of Kilauea Military Camp 

also shows gable roofs. This discrepancy may 

have arisen because Hoshida completed the 

drawing from memory: the date on the drawing 

is either 5-25-42 or 8-25-42, and he reportedly 

left Kilauea Military Camp on May 23, 1942. 

In addition, in the limited circuit the internees 

were allowed to walk between the barrack and 
Chapter 2: Historical Overview and Resources  Part II: Sites Associated with the Internment in Hawai‘i 31

Photos (top to bottom): 1. Kilauea Military Detention Camp. 

Drawing by George Hoshida, 1942. Courtesy of the Japanese 

American National Museum. Gift of June Hoshida Honma, 

Sandra Hoshida, and Carole Hoshida Kanada. 2. Building 34 at 

Kilauea Military Camp. Based on primary source evidence from 

George Hoshida, this structure likely served as the internee 

barrack. Photo: NPS, 2010. 3. Kilauea Military Camp cabins, 

2006. Photo: Burton and Farrell 2007.
32 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

the mess hall, the ends of the roofs would not 

have been particularly noticeable.

According to Tomonari-Tuggle and Bouthillier, 

Buildings 34 and 35 were both built in 1916. 

Building 34, which was used as the internee 

barrack, was originally a mess hall, measuring 

50 by 154 feet, with an 8-foot wide verandah 

on the south side. It was converted to offices in 

1919, but reverted to its mess hall status in 1922, 

which is also when the lava rock fireplace on the 

east part of the north side of the building was 

built. The original building foundation is post 

and pier with a rock perimeter; additions have 

concrete slab foundations. Building 35, now the 

recreation center, was built as an enlisted men’s 

mess hall and converted to a dormitory in 1919. 

It was used as the internee mess hall in 1943 and 

became the recreation hall in 1945 (ibid, 17).

Waiäkea Prison Camp

In September 1942, six individuals of Japanese 

heritage from the island of Hawai‘i were likely 

held at the Waiākea Prison Camp, outside Hilo 

(Okihiro 1992). The camp was established 

in the 1930s to use prisoner labor to create 

an airstrip, using only picks, shovels and 

wheelbarrows (Ellis n.d., 2–3). The airstrip was 

taken over by the military when the war began, 

and in January 1942, the Army Commander 

of Hawai‘i District wrote to his superior, “The 

Waiākea Prison Camp is the most convenient 

and practicable institution for confinement at 

hard labor on Hawaiʻi. The county jail is a rest 

house [in comparison].” Okihiro notes that 

some of the Waiākea prisoners were internees 

who were being punished for being considered 

troublemakers. 

According to the camp’s Prison Report, a 

sentence of one month of hard labor was given 

for using profane and obscene language. Three 

months of hard labor for being a “disorderly 

person,” six months for being a “common 

nuisance,” and one year for “possession of 

excessive amount of currency” and “unlawful 

possession of a Japanese flag.” Waiākea’s 

internees shared the camp with such civil 

offenders as rapists and burglars (Okihiro 1992, 

248).

 It is not known how long internees were held 

at the Waiākea Prison Camp. One account 

says that under pressure from the military to 

remove people of Japanese heritage from a 

critical defense location, the prison camp was 

1932 aerial photograph of the landing field at Hilo Airport, near the Waiākea Prison Camp. Photo: Hawai‘i Department of Transportation.
Chapter 2: Historical Overview and Resources  Part II: Sites Associated with the Internment in Hawai‘i 33

moved away from the airport area and prisoners 

worked on the road to Mauna Loa within 

Hawai‘i Volcanoes National Park (Ellis n.d.). 

PHYSICAL REMAINS

Waiākea Prison Camp is no longer intact, 

though a former mess hall slab may still exist. 

The Waiākea Prison Camp was located in the 

vicinity of 1498 Kalanianaole Avenue and is 

currently owned by Kamehameha Schools and 

leased to the Edith Kanakaole Foundation for 

their use (Mossman, pers. comm. 2013). A 

complex of new structures exists at the site 

today. 

Hilo Independent Japanese Language 

School

An additional site, the Hilo Independent 

Japanese Language School, was identified 

during the study process as a location where 

Hilo residents were detained before being sent 

to Oʻahu (Nunes-Atabaki and Nunes 1999, 41). 

Beginning in the 1800s, Japanese immigrants 

came to Hawai‘i to work in plantations. Because 

many Japanese laborers eventually planned to 

return to Japan, Japanese language schools were 

established throughout the territory so that the 

children of the laborers could learn about the 

language and culture. 

By World War II, the Hilo Independent 

Japanese Language School was the largest 

Japanese language school on the island of 

Hawai‘i. The campus was located at the corner 

of Ululani and Kukuau Streets. During the 

war, all Japanese language schools were closed, 

and the Hilo Independent Japanese Language 

School became a military police headquarters. 

The kindergarten building was used as a jail and 

the principal’s residence was used as a holding 

cell for temporary detention.

The principal of the school, Imo Shinoda, was 

briefly detained at his residence before being 

sent to Kilauea Military Camp. From there he 

was sent to Sand Island where he was detained 

for several months. Shinoda was eventually 

released, as no charges were found against 

him. The language school never reopened after 

the war and Imo Shinodo had to find another 

means of livelihood to support his family. After 

working for the Hawai‘i Importing Company 

designing and producing hand-block souvenirs 

that were popular with military personnel, Imo 

Shinodo and his wife established and ran a wellknown Japanese embroidery school (NunesAtabaki and Shinoda Nunes 1999).

PHYSICAL REMAINS

Additional research is needed to determine how 

many individuals were detained at the language 

school and the location and condition of any 

remaining resources. 

KAUA‘I INTERNMENT SITES

The FBI’s custodial detention list of December 

4, 1942 listed 41 people on Kauaʻi to be 

arrested in the event of war (Kashima 2003, 

71). However, no provisions had been made 

to house potential internees and it took a few 

days to gather the internees together (U.S. Army 

1942). Most internees on Kauaʻi were housed at 

the Wailua County Jail on the east side of Kauaʻi, 

first in the regular jail facilities and then in a 

dormitory constructed especially for them. 

At least ten persons were held for a few days 

at the Waimea Jail on the southwest side of 

Kauaʻi, before transfer to the Wailua County 

Jail (Burton and Farrell 2007, 5). One internee 

was held in solitary confinement in the Līhu‘e 

Plantation Gymnasium shower room for a 

month. Later, Kaua‘i internees were moved 

to the Kalāheo Stockade. On March 5, 1942, 

45 internees from Kauaʻi were transferred to 

Sand Island (Soga 2007). Three weeks later 

an FBI memo reported that there were still 20 

male aliens, nine male citizens, and one female 

citizen interned on Kauaʻi (Shivers 1942). The 

one female citizen was Mrs. Umeno Harada, 

from Niʻihau, whose husband had killed himself 

after helping a Japanese pilot who had crashlanded on the island. Mrs. Harada was interned 

for four years, first at the Waimea Jail, followed 

by Wailua County Jail for two months, the U.S. 

Immigration Station, Sand Island, and finally 

at Honouliuli (Burton and Farrell 2007, 21). 

Mrs. Harada’s daughter stayed with a relative 

on Kauaʻi (Saiki 1982, 55). Mr. Ishimatsu 

Shintani, also from Niʻihau, was also interned 

for four years, initially on Kauaʻi and later on the 

mainland (Burton and Farrell 2007, 22). 

Wailua County Jail

The Wailua County Jail was the first place 

on Kauaʻi where internees were assembled. 

Initially, conditions were so crowded that 

health and sanitation problems developed. To 

alleviate the overcrowding, as well as to separate 

the internees from regular jail inmates, a twostory dormitory with 48 bunks, a kitchen, and 

a latrine was constructed (U.S. Army 1942). 

Reports suggest that the number of internees 

fluctuated as additional people were arrested; 
34 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

some were transferred to other internment 

camps and some were released. For example, 

Henry Tokutaro Tanaka was arrested February 

19, 1942 and taken to Wailua County Jail, where 

he met 10 to 15 others. The number of internees 

must have increased over the next few days, 

because five days later, it was reported that 

45 detainees were turned over to the Military 

Police to be taken to Honolulu, leaving 24 

detainees at the Wailua County Jail (Saiki 1982, 

170–71). The jail was used to house civilian 

internees at least until June 6, 1942, when 

internees including Mrs. Harada were moved to 

Sand Island. 

PHYSICAL REMAINS

A historic photograph shows the Wailua County 

Jail as a two-story concrete building with a small 

one-story barracks built behind it. Destroyed by 

a hurricane and replaced with a modern facility 

of several one-story buildings, the jail is now 

known as the Kauaʻi Community Correctional 

Center (Ashman 2004, 8–9). No buildings 

related to the internment history remain in 

that location. Because of restricted access, 

no archeological reconnaissance has been 

conducted at the site, and features or artifacts 

related to the World War II internment may be 

present and obscured by modern development. 

Waimea Jail

Mrs. Harada and Ishimatsu Shintani from 

Niʻihau were taken to Waimea Jail on 

December 15, 1941 (Beekman 1982). Anecdotal 

information places at least ten other Nikkei 

internees there shortly after the Pearl Harbor 

attack. Okihiro describes one internee’s 

experience: 

Jukichi Inouye, another Japanese language 

school principal on Kauaʻi, described how his 

path led to Sand Island. Inouye was arrested 

in the early morning of December 8 and taken 

to Waimea Jail where he found several of his 

friends. The quarters were cramped, the toilet 

was a bucket, and “there was no place to hide.” 

After three days, without explanation, Inouye 

and nine others were placed in a “dump truck” 

and driven away (Okihiro 1992, 218–19).

PHYSICAL REMAINS

At one time it was thought that Waimea Jail 

might have been located in the NationalRegister-listed Gulick-Rowell house, because 

Map of internment sites on the island of Kaua‘i.
Chapter 2: Historical Overview and Resources  Part II: Sites Associated with the Internment in Hawai‘i 35

Photos (top to bottom): 1. Wailua County Jail, Kaua‘i, possibly with internee housing in the background. Photograph taken by Lt. James 

Daniels during WWII, Kaua‘i Museum Archives. 2. Kaua‘i Community Correctional Center, located on the site of the demolished Wailua 

County Jail. Photo: Burton and Farrell 2007.
36 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

its basement was once used as Waimea’s jail 

(Soboleski 2008). However, staff of the Kauaʻi 

Museum and longtime residents of Waimea 

have indicated that the Waimea Jail where the 

internees were held was in a structure that has 

since been demolished. The site is now the 

location of the county police and fire station 

in Waimea (Faye, Faye, and Miyake interview 

2011, Kauaʻi Museum, personal communication 

December 2013).

Kaläheo Stockade

It is not clear when internees were first held at 

the Kalāheo Stockade or where it was located. 

The term “stockade” usually implies a jail within 

a military camp. The Kalāheo Stockade also 

jailed, in separate quarters, some 50 members 

of the Army who had been convicted of 

criminal offenses or misconduct (Burton and 

Farrell 2007, 8). The Kalāheo Stockade seems 

likely to have been part of an established army 

encampment. 

According to Saiki, internees at the Kalāheo 

Stockade were held in one structure large 

enough to house 20 to 25 people, with a 

mess hall, showers, and latrine adjacent. The 

Vice-Consul of Sweden, G. W. Olson, visited 

Kalāheo Stockade to check on the status of the 

internees in 1943 (Burton and Farrell 2007, 

23). Olson’s report notes that at his September 

15, 1943 visit, the Kalāheo Stockade was much 

improved over its condition reported February 

12, 1943. In September it had electric lights, 

landscaping, lawns, improved sanitary facilities, 

and land prepared for vegetable gardening. 

But the Kalāheo Stockade may not have been 

used for internees after September 1943; at 

that time Olson reported that there was only 

one internee, who had been recommended for 

release by the local hearing board.

PHYSICAL REMAINS

The location of Kalāheo Stockade has not yet 

been fully determined. Six possible locations 

were investigated during the 2006 archeological 

reconnaissance, and additional reconnaissance 

was attempted in 2014. No conclusive evidence 

of the stockade was found, but many members 

of the public believe it to be at or near the 

Medeiros Chicken Farm. A 1943 military map 

places the stockade in the Medeiros Chicken 

Farm vicinity, but to the east. Additional 

research would be needed to confirm the 

precise location of the Kalāheo Stockade and 

condition of any remaining resources.

Medeiros Chicken Farm, possible site of the Kalāheo Stockade. Photo: Burton and Farrell 2007.
Chapter 2: Historical Overview and Resources  Part II: Sites Associated with the Internment in Hawai‘i 37

Kaua‘i County Courthouse and Līhu‘e 

Plantation Gymnasium 

Participants in the scoping sessions on Kauaʻi 

also indicated that the County Courthouse in 

Līhuʻe was a location of importance. This is 

where Kauaʻi internee hearings were held. The 

Līhuʻe Plantation Gymnasium was known as 

a site used for solitary confinement for at least 

one internee.

PHYSICAL REMAINS

The County Courthouse at 4444 Rice Street was 

the location of the military court. The building 

is within the Līhuʻe Civic Center Historic 

District, listed in the National Register of 

Historic Places in 1981.

The Līhuʻe Plantation Gymnasium is the only 

site on Kauaʻi that remains today. It is located 

in Isenberg Park, and is currently used by the 

Church of Jesus Christ of the Latter-day Saints 

(Kauaʻi Museum, personal communication 

December 2013). Additional research and 

investigation would be needed to determine 

the structure’s integrity relative to the time of 

internment.

MAUI INTERNMENT SITES

The two known internment sites on Maui are 

the Maui County Jail—called the “Detention 

Camp” in Wailuku, which was located at the 

site of the current Maui County Correction 

Center—and the Ha‘ikū Military Camp in the 

town of Ha‘ikū. The FBI’s custodial detention 

list of December 4, 1941 listed 58 people on 

Maui to be arrested in the event of war; four 

from Molokaʻi and three from Lānaʻi were also 

taken to Maui (Kashima 2003, 71). On March 

6, 1942, 36 people were transferred from Maui 

to Sand Island (Soga 2007). The March 30, 1942 

FBI memo indicates that 34 aliens and eight 

citizens were still interned on Maui as of March 

26 (Shivers 1942). As at the other internment 

sites, most of the internees were incarcerated 

because they were leaders in the Japanese 

American community, but one Nikkei man 

was kept at Ha‘ikū for three days for a blackout 

violation (Saiki 1982, 70). 

Maui County Jail

Records indicate that the Maui County Jail, 

also called the Wailuku County Jail, was used 

to detain individuals of Japanese descent. A 

Map of internment sites on the islands of Maui, Lāna‘i, and Moloka‘i.
38 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Photos (clockwise from top left): 1. The Old Police Station in 

Wailuku may have been used to detain internees temporarily. 

Photo by Rick Regan: provided as part of National Register 

nomination form, 1981. 2. The Old Wailuku Courthouse, seen 

here in 2006. Photo: Burton and Farrell 2007. The significance 

of the Police Station and the Courthouse to WWII internment 

requires further investigation. 3. Historic cannery building, 

Ha‘ikü. Photo: Burton and Farrell 2007. 4. Roots School, possible 

United Service Organizations (USO) site of Ha‘ikü Camp during 

WWII. Photo: NPS, 2011.
Chapter 2: Historical Overview and Resources  Part II: Sites Associated with the Internment in Hawai‘i 39

letter from an internee, dated June 3, 1942, 

identified the return address as “Detention 

Camp, Wailuku.” The original jail building 

was constructed in 1941 as the county’s jail 

facility, and then was used during World War 

II as a location to detain internees. It was 

located at the site of the current Maui County 

Correctional Center at 600 Waiale Road in 

Wailuku. Additional research is necessary to 

determine if the Old Wailuku Courthouse and 

the Old Police Station, now called the Kalana 

Pakui Building, were used during internment.

PHYSICAL REMAINS

The Maui County Jail structure was demolished 

in 1970. The Old Police Station (built in 1928) 

and the Old Wailuku Courthouse (built in 1907) 

are part of the Wailuku Civic Center Historic 

District. The district was listed in the National 

Register of Historic Places in 1986.

Ha‘ikü Camp

Internees were held at Ha‘ikū Camp in tents 

and temporary structures. The exact dates and 

numbers of individuals incarcerated at Ha‘ikū 

Camp is not known at this time. In his letter of 

September 23, 1943, Swedish Vice-Consul G. W. 

Olson reported that Ha‘ikū Camp was “the best 

of all the internment camps in the Territory... It 

is a most delightful place, and being on vacation 

at the time of my visit I would rather have stayed 

there than return to the hotel in Wailuku.” At 

the time of Olson’s visit on September 8, 1943, 

there were only four internees, only one of 

whom was a Japanese citizen; the other three 

were therefore probably American citizens of 

Japanese ancestry. All had been recommended 

for release by the local board. It was not stated 

why they were still being held (Burton and 

Farrell 2007, 39).

PHYSICAL REMAINS

The location of the Ha‘ikū Camp was provided 

by Kenneth Okano and David Lindsay, both of 

whom indicated that they were familiar with the 

approximate location of the camp from direct 

experience as children during World War II. 

Okano noted that the internment camp was set 

up on an athletic field an estimated 250 feet or 

so makai (towards the ocean) of the old Ha‘ikū 

Pineapple Company cannery. Although Mr. 

Okano recognized no features of the internment 

camp, he confirmed that it was located north of 

the Post Office, west of Ha‘ikū Road, north of 

Pokoa Place to Laupapa Place, and west of the 

old railroad and plantation (ibid., 39).

Lindsay went to visit the Ha‘ikū Camp during 

World War II. His personal recollection is that 

the existing Roots School building located at 

740 Ha‘ikū Road may have been part of the old 

Ha‘ikū Pineapple Company and later used for 

the internment camp (Lindsay, pers. comm. 20

10). 

Additional research completed by David 

Fukuda of the Nisei Veterans Memorial Center 

confirms the location of the Ha‘ikū Camp in the 

area north and east of the existing Ha‘ikū Post 

Office. Fukuda interviewed Ty Kakihara, born in 

1927, who remembered the area during World 

War II. He remembered the former dorm for 

cannery workers was enclosed with a wire fence 

and guard towers 

The camp area is now a residential area. New 

houses may have obscured or obliterated traces 

of the camp. One resident of the area noted 

that historic foundations that had been part of 

the Ha‘ikū military camp were being removed 

for new development (Whittle-Wagner, pers. 

comm. 2011). 

MOLOKA‘I AND LƖNA‘I INTERNMENT 

SITES

The few individuals of Japanese heritage from 

Molokaʻi and Lānaʻi interned were jailed locally, 

and then transferred to the Maui County Jail 

before being transferred to Oʻahu (Burton and 

Farrell 2007, 11). Local jails in Kaunakakai, 

Molokaʻi and Lānaʻi City were the likely 

locations prior to transfer. The two or three 

internees from Lānaʻi were held for at least two 

months, likely at the Lānaʻi City Jail on Gay and 

8th Street.

PHYSICAL REMAINS

Each jail and adjacent courthouse in both towns 

are still standing. The Kaunakakai County Jail 

and courthouse were moved offsite to a local 

park to make room for a new public library. 

The Lānaʻi City Jail and courthouse are in 

good condition and in their original location. 

They, along with several other structures in the 

historic Lānaʻi City downtown area compose 

a rare intact plantation town and were listed 

as one of the National Trust for Historic 

Preservation’s 11 Most Endangered Historic 

Places in 2009. 
40 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Photos (clockwise from top left): 1. Läna‘i City Jail. 2. Kaunakakai County Jail, Moloka‘i (moved offsite). 3. Kaunakakai County 

Courthouse, Moloka‘i. All photos: NPS, 2011.
3RESOURCE SIGNIFICANCE
A view into daily life at Honouliuli Internment Camp, c. 1945, by R. H. Lodge. Photo: Hawai‘i’s Plantation Village.
Chapter 3: Resource Significance  Criteria for National Significance 41

CHAPTER 3: RESOURCE 

SIGNIFICANCE

This section describes the National Park Service’s 

analysis of nationally significant resources within 

the study area. 

Criteria for National Significance 

Study areas are evaluated for national 

significance by applying two sets of criteria: 

national historic landmark criteria and special 

resource criteria. National Park Service 

Management Policies 2006 mandate that national 

significance for cultural resources be evaluated 

by applying the national historic landmarks 

criteria for national significance. Under §1.3.1 

of NPS Management Policies 2006, a proposed 

addition to the national park system must also 

meet four additional National Park Service 

special resource study criteria. National Park 

Service professionals, in consultation with 

subject matter experts, scholars, and scientists, 

determine whether a resource is nationally 

significant. This chapter describes the results of 

that analysis. 

NATIONAL HISTORIC LANDMARK 

CRITERIA 

According to 36 CFR 65.4–National Historic 

Landmark (See Appendix C), the quality of 

national significance is ascribed to districts, 

sites, buildings, structures, and objects 

that possess exceptional value or quality in 

illustrating or interpreting the heritage of 

the United States in history, architecture, 

archeology, engineering and culture and that 

possess a high degree of integrity of location, 

design, setting, materials, workmanship, feeling 

and association, and:

Criterion 1: That are associated with events

that have made a significant contribution to, 

and are identified with, or that outstandingly 

represent, the broad national patterns of United 

States history and from which an understanding 

and appreciation of those patterns may be 

gained; or

Criterion 2: That are associated importantly 

with the lives of persons nationally significant 

in the history of the United States; or

Criterion 3: That represent some great idea 

or ideal of the American people; or

Criterion 4: That embody the distinguishing 

characteristics of an architectural type 

specimen exceptionally valuable for the study 

of a period, style, or method of construction, 

or that represent a significant, distinctive and 

exceptional entity whose components may lack 

individual distinction; or

Criterion 5: That are composed of integral 

parts of the environment not sufficiently 

significant by reason of historical association or 

artistic merit to warrant individual recognition 

but collectively compose an entity of 

exceptional historical or artistic significance, or 

outstandingly commemorate or illustrate a way 

of life or culture; or

Criterion 6: That have yielded or may be 

likely to yield information of major scientific 

importance by revealing new cultures, or by 

shedding light upon periods of occupation 

over large areas of the United States. Such sites 

are those which have yielded, or which may 

reasonably be expected to yield, data affecting 

theories, concepts and ideas to a major degree.

It should be noted that none of the sites 

included in this study are currently designated 

NHLs. However, some of the sites under 

consideration in this study have the potential to 

meet NHL criterion 1 and 6 for their association 

with the history of internment in Hawai‘i during 

World War II. Those events, as outlined below, 

outstandingly represent broad national patterns 

of United States history, and the associated 

resources have the potential to provide an 

understanding and appreciation of this history 

for the public. 

SPECIAL RESOURCE STUDY CRITERIA

The National Park Service Management 

Policies 2006 state that a resource is nationally 

significant if it meets all of the four following 

conditions:

1. It is an outstanding example of a particular 

type of resource;

2. It possesses exceptional value or quality 

in illustrating or interpreting the natural or 

cultural themes of our nation’s heritage;
42 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Barracks and tents at Honouliuli, with the women's internee compound in the background. A portion of the rock wall visible behind still 

stands on the site today. Photo by R. H. Lodge, c. 1945, courtesy Hawai‘i’s Plantation Village.

3. It offers superlative opportunities for 

public enjoyment or for scientific study; and

4. It retains a high degree of integrity as a 

true, accurate, and relatively unspoiled 

example of a resource.

Significance of the Events: 

Incarceration of Civilians in the 

U.S. during World War II

The internment and incarceration of Japanese 

Americans and others during World War II 

on the mainland and in Hawai‘i are nationally 

significant events that shape our understanding 

and commitment to civil liberties and the fair 

treatment of all citizens, regardless of race. By 

identifying the commonalities and distinctions 

between mainland and Hawai‘i stories, this 

study concludes that the internment in Hawai‘i 

is of national significance, distinct from 

mainland incarceration. Through it, we are 

able to more fully understand the abrogation of 

civil liberties that occurred in the U.S. and its 

territories. 

As outlined in the Historical Overview in 

Chapter 2, the incarceration of Japanese 

Americans and legal resident aliens of Japanese 

ancestry on the mainland during World War II 

has been recognized as an important episode in 

United States history. The government’s official 

investigation, conducted by the Commission on 

Wartime Relocation and Internment of Civilians 

(CWRIC), concluded as follows, 

The promulgation of Executive Order 

9066 [the order that allowed the mass 

incarceration of Nikkei] was not justified 

by military necessity, and the decisions 

that followed from it - exclusion, 

detention, the ending of detention 

and the ending of exclusion - were not 

founded upon military considerations. 

The broad historical causes that shaped 

these decisions were race prejudice, 

war hysteria, and a failure of political 

leadership. Widespread ignorance 

about Americans of Japanese descent 

contributed to a policy conceived in 

haste and executed in an atmosphere of 

fear and anger at Japan. A grave personal 
Chapter 3: Resource Significance  Significance of the Events: Incarceration of Civilians in the U.S. during World War II 43

injustice was done to the American 

citizens and resident aliens of Japanese 

ancestry who, without individual review 

or any probative evidence against them 

were excluded, removed and detained 

by the United States during World War II 

(CWRIC 1997, 194). 

This finding has had profound consequences 

not only for the Japanese American community, 

but for all Americans. The national importance 

of the internment and incarceration, its 

repercussions, and eventual redress has been 

reinforced by the involvement of Presidents 

Ford, Carter, Reagan, G. H. W. Bush, Clinton, 

and G. W. Bush with statements and legislation 

decrying the incarceration and affirming civil 

rights. 

The story of imprisonment of Nikkei on the 

mainland has been recounted in numerous 

histories, diaries, analyses, legal discussions, 

and even plays and films. It is the focus of 

exhibits, educational programs, and memorials 

from California to Washington D.C. Four 

historic sites have been set aside by the federal 

government to be preserved and to provide 

opportunities for public education and 

interpretation of the incarceration of Japanese 

Americans during World War II: Manzanar 

National Historic Site, California; Minidoka 

National Historic Site, Idaho; Bainbridge Island 

Japanese American Memorial called Nidoto 

Nai Yoni, Washington; and the Tule Lake Unit 

of World War II Valor in the Pacific National 

Monument, California. All four sites are on the 

mainland. 

The history of civilian internment in Hawai‘i 

during World War II is little known and has 

not received the same level of scholarship, 

educational programs, and attention as on the 

mainland, but it is no less significant. As on the 

mainland, internment in Hawai‘i was based 

on the idea of military necessity, and as on the 

mainland, the internment in Hawai‘i was later 

found to be an unjust abrogation of civil rights. 

On both the mainland and in Hawai‘i, official 

government investigations conducted before 

the war indicated that resident Japanese aliens 

and Japanese American citizens were not likely 

to pose a threat to U.S. security, and that only 

a small number of persons should be detained 

(Kashima 2003, 69). No Japanese Americans 

were ever charged or convicted of treason on 

the mainland, and the only cases of espionage 

in Hawai‘i involved a Japanese consular agent 

and a German resident alien (Allen 1950, 

140–41). Both on the mainland and in Hawai‘i, 

the internment and incarceration illustrates 

the ambivalence with which the United States, 

a nation of immigrants, treated its immigrant 

population. On both the mainland and in 

Hawai‘i, the incarceration resulted in economic 

hardships and long-lasting psychological 

and social repercussions for the people who 

experienced it. Both on the mainland and 

in Hawai‘i, the history of internment and 

incarceration epitomizes how civil rights can be 

brushed aside in a time of crisis. Both mainland 

and Hawaiian incarceration sites embody the 

challenges the United States faces, even today, 

maintaining constitutional rights for American 

citizens. But the incarceration in Hawai‘i also 

differed in several key ways from the mainland, 

as described below.

The first key distinction is that internment of 

American civilians in Hawai‘i was authorized 

by martial law, rather than Executive Order 

9066. The declaration of martial law in Hawai‘i 

provided a way to control the entire population, 

and one of the military’s justifications for 

martial law in Hawai‘i was that the local 

population could not be trusted (Anthony 1975, 

79). As Anthony relates,

The orders of the military governor 

proceeded upon the theory that after 

the declaration of martial law and the 

assumption by the commanding general 

of the office of military governor of 

Hawai‘i all power, legislative, executive, 

and judicial, vested in him; that he was 

not bound by the laws of the United 

States, the Territory of Hawaii, or the 

Constitution itself (Anthony 1975, 12–13).

In Duncan v. Kahanamoku, the U.S. Supreme 

Court decided in 1946 that the military 

tribunals established under martial law in 

Hawai‘i did not have jurisdiction over common 

criminal cases. In effect, the ruling said that 

although the original declaration of martial law 

in Hawai‘i was justified, its continuation after 

the immediate threat of invasion had ended 

was unconstitutional. Scholars Scheiber and 

Scheiber state:
44 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

The record of military rule in wartime 

Hawai‘i is without precedent in American 

history . . . It also differed from the 

internment of Japanese Americans [on the 

mainland] because it involved a complete 

suspension of constitutional liberties for 

an entire civilian population. There is 

abundant evidence that civilians from all 

ethnic groups were subjected to arbitrary 

and humiliating treatment. “While 

fighting for democracy on a dozen fronts,” 

the Interior Department solicitor wrote in 

December 1942, “we have [a]dictatorship, 

quite needlessly—almost by accident, 

in one vital part of the United States of 

America.” That sentiment was echoed 

in a confidential 1946 investigation of 

Hawaiʻi’s wartime military courts, in 

which a Justice Department counsel 

concluded without qualification: “It’s a 

very, very nasty unpleasant picture, and 

you just cannot justify it in any way” 

(Schreiber and Schreiber 2003).

As Scheiber and Scheiber conclude, the Duncan 

decision came too late for the civilians whose 

lives had been so deeply affected by the Army 

regulations, and especially for the hundreds 

who had been sentenced to months or years in 

internment camps without the rudiments of a 

fair trial.

Second, although martial law affected all 

Hawaiian residents, internment in Hawai‘i 

directly affected only a small percentage of the 

population. Although the threat of sabotage, 

aiding and abetting, and espionage was 

potentially much greater in Hawai‘i than on the 

mainland, less than 2 percent of the Hawaiian 

Nikkei were interned. Thirty-seven percent, or 

158,000 of the 420,000 people living in Hawai‘i 

during World War II were of Japanese ancestry, 

and people of Japanese descent were well 

integrated both socially and economically in the 

islands. In contrast, the 127,000 Nikkei living 

on the mainland formed less than 1 percent 

of the population, yet 100 percent of those 

living on the West Coast were incarcerated in 

camps run by the War Relocation Authority and 

Department of Justice.

The distinction between the treatment of 

Nikkei in Hawai‘i and on the mainland during 

World War II is linked to the manner in which 

immigrants were recruited, accepted, and 

integrated into Hawaiian society. It also had 

significant beneficial consequences for Hawaiʻi’s 

role in World War II. The government’s 

more strategic approach to the internment of 

Japanese aliens and U.S. citizens of Japanese 

ancestry, for example, not only allowed persons 

of Japanese ancestry in Hawai‘i to contribute 

fully to the war effort in civilian roles, it fostered 

the creation of the 100th Infantry and the allNisei 442nd Regimental Combat Team. When the 

military was reopened to Japanese Americans, 

almost 10,000 men from Hawai‘i volunteered, 

of whom more than 2,600 were accepted. In 

contrast, there were only 1,250 volunteers from 

the mainland camps (Weglyn 1976, 144, 306n). 

This discrepancy in the rate of volunteering 

for military service is directly related to the 

discrepancy in treatment: many young Japanese 

American men on the mainland had tried to 

join the military as soon as the war started, 

but were declared unfit for service due to their 

race. By the time the military allowed them 

to serve, they and their families were already 

incarcerated. Some even resisted the draft 

Sketch of internees working on crafts at Honouliuli by Dan T. 

Nishikawa, April 29,1943. Courtesy of the Japanese Cultural 

Center of Hawai‘i, Dan Toru Nishikawa Family Collection.
Chapter 3: Resource Significance  Significance of the Events: Incarceration of Civilians in the U.S. during World War II 45

after it was reinstated for Japanese Americans, 

as a protest against the incarceration of their 

families (Lyon 2012; Muller 2001; Hohri et al 

2001; Mackey 2002). Eventually, the combined 

100th and 442nd all-Japanese American battalions 

compiled a distinguished record fighting in the 

European Theater, earning three Presidential 

Unit Citations and many individual decorations 

(U.S. Army Center of Military History 2000).

Third, although the more limited internment 

in Hawai‘i was less damaging to the morale of 

the general population, it may have had even 

more insidious effects on those individuals 

interned. Internment on the mainland was 

psychologically and financially devastating for 

the internees, and the entire Japanese American 

population on the West Coast was directly 

affected. Therefore, it would have been difficult 

to argue that this entire population, including 

U.S. military veterans, the elderly, and babies, 

was potentially guilty of treason. In Hawai‘i, 

individuals were singled out, and therefore 

stigmatized and treated as though there could 

have been a valid reason for their internment. 

The effect on the individuals and their families 

was even more devastating (Kashima 2003, 85), 

and in some cases, children were left to fend 

for themselves when parents and older siblings 

were interned (Nye 2005).

Finally, public awareness during and since 

World War II about the internment in Hawai‘i 

compared with the mass incarceration on the 

mainland was and continues to be remarkably 

different. The internment in Hawai‘i was 

largely kept secret during World War II and 

has only been a subject of scholarship and 

educational efforts in recent decades. Whereas 

on the mainland, the mass incarceration was 

well known along the West Coast primarily 

because all persons of Japanese ancestry were 

excluded and confined, and the media played an 

important role in promulgating wartime hysteria 

and broadcasting the many aspects and events 

of the mass incarceration. Scholar Tetsuden 

Kashima points out the secrecy imposed and 

maintained by the military in Hawai‘i, 

Many Japanese Americans in Hawai‘i 

[and other residents] are still unaware 

of the full story of forced detention and 

removal of island persons to the mainland 

and the existence of the [internment] 

camps. Martial law and use of the 

View to Pearl Harbor from overlook, Honouliuli. Photo: NPS, 2013.
46 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

military-security classification restricted 

information about the entire wartime 

episode (Kashima 2003, 85).

The secrecy surrounding internment in Hawai‘i 

has come to an end due to the research efforts 

of scholars like Tetsuden Kashima and Gary 

Okihiro and especially the Japanese Cultural 

Center of Hawai‘i and faculty and students at 

the University of Hawai‘i—West O‘ahu. 

National Historic Landmark 

Criteria Analysis

The 17 internment sites in Hawai‘i were 

considered for their role and importance in 

telling the internment story. For each site, the 

duration of use, number of internees held, and 

condition and status of the site were considered 

based on the best available information. The 

internment history of each site was researched 

and documented.

Based on the findings and analysis in this study, 

two sites, Honouliuli Internment Camp and 

the U.S. Immigration Station, are found to be 

nationally significant as defined in the NHL 

guidelines (See Map: Nationally Significant 

Sites, Island of O‘ahu). The study team received 

concurrence from the Washington Office of 

the National Historic Landmarks Program on 

the determination of national significance for 

the Honouliuli Internment Camp and the U.S. 

Immigration Station.

The other 15 sites had significantly shorter 

occupations, held small numbers of internees, 

played a peripheral role in the internment 

history, and/or lacked historic integrity. Certain 

sites merit greater recognition related to their 

internment history but fail to meet the NHL 

criteria for national significance. More detailed 

information about the other 15 sites is located 

later in this chapter in the section: Significance 

of Additional Sites Associated with Civilian 

Internment during World War II. 

Honouliuli Internment Camp and the U.S. 

Immigration Station sites are associated with 

several of the nationally significant themes 

identified in the Japanese Americans in World 

War II National Landmark Theme Study,

as manifest in the special circumstances of 

internment in Hawai‘i, described above. 

The sites exemplify the themes of: Politics/ 

Government for the critical role of the federal 

government (the FBI and the military) in the 

internment of citizens and immigrant aliens; 

Law for the constitutional questions that were 

raised by the internment and martial law versus 

the protection of civil liberties in time of war; 

Military for the role of the Army and martial law 

in the internment; Ethnic Heritage and Social 

History for the internment’s association with the 

treatment of minority populations on the home 

front during World War II, and as part of the 

general history of minorities in the U.S. 

The Honouliuli Internment Camp and 

the U.S. Immigration Station held citizens 

and immigrants of other ethnicities too, 

demonstrating that internment affected people 

of Japanese and European ancestry during 

World War II. 

HONOULIULI INTERNMENT CAMP

Opened in 1943, the Honouliuli Internment 

Camp was the last, largest, and longest-used 

World War II confinement site in Hawai‘i. 

The camp was built to intern Japanese and 

European Americans, Japanese and European 

resident aliens, and POWs captured in military 

operations during World War II. As both a 

civilian internment camp and a prisoner of 

war camp, the Honouliuli site embodies two 

different facets of World War II: the control of 

U.S. residents and citizens and the treatment 

of enemy soldiers. The fact that these two 

seemingly distinct classes of people were 

incarcerated at one site indicates that the two 

groups were considered equivalent, at least in 

some ways. 

As an internment site, Honouliuli represents the 

fragility of constitutional rights, and is a physical 

symbol of the prejudice and discrimination that 

immigrants experienced. Honouliuli is also a 

rare and tangible manifestation of martial law, 

which had a profound effect on all citizens 

of Hawai‘i but which left little imprint on the 

landscape. Internment loomed as a threat even 

to those not held for long periods of time.

As a prisoner of war camp, Honouliuli illustrates 

how the U.S. military handled and housed an 

influx of prisoners of war, balancing compliance 

with the Geneva Convention with demands for 

national security. The POWs held at Honouliuli 

included soldiers and labor conscripts from 

Korea, Okinawa, Taiwan, Japan, and Italy. 

Honouliuli’s separate POW compounds for 
Chapter 3: Resource Significance  National Historic Landmark Criteria Analysis 47
48 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Main entry, U.S. Immigration Station former administrative building, 2006. Photo: Burton and Farrell 2007.

Korean enemy non-combatants and the stories 

of the three Korean students who worked for 

the United States military before reverting to 

POW status at Honouliuli reveal the antagonism 

between Japan and its forced allies (Ch’oe 2009). 

In addition, the large capacity of the POW 

compounds reflects a change in the course of 

the war. By the time Honouliuli was constructed 

and put to use, the Allied forces were winning 

more battles in the Pacific and taking more 

prisoners. Archeological and archival evidence 

indicates Honouliuli was expanded during its 

occupation. With one compound added and 

others modified to accommodate the influx of 

POWs, Honouliuli illustrates the changes in the 

U.S. war fortunes, as more and more members 

of the enemy military were captured in the 

Pacific war zones. 

The analysis indicates that the Honouliuli 

Internment Camp meets national significance 

criterion 1 for “ its association with events that 

have made a significant contribution to, and are 

identified with, or that outstandingly represent, 

the broad national patterns of United States 

history and from which an understanding and 

appreciation of those patterns may be gained” 

(NHL 1997). 

Honouliuli Internment Camp likely meets NHL 

criterion 6 for its potential to yield information 

of major scientific importance as it relates to the 

treatment of Japanese and European internees 

and POWs during World War II. Archeological 

features and deposits throughout the site could 

provide comparative data about expressions of 

ethnicity, confinement and identity (Burton and 

Farrell 2008).

U.S. IMMIGRATION STATION

The U.S. Immigration Station was listed in the 

National Register of Historic Places at the state 

level of significance in 1973 (listed as the U.S. 

Immigration Office). Although the nomination 

outlines the history of immigration to the 

Hawaiian Islands, the buildings were considered 

more significant for their architecture than 

for their association with significant events in 

U.S. history. Designed by Charles W. Dickey, 

the station’s architecture directly relates to its 

role in immigration history: the station was 
Chapter 3: Resource Significance  National Historic Landmark Criteria Analysis 49

“designed to fit the climate and atmosphere 

of Hawai‘i and to be an inviting place for 

immigrants to come through” (NPS 1973). As 

the nomination form notes, 

The entrance portico... reflects Hawai‘i 

and the U.S. Immigration Station’s 

function as a bridge between East 

and West. The portico is accented by 

Chinese architectural details and the 

large bronze compass plaque set in 

the floor of the entrance lobby shows 

Hawai‘i as the crossroads of the Pacific 

by indicating distances to principle cities 

on the Pacific rim. 

These buildings symbolize the coming to 

the Islands of the numerous ethnic groups 

which make up Hawai‘i’s present population. 

It is a great source of local pride that on the 

foundation of an open Hawaiian culture, a 

fusion of races and cultures is evolving in which 

the many immigrant groups are losing their 

separate identities and by intermarriage creating 

“one people” (NPS 1973).

The U.S. Immigration Station’s World War 

II history enhances and expands the U.S. 

Immigration Station’s importance. The U.S. 

Immigration Station was used for a number of 

purposes related to internment. O‘ahu internees 

were initially confined at the U.S. Immigration 

Station following the attack on Pearl Harbor. 

Some were sent to Sand Island, and then on 

to mainland camps, or after its creation, to 

Honouliuli Internment Camp (Burton and 

Farrell 2007). 

All of the hearings for arrested individuals 

in O‘ahu (and likely for all other Hawaiian 

residents) were held at the U.S. Immigration 

Station. Some individuals were held in the 

courtyard or in holding cells in back of the 

main building. Many arrested individuals were 

shuffled back and forth from Sand Island and 

Honouliuli to the U.S. Immigration Station for 

their hearings and eventual release. Internees 

were often required to come back to the U.S. 

Immigration Station after release to process 

paperwork related to their parole. 

The U.S. Immigration Station, Honolulu, as it appeared in 1938. Photo on display at the U.S. Immigration Station.
50 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Scholar Alan Rosenfeld uncovered evidence 

which indicates that virtually all internees 

from the Hawaiian Islands may have passed 

through the U.S. Immigration Station. Military 

authorities completed daily reports through 

1942-1944 detailing traffic through the U.S. 

Immigration Station. One report documents 

219 detained individuals at the U.S. Immigration 

Station from February 20 to February 21, 1942 

(Department of the Army 2012). 

The analysis of the central role of the U.S. 

Immigration Station in Hawai‘i’s internment 

history indicates that the U.S. Immigration 

Station meets national significance criterion 1 

for “ its association with events that have made 

a significant contribution to, and are identified 

with, or that outstandingly represent, the broad 

national patterns of United States history and 

from which an understanding and appreciation 

of those patterns may be gained” (NHL 1997). 

Today, almost 40 years after the original national 

register nomination and with new information 

about the history of immigration in the U.S., 

it is likely that the U.S. Immigration Station 

could be considered nationally significant 

for its role in immigration history in Hawai‘i. 

Similar immigration stations, like Angel Island 

in California, have been determined to be of 

national significance as primary portals for 

hundreds of thousands of immigrants from 

Asia and the Pacific. Additional research and 

analysis should be conducted on the national 

significance of the U.S. Immigration Station as it 

relates to immigration in the United States. 

The U.S. Immigration Station in Honolulu is 

considered nationally significant for its role 

in Hawaiʻi’s incarceration history alone and 

meets NHL criterion 1. When its importance 

to immigration is also taken into account, its 

significance could be twofold.

Special Resource Study Criteria 

Analysis

The following section applies the special 

resource study criteria to the Honouliuli 

Internment Camp and the U.S. Immigration 

Station. For some criteria, both sites are 

analyzed together for their similar themes. 

Other criteria require an analysis of each site.

Photos (top to bottom): 1. Modern chicken shed constructed 

of World War II-era scrap materials. World War II building in 

the guard camp area in the background. 2. Dry stone wall, 

Honouliuli Internment Camp. 3. Existing septic tank access, 

Honouliuli Internment Camp. All photos: NPS, 2011.
Chapter 3: Resource Significance  Special Resource Study Criteria Analysis 51

1. OUTSTANDING EXAMPLE 

The Honouliuli Internment Camp is a nationally 

significant site which meets NHL criterion 

1 as an outstanding example of a resource 

associated with the World War II internment 

of civilians in Hawai‘i and NHL criterion 6 for 

the archeological features and remains that 

are likely to augment important information 

about military control of POWs and internees, 

and how the prisoners responded (Burton and 

Farrell 2008). The U.S. Immigration Station is 

an outstanding example of an initial detention 

site and the primary location for hearings and 

processing of all internees from Hawai‘i; it 

meets NHL criterion 1. Each site may also be 

an outstanding example of additional themes 

important in U.S. history: the treatment 

of prisoners of war at Honouliuli, and the 

treatment of immigrants at the U.S. Immigration 

Station. 

2. EXCEPTIONAL VALUE IN 

INTERPRETING HISTORICAL AND 

CULTURAL THEMES

The National Park Service has developed 

a thematic framework for evaluating the 

significance of resources for designation as 

national historic landmarks, or for potential 

addition to the national park system. The NPS 

thematic framework “is used to help identify 

cultural resources that embody America’s past 

and to describe and analyze the multiple layers 

of history encapsulated within each resource” 

(NPS .n.d.). Honouliuli Internment Camp 

and the U.S. Immigration Station both possess 

exceptional value in illustrating and interpreting 

five of the themes identified in the framework: 

peopling places, creating social movements, 

expressing cultural values, shaping the political 

landscape, and changing role of the United States 

in the world community.

Peopling places: The internment of U.S. citizens 

and civilian aliens at Honouliuli Internment 

Camp and the U.S. Immigration Station 

demonstrates the ambivalence of officials in 

Hawai‘i toward immigrants: immigrants were 

valued for the labor they contributed, were 

integrated into the culture of the Hawaiian 

Islands, but they were also sometimes viewed 

with suspicion. The internment reflects conflict 

between the U.S. government and its immigrants 

and citizens through the acts of imprisonment 

and incarceration. Immigration and the 

evolution of communities are represented by 

the history of Japanese, Chinese, Filipino, and 

European settlers who immigrated to Hawaiʻi 

and settled in Honolulu and the rural areas of 

Hawaiʻi, and the communities they formed. 

This theme also is represented by how other 

ethnic groups were affected by the internment 

in Hawai‘i. 

The U.S. Immigration Station exhibits 

exceptional value in illustrating and interpreting 

the theme of peopling places through its direct 

and significant role in immigration.

Creating social institutions and movements:

The NPS notes that “Americans generate 

temporary movements and create enduring 

institutions in order to define, sustain, or reform 

their values” (NPS 1996, 8) and this theme is 

illustrated by the internment sites. Honouliuli 

Internment Camp and the U.S. Immigration 

Station were used to incarcerate community 

leaders who created organizations to honor 

and perpetuate Japanese cultural values. Now, 

Honouliuli Internment Camp is associated with 

the creation of social movements that examine 

this aspect of World War II history in relation 

to the U.S. Constitution and American ideals of 

equality and justice. The site contributes to the 

civil liberties movement by reaffirming these 

values through education, pilgrimages, and days 

of remembrance. 

Expressing cultural values: As a nation of 

immigrants, the United States accrues the 

cultural values of many different ethnic groups. 

Internees of Japanese ancestry at Honouliluli 

and the U.S. Immigration Station demonstrated 

their cultural ideals of perseverance and honor 

when faced with loss of cultural identity during 

the war: for example, “gaman,” meaning 

patience and perseverance, and “Ganbare!” 

(Japanese for “hold on!” or “persevere!”) were 

expressed through poetry, art, landscapes, 

and other actions during the World War II 

incarceration. Both sites provide a tangible 

places to interpret the many personal stories 

and anecdotes associated with the broader 

confinement of Japanese Americans and 

European Americans that illustrate cultural 

values.

Perhaps most importantly, cultural values 

embodied in the U.S. Constitution are 

compellingly expressed by the fight to recognize 
52 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

the injustices of incarceration which began 

during World War II and continue today. 

Cultural values (including perseverance and 

faith in the government and U.S. Constitution) 

are also expressed through the efforts of several 

internees to fight their incarceration by pursuing 

legal redress through the American court 

system. 

In addition, the U.S. Immigration Station 

expresses cultural values and the sometimes 

contradictory nature of those values: the 

station’s architecture was designed to welcome 

immigrants to this land of opportunity, but the 

station’s use as a holding and hearing center 

during World War II illustrates immigrants’ 

treatment as a security risk during times of 

crisis.

Shaping the political landscape: The events 

of this time were also responsible for shaping 

the political landscape, which includes military 

institutions and activities, government 

institutions, and political ideas. All aspects 

of American life were profoundly affected by 

the war, including in Hawai‘i. Honouliuli and 

the U.S. Immigration Station are important 

physical manifestations of the effects and 

reach of martial law, which has been rarely 

implemented in this country (Yamasaki 1991). 

On the islands, the concern for military security 

led to the internment, but the war also led to 

the formation of the Varsity Victory Volunteers 

and later the 100th Infantry Battalion—

442nd Regimental Combat Team, whose 

unquestionable valor and loyalty led to greater 

acceptance of Japanese Americans in the larger 

American society. 

Honouliuli illustrates how martial law and 

internment shaped the political landscape 

through legislation and court rulings regarding 

internment and martial law. Honouliuli 

was associated with important legal rulings, 

including Duncan v. Kahanamoku in which the 

U.S. Supreme Court decided that the military 

tribunals established under martial law in 

Hawai’i did not have jurisdiction over common 

criminal cases. Two of three German American 

citizens who challenged their internment in 

Hawai‘i were held at Honouliuli (Burton and 

Farrell 2008). 

The U.S. Immigration Station has exceptional 

value in illustrating the theme of shaping the 

political landscape through its role in enhancing 

the ethnic, cultural, and political diversity of 

people in Hawai‘i and therefore of the United 

States.

Changing role of the United States in the 

world community: This theme includes 

immigration, cultural exchange, security, 

defense, and international relations. Honouliuli 

and the U.S. Immigration Station have 

exceptional value in illustrating and interpreting 

these aspects of our history. They illustrate our 

relationships with other countries, especially 

enemy nations, not only in the incarceration 

of immigrants but also in the adherence to 

the Geneva Conventions for the treatment of 

POWs.

Honouliuli was established to incarcerate 

civilians and POWs outside the active battle 

zone in Pearl Harbor to comply with Geneva 

Convention standards for the treatment of 

POWs (Burton and Farrell 2008). Internally, 

separate compounds were established for 

groups of civilians and POWs, largely based 

on ancestry. The activism of Korean POWs at 

Honouliuli helped shape the political landscape 

of their own country and Korea’s relations 

with the United States. In addition, the humane 

treatment of Japanese POWs at Honouliuli and 

other POW camps had beneficial repercussions 

for later relationships between Japan and the 

United States, illustrating the changing role of the 

U.S. in the world community.

The U.S. Immigration Station’s recent change 

in administration illustrates the changing role 

of the United States in the world community: 

the 70-year-old United States Immigration 

and Naturalization Service was dismantled 

by the Homeland Security Act of 2002 and 

separated into the U.S. Immigration and 

Customs Enforcement, U.S. Customs and 

Border Protection, and the U.S. Citizenship and 

Immigration Services, all within the Department 

of Homeland Security. The U.S. was, and still is, 

the land of opportunity for people from all over 

the world, but the country continues to struggle 

to balance the ideal of welcoming immigrants 

and visitors with the need for internal security 

and safety, echoing the motivation and rationale 

behind the World War II internment episode. 
Chapter 3: Resource Significance  Special Resource Study Criteria Analysis 53

Both sites are of exceptional value in 

interpreting historical and cultural themes and 

meet criterion 2.

3. SUPERLATIVE OPPORTUNITIES FOR 

PUBLIC ENJOYMENT AND SCIENTIFIC 

STUDY

Honouliuli Internment Camp and the U.S. 

Immigration Station are located not far from 

Pearl Harbor and its interpretive sites that 

commemorate other aspects of the war. Both 

sites can provide information about one of the 

ways the war affected civilians: the incarceration 

of citizens and resident immigrants of “suspect” 

ethnicity or heritage. As tangible links to an 

event in which fear exacerbated racism and 

led to the suppression of civil rights during 

World War II, these sites can inform today’s 

discussions about the relationship and 

interplay of national security and the U.S. 

Constitution. They provide an opportunity to 

more fully interpret the story of internment and 

incarceration in the U.S. during World War II.

Honouliuli Internment Camp 

OPPORTUNITIES FOR PUBLIC ENJOYMENT

Honouliuli Internment Camp offers outstanding 

opportunities for public interpretation about 

the internment of civilians and POWs during 

wartime. Educational opportunities go beyond 

World War II and also include opportunities 

in ethnic studies, political science, and civil 

rights. Hawaiian residents and visitors alike 

will relate to, and perhaps empathize with, the 

civilian prisoners at Honouliuli, who were of 

diverse backgrounds and represented several 

different ethnicities. In addition, Honouliuli 

is a rare tangible example of three aspects of 

the war: the effects of martial law on civilians, 

which regulated an astounding amount of 

everyday life; the changing course of the war in 

the Pacific, as more and more prisoners were 

captured and needed housing; and the hostilities 

and tension between Japan and its forced allies, 

as separate compounds had to be designated 

for Japanese and Korean POWs. Further, as it 

represents the treatment of POWs, the rights 

and meaning of citizenship, and the difficulty 

balancing civil rights with national security, 

Honouliuli has great potential to generate public 

discussion and discourse relevant to today’s 

political world. 

Physically, Honouliuli continues to evoke the 

isolation and remoteness felt during the time of 

internment (Burton and Farrell 2007). As the 

current site of an annual Day of Remembrance 

pilgrimage and tours sponsored by the Japanese 

Cultural Center of Hawai‘i, that feeling of 

Students in a summer archeology course at the University of Hawai‘i–West O‘ahu conduct fieldwork at Honouliuli. Photo: Valentino 

Valdez.
54 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

confinement evoked by the gulch itself, in a 

remote setting surrounded by agricultural fields, 

is still felt today by visitors to the site.

Finally, given its location near Pearl Harbor 

and interpretive sites that commemorate the 

beginning of the war (USS Arizona Memorial) 

and the end of hostilities (Battleship Missouri 

Memorial), Honouliuli can be incorporated into 

an interpretive program that provides the public 

with a more complete understanding of World 

War II history. 

OPPORTUNITIES FOR SCIENTIFIC STUDY

Protected by its isolated location amidst 

agricultural lands, Honouliuli offers the greatest 

potential for identification of archeological 

remains when compared to other internment 

sites in the state of Hawai‘i. Honouliuli has 

tremendous research potential and could yield 

information of major scientific importance 

as it relates to the treatment of Japanese and 

European internees and POWs during World 

War II.

The site is also located adjacent to a parcel of 

land owned by the University of Hawai‘i—West 

O‘ahu (UHWO), and the faculty and staff 

of UHWO have expressed strong interest in 

working with the NPS to continue archeological 

research and studies in World War II history, 

democratic studies, Pacific Area studies, and 

other social sciences using Honouliuli as a focal 

point. 

U.S. Immigration Station

OPPORTUNITIES FOR PUBLIC ENJOYMENT

The U.S. Immigration Station, located 

on a major thoroughfare in the Honolulu 

metropolitan area, is adjacent to Honolulu’s 

downtown civic center and within 3 miles of 

Waikiki. The U.S. Immigration Station’s history 

as a “round-up,” interrogation, and processing 

site is fundamental to understanding the 

history of internment in Hawai‘i and has great 

potential to generate public discussion about 

the incarceration of citizens and civilian aliens. 

However, the U.S. Immigration Station complex 

is actively used for Department of Homeland 

Security offices. 

OPPORTUNITIES FOR SCIENTIFIC STUDY

The U.S. Immigration Station holds great 

research potential in uncovering the inner 

workings of the government’s action to 

identify, locate, detain, interrogate, and process 

internees. As the primary location where 

these activities occurred, the U.S. Immigration 

Station’s history is vital to a complete 

understanding of internment in Hawai‘i. 

Photos (top to bottom): 1. Entry to the U.S. Immigration Station. 

2. Bus stop outside the U.S. Immigration Station. 3. U.S. 

Immigration Station detention building. All photos: NPS, 2013.
Chapter 3: Resource Significance  Special Resource Study Criteria Analysis 55

Archival research could yield this information. 

In addition, the U.S. Immigration Station had 

a profound role as a port of entry for waves of 

immigrants coming from Asia and the Pacific 

beginning in the 1930s. Research on this aspect 

of the U.S. Immigration Station’s history is 

needed and could yield significant information 

about immigration from Asia. More research 

could determine whether the U.S. Immigration 

Station is eligible for national historic landmark 

listing related to its immigration history. 

Both sites provide superlative opportunities for 

public enjoyment and scientific study.

4. HIGH DEGREE OF INTEGRITY 

A nationally significant site or resource must 

retain a high degree of integrity as a true, 

accurate, and relatively unspoiled example of a 

resource. Seven attributes are used to evaluate 

integrity: location, design, setting, materials, 

workmanship, feeling, and association. This 

evaluation of integrity fulfills both the national 

historic landmark and special resource study 

requirements.

Because of their temporary nature, sites 

associated with the internment and 

incarceration of Japanese Americans during 

World War II present unique challenges in 

evaluating national historic landmark criteria 

for integrity. As the incarceration sites were not 

intended to be permanent, buildings were often 

removed very soon after the war’s end. As such, 

evaluation of integrity must be considerate of 

more subtle aspects of integrity, such as the 

ability of the environment, landscape, building 

and site plan remnants to convey a sense of 

place and feeling.

The Japanese Americans in World War II Theme 

Study (theme study) provides guidelines for 

evaluating the significance and integrity of 

associated properties based on the evaluations 

of previously designated national historic 

landmarks including: Granada Relocation 

Center (Colorado), Heart Mountain Relocation 

Center (Wyoming), Manzanar Relocation 

Center (California), part of the Rohwer 

Relocation Center (Arkansas), Topaz Relocation 

Center (Utah), and Tule Lake Relocation Center 

(California) (NPS 2012). Such considerations 

Photos (top to bottom): 1. Existing mess hall slab in internee 

compound, Honouliuli Internment Camp. Fifteen building 

foundations have been documented to date at Honouliuli. 

Photo: NPS, 2011. 2. Existing viaduct over Honouliuli Stream 

channel, Honouliuli. Photo by Jeffery Burton, 2011.

are applied to the evaluation of integrity for 

Honouliuli Internment Camp and the U.S. 

Immigration Station.

Honouliuli Internment Camp

Honouliuli Internment Camp retains a high 

degree of integrity of location, setting, feeling, 

and association. World War II era features 

include the remains of two buildings, numerous 

foundations, fence remnants, artifact scatters, 

and other features that convey the historic 

significance of the site. Modern development at 

the site has been minimal and does not detract 

from the overall site integrity. In addition, 

Honouliuli Internment Camp retains historic 

features associated with design, workmanship, 

and materials.
56 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

LOCATION

Location refers to the place where the historic 

property was constructed or the place where 

historic events occurred. Properties associated 

with Japanese American internment and 

incarceration must be located within the 

wartime boundaries of the United States and its 

possessions (NPS 2012). 

Honouliuli Internment Camp is in its original 

location and the contributing resources are in 

their original locations, as verified by Army 

blueprints (See Map: Honouliuli Internment 

Camp—Historic Layout and Modern Features). 

SETTING

Setting is the physical environment of a 

historic property—the character of a place, 

its topography, vegetation, simple manmade 

features such as paths and fences, and the 

relationship between features, and open space. 

For properties related to Japanese American 

incarceration during World War II, the setting 

includes the character of the places where they 

were developed, as well as their siting in those 

places. The isolated settings of the centers 

were highly significant in that they reveal a 

perceived need to remove Japanese Americans 

from mainstream American culture. There 

was also a perception that security would be 

easier to enforce in rural locations. In order for 

above ground resources at these properties to 

meet NHL criteria for integrity, much of the 

harshness and isolation of the original setting 

should remain (NPS 2012). 

The setting of Honouliuli, in a hidden gulch 

surrounded by agricultural fields, remains 

virtually unchanged since World War II. 

Within the 122-acre site, modern intrusions are 

minimal and include a satellite dish site, a water 

treatment facility, and a paved access road.

MATERIALS

Materials are the physical elements that were 

combined or deposited during a particular 

period of time and in a particular pattern or 

configuration to form a historic property. For 

incarceration sites, most construction materials 

such as lumber and tarpaper no longer remain 

above ground. Material remains typically 

Generator building foundation uncovered by JCCH volunteers in 2008, Honouliuli. Photo: Burton and Farrell 2008.
Chapter 3: Resource Significance  Special Resource Study Criteria Analysis 57

include durable materials such as concrete and 

stone used for building footprints, sidewalks, 

roads, footings, and other landscape features. 

The remnants of landscape materials placed by 

residents, including trees and other plantings, 

concrete garden pools, and other features, also 

provide a key to the appearance of a site during 

occupation and lend integrity to the site (NPS 

2012). 

Honouliuli retains integrity of materials in 

two extant buildings, in site features, and in 

archeological deposits. The National Register 

of Historic Places nomination for Honouliuli 

Internment Camp documents 134 features 

recorded during an archeological survey of the 

site. All but 16 were determined likely to be 

associated with the internment camp. The two 

extant buildings retain foundations, windows, 

doors, and siding. One building still retains 

a World War II-era light fixture. Numerous 

concrete foundations, roads, remnants of 

security fences, pathways lined with rock, 

concrete tanks, and metal and clay pipes (part 

of the sewage disposal system) are still present, 

lending to the appearance of the site during 

occupation (Burton and Farrell 2008 and 2011). 

DESIGN

Design is a combination of elements that create 

the form, plan, space, structure, and style of 

a property. Design includes such factors as 

the organization of space, proportion, scale, 

technology, ornamentation, and materials. 

Where few historic buildings survive, the ability 

of the property to visually convey its original 

planned layout may determine whether integrity 

of design is retained.

Generally imposed on stark landscapes, the 

designs of the centers were based on right-angle 

grids, which imbued the centers with a sense of 

military order. In some cases, the configuration 

of the grid was broken to accommodate a river, 

a road, or a railroad. 

Any physical evidence of the site plan—above 

or below ground—has potential significance. 

Gardens, pools, and other landscape features 

created by the residents often embellished 

the stark layout. The survival of these features 

contributes to the design integrity of related 

Photos (top to bottom): 1. Manhole cover with Nov. 4, 1944 

inscription, Honouliuli, 2006. Photo: Jeffery F. Burton, provided 

as part of the National Register of Historic Sites nomination 

form. Fifteen building foundations have been documented 

to date at Honouliuli. 2. Remnant of mortared stone wall, 

Honouliuli Internment Camp. Photo: NPS, 2011. 3. Remains of 

stone edging, Honouliuli Internment Camp. Photo: Burton and 

Farrell 2007.

properties. Security features also contribute 

to the design integrity of the site. Surviving 

remains of fences, watchtowers, jails, and police 

compounds provide important insights to the 

layout and feeling of a site (NPS 2012). 
58 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

The design of Honouliuli Internment Camp is 

apparent in the overall layout and the individual 

features within the site. Although some features 

are obscured by vegetation, the combination 

of remaining features including building 

foundations, fence and watchtower footings, 

rock-lined pathways, roads, and water and 

sewage system remains, collectively convey the 

military design and appearance of the camp 

during occupation (Burton and Farrell 2011).

WORKMANSHIP

Workmanship relates to the physical evidence 

of the crafts of a particular culture or people 

during any given period in history or prehistory, 

is seen in elements in the large-scale landscape. 

The workmanship of extant camp buildings 

and structures can illustrate the military 

standardization of plans (or the modification 

of plans) and the temporary nature of the 

construction. Surviving buildings and those 

examined archeologically may show the 

differences between housing for staff members 

and housing for the prisoners. 

Above and below ground archeological 

evidence may indicate the quality of 

workmanship that existed in buildings and 

structures that are no longer extant above 

ground. Workmanship can also be applied to 

residential landscape features, particularly those 

designed and built by prisoners. If sufficient 

integrity exists to decipher the plan or form of a 

landscape feature, the quality of workmanship 

can be assessed. Names, dates, and other 

expressions incised into concrete or carved 

or painted on wood may document builders’ 

identities and contribute to the integrity of 

workmanship (NPS 2012).

Honouliuli Internment Camp was divided into 

seven compounds, five of which were prisoner 

of war compounds. The other two compounds 

were for administration and Japanese American 

internees. An archeological survey of the site 

documented 43 features related to the prisoner 

of war camps, 16 features in the administration 

area (including two standing structures), and 

27 features related to the internees. Linear 

features that crossed more than one compound 

were also recorded. These resources illustrate 

military standardization of plans, as well as, 

differences in housing between administration, 

internees, and prisoners of war (Burton and 

Farrell 2008 and 2011). 

The National Register Nomination for 

Honouliuli Internment Camp notes that 

“expedient military-style workmanship is 

evident in the standardized mess hall, laundry 

and other foundations; the standing buildings; 

Inscription on the base of a former guard tower, Honouliuli Internment Camp. Photo: NPS, 2013.
Chapter 3: Resource Significance  Special Resource Study Criteria Analysis 59

the guard tower footings; and the overall 

layout.” Although no prisoner-produced 

landscape elements have been documented, 

such features may be obscured by dense 

vegetation or sediment deposits. Oral histories, 

photographs, and historical descriptions of 

the camp indicate that internees planted trees, 

shrubs, and flower beds with rock borders 

(Burton and Farrell 2011).

FEELING

Feeling refers to a property’s expression of 

the aesthetic or historic sense of a particular 

period of time. Because sites associated with the 

Japanese American wartime experience have 

lost many buildings and structures, feeling can 

be created by an intact setting or the footprints 

of lost buildings. The remote landscapes that 

characterized detention centers can also lend 

a sense of isolation and abandonment to these 

sites (NPS 2012).

Honouliuli expresses the feeling of the 

internment camp, not only with its isolated 

location, but also with the presence of artifacts 

related to prison security, such as fence posts, 

and the gulch itself. The bottom of Honouliuli 

Gulch is located six miles mauka (inland from 

the coast). It is bounded by steep slopes that 

reinforce the feeling of confinement. Oral 

histories from internees have documented that 

Honouliuli Gulch was referred to as JigokuDani, or “hell valley,” because the confining 

slopes caused the valley to be excessively hot. In 

a 2011 pilgrimage to the site, both visitors and 

former internees reacted to the seclusion of the 

site (Burton and Farrell 2011). 

Rusted vehicle in the overgrown gulch, Honouliuli. Photo: Valentino Valdez.
60 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

ASSOCIATION

Association refers to the connection we make 

today between a particular place and an 

important historic event or person. Internment 

sites maintain associative integrity if sufficient 

evidence from the period remains (NPS 2012). 

The historic site of the Honouliuli Internment 

Camp has integrity of association, as the largest 

and longest-lived of the Hawaiian internment 

sites and as a prisoner of war camp. Over 100 

features remain on the original site (Burton 

and Farrell 2008 and 2011). Honouliuli 

provides a tangible link to the reach and depth 

of martial law in Hawai‘i, the internment of 

civilians, and the treatment of enemy captives. 

Ongoing research and the public visitation that 

has occurred to date indicate the site offers 

exceptional opportunities to understand and 

interpret complex aspects of America’s homefront World War II history.

The U.S. Immigration Station

The U.S. Immigration Station, listed in the 

National Register of Historic Places, also retains 

a high degree of integrity of location, design, 

setting, workmanship, materials, feeling, and 

association. 

Originally constructed in 1933, three of the 

buildings that were present on the site during 

World War II remain today. This includes the 

administration building, the detention building, 

and a long, one-story annex (garage/waiting 

shed). Japanese Americans were held in the 

site’s courtyard and in holding cells in back of 

the administration building. The holding cells 

are still present today.

The design of the U.S. Immigration Station is 

apparent in the overall layout and the individual 

features within the site. The National Register 

of Historic Places nomination for the site 

recognizes that the buildings were designed to 

express the spirit and environment of Hawaiʻi 

“and at the same time maintaining well balanced 

and well-proportioned masses, graceful lines 

and a pleasing color effect (National Register 

of Historic Places 1973).” The setting remains 

virtually unchanged since World War II. 

Workmanship is evident in the main building, 

including Chinese architectural details, a 

terra cotta portico, and a large bronze manypointed star in the floor. The U.S. Immigration 

Station retains integrity of materials in the 

Photos (top to bottom): 1. Architectural details, U.S. Immigration 

Station former administrative building. 2. Interior, U.S. 

Immigration Station former administrative building. 3. Interior, 

U.S. Immigration Station former administrative building. All 

photos: NPS, 2013.
Chapter 3: Resource Significance  Special Resource Study Criteria Analysis 61

Photos (clockwise from top left): 1. Garage and 

waiting shed, U.S. Immigration Station. 2. Interior, 

U.S. Immigration Station garage and waiting 

shed. 3. Entry, former administration building, 

U.S. Immigration Station. 4. Lounging shed, U.S. 

Immigration Station. All photos: NPS, 2013.
62 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

three remaining buildings and in site features 

such as the courtyard. The U.S. Immigration 

Station expresses the feeling of the period of 

internment, courtyards used during this time 

remain and the main building still retains 

holding cells that were used during this period. 

Finally, the U.S. Immigration Station buildings 

have integrity of association, providing a tangible 

link to the history of the initial detention of 

both immigrants and citizens during World 

War II. The buildings continue to be used 

for immigration and internal security related 

activities which further contributes to the site’s 

feeling and association.

Both sites possess a high degree of integrity.

Significance of Additional 

Sites Associated with Civilian 

Internment during World War II

The other sites associated with internment 

considered in this study were used for shorter 

periods of time, interned fewer numbers of 

people, or have been substantially changed since 

the period of significance. As such, they do not 

meet the criteria for national significance as 

defined in the SRS and NHL guidelines. Many 

of these sites are, however, listed or eligible for 

listing in the National Register of Historic Places 

and provide opportunities to further interpret 

the story of internment and incarceration in 

the U.S. during World War II. More detailed 

information about each site is located in 

Chapter 2, Part II: Sites Associated with the 

Internment in Hawai‘i. 

The Honolulu Police Department, Yokohama 

Specie Bank, and Kauaʻi County Courthouse 

are three sites associated with internment 

that are already listed in the National Register 

of Historic Places and retain high integrity. 

Although listed in the National Register for 

other associations, their relationship to World 

War II internment expands their significance. 

Two sites appear eligible for listing in the 

National Register of Historic Places, the Kilauea 

Military Camp and the Lāna‘i City Jail. Both 

sites possess integrity of location, setting, 

materials, workmanship, design, feeling, and 

association. Together, these five sites possess 

opportunities to tell multiple aspects of the story 

of the forcible internment of civilians during 

World War II. 

SITES LISTED OR ELIGIBLE FOR LISTING 

IN THE NATIONAL REGISTER OF 

HISTORIC PLACES

Association with internment enhances the 

significance of three buildings already listed 

in the National Register of Historic Places: 

Honolulu Police Department, Yokohama Specie 

Bank, and Kauaʻi County Courthouse. 

The National Park Service is currently 

preparing a National Register Nomination for 

the Kilauea Military Camp. The focus of the 

nomination is the significance of this site as a 

result of its association with the development 

of a recreation camp for military personnel 

on the Island of Hawaiʻi. The association 

with internment enhances this significance. 

Kilauea Military Camp contains the bestpreserved primary internment camp structures 

found in the state of Hawai‘i. It retains a 

high degree of integrity of location, design, 

setting, workmanship, materials, feeling, and 

association. The site and buildings have been 

preserved as part of the military and National 

Park Service activities within Hawai‘i Volcanoes 

National Park, and visitation is available to the 

general public. The modifications of details and 

rearranging of functions of the buildings has 

been ongoing since their construction in the 

1920s and reflect standard military adaptability. 

The location and setting are nearly unchanged 

from the World War II period. Original design 

is still evident in the layout of the buildings; 

integrity of workmanship and materials is 

manifest in the fireplace; and the association 

is clear. The site as a whole retains a strong 

integrity of feeling: former internees would have 

no trouble recognizing the site today.

The Lānaʻi City Jail and Courthouse could be 

significant for their association with World 

War II internment. The buildings are part of an 

intact plantation town from the Dole Pineapple 

era and retain sufficient integrity for nomination 

to the National Register of Historic Places. 

SITES NEEDING ADDITIONAL RESEARCH 

In six cases, additional research is necessary 

to establish clear association with internment, 

or to determine whether the property 

retains sufficient integrity to convey its 
Chapter 3: Resource Significance  National Significance Conclusion 63

significance: Waiākea Prison Camp and the 

Hilo Independent Japanese Language School 

on the the island of Hawai‘i, Līhuʻe Plantation 

Gymnasium and Kalāheo Stockade on Kaua‘i, 

and Haʻikū Military Camp and Maui County 

Courthouse and Police Station on Maui. 

OTHER SITES

Six of the sites associated with the World War II 

internment of civilians appear to lack sufficient 

integrity for National Register consideration: 

Sand Island Detention Camp on O‘ahu, Wailua 

Jail and Waimea Jail on Kaua‘i, Maui County 

Jail on Maui, Waiākea Prison Camp on the 

island of Hawai‘i, and Kaunakakai Jail and 

Courthouse on Molokaʻi. Structures related to 

World War II internment have been removed 

from the Sand Island, Wailua, Waimea, Waiākea, 

and Maui County Jail sites, and because of 

modern disturbance there is little potential for 

significant archeological deposits at those sites. 

The Kaunakakai Jail and Courthouse, while still 

standing, have been moved from their World 

War II location, and moved properties are 

generally not eligible for the National Register.

National Significance Conclusion

This study concludes that the Honouliuli 

Internment Camp and the U.S. Immigration 

Station are nationally significant and meet 

national historic landmark and special resource 

study criteria. 

Honouliuli Internment Camp was the last, 

largest, and longest-used World War II 

confinement site in Hawai‘i and contains 

archeological features and deposits that have the 

potential to yield important new information 

about the treatment of Japanese and European 

internees and prisoners of war. Honouliuli 

Internment Camp meets NHL criteria 1 and 6.

The U.S. Immigration Station complex in 

Honolulu is significant as the location where 

virtually all internees in Hawai‘i were processed 

or temporarily incarcerated before being 

transferred to internment sites on O‘ahu or 

mainland United States. The U.S. Immigration 

Station meets NHL criterion 1. 

Honouliuli Internment Camp and the U.S. 

Immigration Station meet all four special 

resource study criteria. They are outstanding 

examples of primary sites associated with 

internment; they possess exceptional value in 

illustrating or interpreting the event; they have 

the potential to offer superlative opportunities 

for public education or for scientific study; and 

they retain a high degree of integrity as true, 

accurate, and relatively unspoiled examples of a 

resource. 

The other 15 sites associated with internment 

considered in this study were used for shorter 

periods of time, interned fewer numbers of 

people, or have been substantially changed 

since the period of significance. As such, 

they do not meet the criteria for national 

significance as defined in the special resource 

study and national historic landmark criteria. 

Many of these sites are, however, listed or 

eligible for listing in the National Register of 

Historic Places and/or provide opportunities 

to further interpret the story of internment and 

incarceration in the U.S. during World War II.
64 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Table 3-1: Nationally Significant Sites 

Site Name Location Integrity Description

Honouliuli 

Internment Camp

West of Kunia 

Road, Waipahu, 

O‘ahu

High The largest and longest-used internment site in Hawaiʻi 

and a prisoner of war camp as well, Honouliuli provides 

a tangible link to the reach and depth of martial law in 

Hawai‘i, the internment of civilians, and the treatment 

of enemy captives. Ongoing research and public 

visitation that has occurred to date indicate the site offers 

exceptional opportunities to understand and interpret 

complex aspects of the U.S.’s homefront World War II 

history. Listed in the National Register of Historic Places 

on February 21, 2012 for areas of significance related to 

Asian and European ethnic heritage, military and social 

history, politics, government, law, and historic archeology.

U.S. Immigration 

Station

595 Ala Moana 

Boulevard, 

Honolulu, 

O‘ahu

High The U.S. Immigration Station is nationally significant for its 

role in the history of internment in Hawai‘i during World 

War II. Designed to welcome immigrants to Hawai‘i, the 

U.S. Immigration Station was also used during World War 

II to detain resident aliens and U.S. citizens whose race or 

ethnicity aroused suspicion. Further analysis of the U.S. 

Immigration Station’s role in U.S. immigration history is 

recommended. Listed in the National Register of Historic 

Places on August 14, 1973 for its architecture, social/

humanitarian contributions, and as a “Pacific Bridge.”
Chapter 3: Resource Significance  National Significance Conclusion 65

Table 3-2: Sites Listed in the National Register of Historic Places, where Internment History 

Enhances or May Enhance Their Significance

Site Name Location Integrity Description

Honolulu Police 

Department

842 Bethel Street, 

Honolulu, O‘ahu

High Some individuals were taken to the downtown 

Honolulu Police Department Headquarters or 

the Military Police Headquarters (formerly the 

Yokohama Specie Bank) before transfer to the U.S. 

Immigration Station. Listed as part of the Merchant 

Street Historic District in the National Register of 

Historic Places on June 19, 1973 for architecture. 

The relationship to World War II internment 

enhances the significance of the site.

Yokohama Specie 

Bank

36 Merchant 

Street, Honolulu, 

O‘ahu

High The Yokohama Specie Bank was originally a bank 

for Japanese nationals living in Hawaiʻi. After the 

attack on Pearl Harbor, the building was seized by 

the Army and used as the military police station. It 

housed a jail in the basement where it is reported 

that Hawaiian residents of Japanese ancestry were 

kept prior to transfer to the U.S. Immigration 

Station. Listed as part of the Merchant Street 

Historic District in the National Register of Historic 

Places on June 19, 1973 for architecture.

Kauaʻi County 

Courthouse

4444 Rice Street, 

Līhuʻe, Kaua‘i

High According to information obtained during public 

meetings conducted for this study, Kauaʻi internee 

hearings were held here. Listed as part of the Līhuʻe 

Civic Center Historic District in the National 

Register of Historic Places on December 17, 1981 

for architecture. Its association with World War II 

internment expands its significance.

Table 3-3: Sites Associated with World War II Internment in Hawai'i Recommended for 

Nomination to the National Register of Historic Places

Site Name Location Integrity Description

Kilauea Military 

Camp (KMC)

Hawai‘i Volcanoes 

National Park, 

Island of Hawaiʻi

High Used as an internment site for individuals from the 

island of Hawaiʻi until mid-1942, KMC is significant 

as a true and relatively unspoiled example of an 

internment site quickly created at a military facility, 

itself a recreation site hastily adapted for wartime use.

Lānaʻi City Jail 

and Courthouse

Gay and 8th 

Street, Lānaʻi City, 

Lānaʻi

High Two or three internees from Lāna‘i were arrested and 

held at the Lāna‘i City Jail. Structures remain in their 

original location, little modified, on Lānaʻi City’s open 

square. The Lānaʻi City Jail and courthouse along 

with several other structures in the historic Lānaʻi City 

downtown area, were listed as one of the National 

Trust for Historic Preservation’s 11 Most Endangered 

Historic Places in 2009.
66 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Table 3-4: Sites Needing Additional Research

Site Name Location Integrity Description

Waiākea Prison 

Camp

Hilo, Island of 

Hawai‘i

Unknown As a hard-labor prison camp where internees 

considered “troublemakers” were sent, this site could 

have a high level of significance for its ability to convey 

the reach of martial law. However, its integrity needs to 

be determined.

Hilo Independent 

Japanese 

Language School

Hilo, Island of 

Hawai‘i

Unknown According to information obtained during public 

meetings conducted for this study, individuals were 

detained at this site pending transfer to Oʻahu. 

Location and integrity need to be determined.

Līhuʻe Plantation 

Gymnasium

Līhuʻe, Kaua‘i Unknown Because one internee was held in solitary confinement 

at this site for a month, it would be considered a 

secondary site associated with internment. The 

structure still remains at Isenberg Park. However, 

additional research would be necessary to determine 

integrity. This site may have potential for interpreting 

internment during World War II.

Kalāheo Stockade Kalāheo vicinity, 

Kaua‘i

Unknown With a capacity for 20 to 25 people and used for more 

than 6 months, this is a primary site associated with 

internment in Hawai‘i. However, location and integrity 

need to be determined. 

Haʻikū Military 

Camp

Haʻikū, Maui Unknown Historic records indicate there were at least four 

internees at this site in September 1943, and the fact 

that they were present almost two years after the 

war started suggests Haʻikū may have been used to 

incarcerate internees for a long time. One building 

remains from its World War II use, but its relationship 

to internment is unknown. Other features of the camp 

have reportedly been removed.

Maui County 

Courthouse and 

Police Station

150 and 200 

South High Street, 

Wailuku, Maui

High Further investigation is required to determine whether 

the Courthouse and Police Station were associated 

with the World II internment. The Courthouse and the 

Police Station were listed as part of the Wailuku Civic 

Center Historic District in the National Register of 

Historic Places in 1986 for their architecture and for 

their association with the early development of Maui 

County.
Chapter 3: Resource Significance  National Significance Conclusion 67

Table 3-5: Other Sites

Site Name Location Integrity Description

Sand Island 

Detention Camp

Sand Island, 

O‘ahu

Lacks 

Integrity/

Demolished

The Sand Island Detention Camp opened on 

December 8, 1941 and operated for 15 months until 

March 1, 1943. At one point there were four separately 

fenced enclosures for internees, two for male Nikkei 

with 250 persons each, one for 40 females “of mixed 

races,” and one for 25 male U.S. citizens and nationals 

of German and Italian ancestry. Most internees were 

sent to mainland internment camps; some were sent to 

Honouliuli Internment Camp once it was constructed. 

Today, no evidence of the internment camp remains.

Wailua County Jail Wailua, Kaua‘i Lacks 

Integrity/ 

Destroyed

The Wailua County Jail was the first place on Kauaʻi 

where internees were assembled. The number of 

internees held there was approximately 65. The 

building was destroyed by a hurricane and replaced 

with a modern facility of several one-story buildings, 

now known as the Kauaʻi Community Correctional 

Center. No buildings related to the internment history 

remain in that location.

Waimea Jail Līhuʻe, Kaua‘i Lacks 

Integrity/ 

Demolished

At least ten Nikkei were incarcerated at the jail, 

including one Nikkei woman from Ni‘ihau. It is 

believed that the jail has since been demolished. Its 

site is the current location of the county police and fire 

station in Waimea.

Kaunakakai Jail 

and Courthouse

Kalāheo vicinity, 

Kaua‘i

Moved The few individuals of Japanese heritage from Molokaʻi 

were likely jailed here before being transferred to the 

Maui County Jail and then to Oʻahu. The Kaunakakai 

County Jail and courthouse are still standing but were 

moved offsite to a local park to make room for a new 

public library. Moved properties are generally not 

eligible for the National Register.

Maui County Jail 600 Waiale Road, 

Wailuku, Maui

Lacks 

Integrity/

Demolished

The Maui County Jail, also called the Wailuku County 

Jail, was used to detain individuals of Japanese descent. 

It was called the "Detention Camp, Wailuku." The jail 

was demolished in 1970.
68 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 
4SUITABILITY
Latrine and shower room foundation in the guard camp uncovered by JCCH volunteers in 2011, Honouliuli Internment Camp. 

Photo: Jeffery Burton.
Chapter 4: Suitability  Introduction 69

CHAPTER 4: SUITABILITY

This section describes the National Park Service 

analysis of whether nationally significant sites are 

suitable for inclusion in the national park system.

Introduction

To be considered suitable for addition to the 

national park system, an area must represent 

a natural or cultural resource type that is 

not already adequately represented in the 

national park system, or is not comparably 

represented and protected for public enjoyment 

by other federal agencies; tribal, state, or local 

governments; or the private sector. Adequacy 

of representation is determined on a caseby-case basis by comparing the potential 

addition to other comparably managed areas 

representing the same resource type, while 

considering differences or similarities in the 

character, quality, quantity, or combination of 

resource values. The comparative analysis also 

addresses rarity of the resources, interpretive 

and educational potential, and similar resources 

already protected in the national park system 

or in other public or private ownership. The 

comparison results in a determination of 

whether the proposed new area would expand, 

enhance, or duplicate resource protection 

or visitor use opportunities found in other 

comparably managed areas.

For the purposes of this analysis only the sites 

found to be nationally significant in Hawai‘i 

(Honouliuli Internment Camp and the U.S. 

Immigration Station) are analyzed compared 

to the U.S. mainland incarceration sites. 

Honouliuli Internment Camp and the U.S. 

Immigration Station are analyzed in comparison 

with the history and conditions of mainland 

incarceration sites and other similarly themed 

sites throughout the United States. In addition, 

this chapter analyzes Honouliuli Internment 

Camp and the U.S. Immigration Station in the 

context of other national park system units 

and sites related to similar themes of peopling 

places, creating social institutions, expressing 

cultural values, shaping the political landscape, 

and the changing role of the United States in the 

world community.

Comparative Analysis of 

U.S. Mainland and Hawai‘i 

Incarceration Sites

This section compares the history, sites, 

quality and quantity, and opportunities for 

interpretation and education between the U.S. 

mainland and Hawai‘i incarceration sites during 

World War II. Several mainland incarceration 

sites are designated units of the national park 

system or are national historic landmarks, and 

this section documents the similarities and 

differences between these mainland sites and 

Honouliuli Internment Camp and the U.S. 

Immigration Station. 

DIFFERENCES BETWEEN THE HISTORY 

OF THE INCARCERATION OF CIVILIANS 

ON THE U.S. MAINLAND AND IN 

HAWAI‘I 

The incarceration of civilians during World 

War II has been determined to be a nationally 

significant episode in American history. In 

Chapter 3: Resource Significance, the section 

Significance of the Events: Incarceration of 

Civilians in the United States during World 

War II provides a complete description of 

the differences between the incarceration of 

civilians in Hawai‘i and on the U.S. mainland. 

The following description provides a summary 

of the key differences to set the context for the 

suitability analysis and determinations.

First, the legal mechanism used to authorize 

incarceration in Hawaiʻi was martial law, 

as opposed to Executive Order 9066 on 

the mainland. Martial law was declared in 

the Hawaiian Islands on December 7, 1941 

immediately following the attack on Pearl 

Harbor. Martial law gave the U.S. military 

jurisdiction over the islands and became the 

mechanism for incarcerating Japanese and 

European American citizens until October 

24, 1944. Immediately before martial law was 

lifted, President Roosevelt signed Executive 

Order 9489, modeled after Executive 9066, that 

authorized Hawai‘i’s military to intern enemy 

aliens and expel from the islands any U.S. 

citizen who were considered a security threat.

Second, although the threat of sabotage, 

aiding and abetting, and espionage was 

potentially much greater in Hawai‘i than on 

the mainland, less than 2 percent of the Nikkei 
70 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

in Hawai‘i were incarcerated as compared 

to the mass incarceration of all people of 

Japanese descent from the mainland’s West 

Coast. Nikkei composed 37% of Hawai‘i’s 

population and were well integrated into the 

social, political, and economic life of Hawaiʻi. 

A mass incarceration was not only logistically 

impossible but also would have crippled the 

economy and social order of the islands. 

In addition, the more strategic approach to 

incarceration allowed Nikkei in Hawai‘i to 

contribute fully to the war effort in civilian roles 

and through the all-Nisei military units.

Third, although the more limited incarceration 

in Hawai‘i was less damaging to the morale 

of the general population, it may have had 

even more insidious effects on the targeted 

individuals. Incarceration on the mainland was 

psychologically and financially devastating for 

the entire Japanese American population. In 

Hawai‘i, to be designated a possible traitor and 

imprisoned was arguably more stigmatizing for 

those involved. Residents of German and Italian 

descent were similarly labeled and incarcerated.

Fourth, the level of public understanding and 

awareness about the history of incarceration 

of civilians during World War II is drastically 

different. On the mainland during World War II, 

the mass incarceration was well known on the 

West Coast because all Nikkei were excluded 

and confined, and the media promulgated 

wartime hysteria and broadcasted the many 

aspects and events of the mass incarceration. 

The mainland incarceration has also been well 

documented, and there is a growing level of 

public awareness about this history. In contrast, 

the incarceration in Hawai‘i was largely kept 

secret during World War II, and this history is 

only now the subject of recent scholarship and 

public awareness campaigns. 

Japanese American heads of family and persons living alone wait outside the Civil Control Station, San Francisco, in response to Civilian 

Exclusion Order Number 20. Photograph by Dorothea Lange, April 25, 1942. Photo: National Archives and Records Administration.
 Chapter 4: Suitability  Comparative Analysis of U.S. Mainland and Hawai‘i Incarceration Sites 71

DIFFERENCES BETWEEN THE 

U.S. MAINLAND AND HAWAI‘I 

INCARCERATION SITES

The incarceration sites—their operation, 

physical locations, structural layout and 

composition, and imprisoned populations were 

markedly different between the mainland and 

Hawai‘i sites. 

Mainland Incarceration Sites

On the mainland, the incarceration process 

and sites were operated by several government 

departments and agencies. These included 

the War Department through the Western 

Defense Command and its Wartime Civil 

Control Administration; the Department 

of Justice and its agencies— the Federal 

Bureau of Investigation and Immigration 

and Naturalization Service; and the War 

Relocation Authority (WRA). The WRA was 

established by executive order to administer 

the mass incarceration of all Nikkei from the 

West Coast at the WRA centers. Generally, 

the War Department and Justice Department 

ran internment camps for individuals deemed 

enemy aliens, while the WRA operated camps 

for the mass incarceration of Nikkei, two-thirds 

of whom were American citizens. 

Soon after the bombing of Pearl Harbor on 

December 7, 1941, thousands of West Coast 

Issei leaders were arrested and taken to local 

immigration stations. After processing, most 

of them were then sent to internment camps 

throughout the U.S. These small camps were 

designed for individuals who were singled out 

by the government as potentially dangerous, 

deemed disloyal, and for those requesting 

repatriation or expatriation to Japan. These 

camps included, but were not limited to, citizen 

isolation centers, temporary detention stations, 

and Department of Justice internment camps. 

These facilities housed mostly men and ranged 

in size from imprisoning fewer than a hundred 

individuals to a few thousand. They were 

generally located in remote areas and set up as 

prisons guarded by Border Patrol agents. 

Once Executive Order 9066 was signed by 

President Roosevelt on February 19, 1942, 

all West Coast Nikkei were forcibly removed 

from their homes and sent to one of fifteen 

temporary detention facilities, called “assembly 

centers” run by the Wartime Civil Control 

Administration. These facilities were generally 

located in converted fairgrounds, racetracks, 

and exposition centers. Their function was to 

hold the incarcerated Japanese Americans while 

the more permanent WRA centers were being 

constructed in remote locations.

The mainland WRA centers (including 

Manzanar, Minidoka, and Tule Lake) were 

located on desolate and expansive tracts of 

government land. The camps were massive, 

covering tens of thousands of acres and 

composed of hundreds of barracks and 

temporary buildings. The camp layouts were 

organized into dozens of blocks of cramped 

communal quarters with WRA operations 

and staff areas separated for functionality and 

perceived security. Large areas of open space 

often surrounded the camps—these areas were 

used for agriculture to enable the camps to be 

sustainable during wartime. 

The ten massive WRA camps were the 

temporary residences for 120,000 Japanese 

Americans of all ages and backgrounds, 

including women, children, and the elderly 

and infirm. In time, the incarcerated Nikkei 

transformed the WRA camps into largely 

self-sustaining communities, functioning as 

small towns with their own schools, places 

of worship, community organizations, and 

recreational leagues. Incarcerated Nikkei 

established businesses, such as general stores, 

banks, and barbershops. Many worked in and 

around the camps, whether in a professional 

capacity as doctors or teachers, or to support 

nearby agriculture or supply the military with 

materials for the war effort. 

Many of the mainland incarceration sites have 

received designations as national park system 

units, national historic landmarks, national 

register of historic places properties, and state 

historic designations. 

Units of the national park system that represent 

the history of incarceration on the mainland:

MANZANAR NATIONAL HISTORIC SITE (INDEPENDENCE, 

CALIFORNIA)

Manzanar National Historic Site is located in 

the Owens Valley of eastern California and 

protects and interprets the historical, cultural, 

and natural resources associated with the mass 

incarceration of Japanese Americans during 
72 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

World War II. Manzanar was the first camp to 

open and the first to be administered by the 

WRA. The camp held 10,046 internees for 44 

months—second only to Tule Lake in the length 

of its occupation. Manzanar National Historic 

Site is considered the best preserved of the 

mainland incarceration camps (NPS 2012, 136). 

MINIDOKA NATIONAL HISTORIC SITE (JEROME COUNTY, 

IDAHO)

Minidoka National Historic Site, in Jerome 

County, Idaho, was established to preserve the 

historic features and interpret the history of 

the former Minidoka Relocation Center, which 

held 13,000 Nikkei from Washington, Oregon, 

California, and Alaska during World War II. 

Located in the high desert of the Snake River 

Plain, it became the seventh most populous 

region in Idaho during World War II, due to 

the size of the camp. Minidoka was known for 

having a high number of Nisei who served in the 

U.S. military during the war. 

NIDOTO NAI YONI MEMORIAL (BAINBRIDGE ISLAND, 

WASHINGTON)

A satellite unit of Minidoka National Historic 

Site, the Nidoto Nai Yoni Memorial marks 

the location of the Eagledale ferry dock on 

Bainbridge Island. Here, on March 30, 1942, 

227 residents of Japanese descent—two-thirds 

of them American citizens—were rounded up 

to board a ferry as they were forcibly removed 

from the island and sent to Manzanar. They 

were the very first Nikkei to be exiled from the 

West Coast; approximately one year later, the 

majority of these Bainbridge Island residents 

were transferred to Minidoka. Nidoto Nai Yoni

means “Let It Not Happen Again.”

TULE LAKE UNIT OF WWII VALOR IN THE PACIFIC

NATIONAL MONUMENT (NEWELL, CALIFORNIA)

The Tule Lake Unit, in rural Newell, California, 

preserves and interprets the history and setting 

of the incarceration and later segregation of 

Nikkei at Tule Lake during World War II. Tule 

This photograph of Manzanar, taken by Ansel Adams in 1943, illustrates the exposed, remote conditions of the majority of mainland 

incarceration sites. Photo: Library of Congress.
 Chapter 4: Suitability  Comparative Analysis of U.S. Mainland and Hawai‘i Incarceration Sites 73

Photographs of Tule Lake reveal key differences between Hawaiian and mainland incarceration sites. Above: Internees contribute to 

a large-scale agricultural operation typical of mainland sites. Below: Women pose outside a barber shop at Tule Lake. Mainland WRA 

camps were often self-sustaining communities, where incarcerees developed their own businesses, civic organizations, and recreational 

leagues. Both photos c. 1942–43, Library of Congress.
74 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Lake was the largest of the ten WRA camps, 

incarcerating approximately 29,000 people over 

the duration of the war. It was also the longest 

in operation, closing in March 1946. In 1943, 

the government administered an ill-conceived 

“loyalty” questionnaire to distinguish “loyals” 

from “disloyals.” Those who answered “no,” 

refused to answer, or gave qualified answers 

were deemed “disloyal.” In summer 1943, the 

camp was converted to the segregation center. 

“Loyals” at Tule Lake were given the option to 

move to another camp, while simultaneously, 

all “disloyals” from the other camps were 

transferred to Tule Lake. The level of security 

intensified, culminating in November 1943 

when the camp was placed under martial law, 

surrounded by tanks and cavalry. Tule Lake may 

be the best example of what President Roosevelt 

called concentration camps in the United States 

during World War II. 

Ten miles from the segregation center is Camp 

Tulelake—one of three areas that compose the 

Tule Lake Unit in northern California. While 

the Tule Lake Unit’s most recognized history 

is related to the mass incarceration of Nikkei 

during World War II, Camp Tulelake also played 

a significant role in incarcerating Nikkei as well 

as prisoners of war. 

National Historic Landmarks that represent the 

history of incarceration on the mainland:

ROHWER RELOCATION CENTER MEMORIAL CEMETERY

(DESHA COUNTY, ARKANSAS)

Located 5 miles west of the Mississippi River in 

southeastern Arkansas, the Rohwer Relocation 

Center operated between September 1942 

and November 1945, holding a maximum 

population of 8,475. The site differs from many 

of the other camps in its riparian setting, once 

forested and now primarily devoted to crops 

and housing. Though few visible remnants 

of the camp exist today, the cemetery is one 

of only three remaining incarceration camp 

cemeteries. 

GRANADA RELOCATION CENTER (PROWERS COUNTY, 

COLORADO)

Sited on an exposed prairie in southeastern 

Colorado, the Granada Relocation Center 

was also called Amache. The smallest of the 

WRA centers, Granada held 7,597 people at its 

peak in October 1942. Most Nikkei came from 

Photos (top to bottom): 1. Remnants of a storage building 

for the camp cooperative store, Granada Relocation Center. 

Photo: Nathan W. Armes, Armes Photography. 2. The Rohwer 

Relocation Center Memorial Cemetery. Photo: Arkansas State 

University.
 Chapter 4: Suitability  Comparative Analysis of U.S. Mainland and Hawai‘i Incarceration Sites 75

agricultural areas in California’s central valleys, 

and Granada was notable for its significant 

agricultural production. Almost all of the 

building foundations, roads, and landscaping 

survive, and the archeological resources are 

among the most intact of all of the WRA camps. 

HEART MOUNTAIN RELOCATION CENTER (PARK

COUNTY, WYOMING)

The Heart Mountain Relocation Center 

was built 12 miles northeast of Cody in 

northwestern Wyoming, on land previously 

managed by the Bureau of Reclamation. At its 

peak in January 1943 it held 10,767 inhabitants. 

When the draft was re-opened to Japanese 

Americans, Heart Mountain experienced 

the highest rate of draft resistance among the 

ten camps. Eighty-five men were imprisoned 

for resisting the draft and protesting the 

confinement of Japanese American citizens. 

CENTRAL UTAH RELOCATION CENTER/TOPAZ (MILLARD

COUNTY, UTAH)

Set in the high desert of west central Utah, the 

camp was also called the Topaz Relocation 

Center, for its view of Topaz Mountain. Unlike 

some other states, Utah welcomed the presence 

of Nikkei because it viewed the camps as a 

source of much-needed agricultural labor 

during wartime shortages. The population 

(8,130 at its maximum) produced much of 

its own food, despite punishing climatic 

conditions. No buildings remain in the central 

area, however many foundations, roads, and 

pathways are still intact.

POSTON ELEMENTARY SCHOOL, UNIT 1, COLORADO

RIVER RELOCATION CENTER (LA PAZ COUNTY, 

ARIZONA)

The Colorado River Relocation Center, also 

called the Poston Relocation Center, was the 

second camp to open, in May 1942. It was also 

the second largest camp with a peak occupancy 

of 17,814. Built on tribal land on the Colorado 

River Reservation, it held a unique position 

in the system due to its administration by 

the Office of Indian Affairs during 1942 and 

1943. The center was constructed despite 

the objections of the Tribal Council of the 

Colorado River Indian Tribes, and it included 

three units, each separated by 3 miles. The 

Poston Elementary School was designed by 

Japanese American architect Yoshisaku Hirose 

Photos (top to bottom): 1. The Heart Mountain Interpretive 

Center commemorates the incarceration of more than 14,000 

Japanese Americans. Photo: Stevan Leger, Heart Mountain, 

Wyoming Foundation. 2. The site of the Central Utah Relocation 

Center today. Photo: Thomas H. Simmons, Front Range Research 

Associates, Inc. 3. Remains of the Unit 1 Auditorium Building, 

Poston Elementary School, Colorado River Relocation Center. 

Photo: Thomas H. Simmons, Front Range Research Associates, 

Inc.
76 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

and built by incarcerees. It is the only standing 

elementary school within a former incarceration 

camp.

Other designated sites that represent the history of 

incarceration on the mainland:

Appendix D: Japanese American Wartime 

Incarceration Properties provides the names 

of properties, their locations, and status of 

federal and state designations of all known 

incarceration sites. This table was adapted from 

the Japanese Americans in World War II Theme 

Study.

HONOULIULI INTERNMENT CAMP

In contrast to the designated mainland 

incarceration sites, Honouliuli Internment 

Camp was run by the U.S. military. The 

Honouliuli Internment Camp was much smaller 

than the massive WRA centers. At Honouliuli, 

the approximate maximum occupancy was 

4,000 prisoners. 

Arguably more akin to the WRA and DOJ’s 

smaller incarceration and internment camps 

on the mainland, Honouliuli Camp also had 

one remarkable difference. Honouliuli Camp 

was both an internment camp and a prisoner 

of war camp, suggesting that the military—at 

least in some respects—viewed enemy soldiers 

and civilian detainees in a similar light. As the 

war progressed and with U.S. forces advancing 

toward Japan, the number of POWs increased 

at Honouliuli, ultimately totaling approximately 

4,000 POWs from Korea, Okinawa, Taiwan, 

Japan, and Italy. Simultaneously, the number 

of incarcerated civilians decreased, as these 

individuals were transferred to the mainland 

WRA and DOJ camps or paroled. The size 

of the imprisoned population at Honouliuli 

changed frequently, with the size of the camp 

increasing as the need arose.

Rather than the remote locations and vast 

landscapes that characterized the majority 

of the incarceration sites on the mainland, 

Honouliuli was situated just a few miles from 

the largest population center (Honolulu) in 

the Pacific. It was isolated at the bottom of a 

deep gulch that trapped heat and moisture and 

bred mosquitoes. Because of these qualities, 

the internees called it jigoku dani, or “hell 

valley.” The prisoners were effectively hidden 

Aqueduct leading through the prisoner of war area, Honouliuli Internment Camp, Honouliuli Day of Remembrance, February 27, 2011. 

Photo: NPS.
 Chapter 4: Suitability  Comparative Analysis of U.S. Mainland and Hawai‘i Incarceration Sites 77

from view, and the segregation imposed by the 

landform only reinforced the inhabitants’ sense 

of imprisonment. 

The differing and variable population 

influenced Honouliuli’s physical and social 

organization: it was divided into compounds 

separating prisoners of war from civilian 

internees. Inmates were housed in barracks 

and tents spread along the Honouliuli Stream’s 

basin. At Honouliuli, the sole compound 

dedicated to civilian internees was located in 

the middle of a long, narrow valley. Four POW 

compounds were located to the north, and a 

fifth POW compound plus the guard camp area 

was located to the south. The population at 

Honouliuli was predominantly male and housed 

in groups of 11 or 12 (Burton and Farrell 2011, 

10), unlike barracks in mainland camps that 

typically held several families each in one room.

Honouliuli functioned as a temporary prison 

mostly relying on materials and goods brought 

in from the outside. In contrast, the WRA 

intended for the mainland centers to be selfsufficient with vast agricultural lands, chicken 

and hog farms, and internal businesses, 

schools, and activities. While the internees at 

Honouliuli occasionally cultivated vegetables 

and reportedly improved the site with the 

introduction of trees, shrubs, and flower beds 

with rock borders (Burton and Farrell 2011, 

6), the large-scale agricultural production that 

took place on lands surrounding mainland 

WRA centers would not have been possible. 

Honouliuli Internment Camp was therefore 

much less self-sufficient and never intended to 

function as an independent unit. 

Honouliuli’s unique and intact landscape 

setting, as well as the camp composition and 

circumstances of incarceration, represent a 

distinct, often overlooked aspect of the story of 

civilian incarceration in the U.S. during World 

War II. In particular, the camp’s importance as 

the largest detention site for prisoners of war 

in Hawai‘i sets it apart from the civilian WRA 

centers on the mainland. 

Of the mainland sites within the national park 

system, Camp Tulelake of the Tule Lake Unit 

of World War II Valor in the Pacific National 

Monument is most comparable to Honouliuli 

Internment Camp. Similarities include its 

isolated location and the fact that both civilians 

and prisoners of war were incarcerated at these 

camps. 

There are also several differences, however, 

the greatest being the historical differences 

listed above (legal mechanisms justifying the 

incarceration, number of those incarcerated 

overall, and personal and social impacts 

resulting from the incarceration). Other 

differences include:

A 1940 photographof Camp Tulelake, looking northeast, when the camp was being used by the Civilian Conservation Corps. Photo: 

National Archives and Records Administration.
78 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

ŐCamp Tulelake was constructed in the 1930s 

for Civilian Conservation Corps purposes. 

It was later converted to an incarceration 

site during World War II to imprison first 

Japanese Americans and then German 

and Italian prisoners of war. Honouliuli 

Internment Camp was constructed during 

World War II for the express purpose of 

serving as an internment camp.

ŐDuring World War II, Camp Tulelake 

was sited in a remote, arid landscape and 

included two dozen wooden buildings 

on 66 acres. Honouliuli was substantially 

larger (160 acres), more developed, and 

significantly more fortified. It was set within 

a deep gulch, hidden from view, with 175 

buildings, 14 guard towers, and over 400 

tents. 

ŐThe population at Camp Tulelake 

changed three times, with groups never 

overlapping in their occupancy. First, 100 

men who refused to answer the “loyalty” 

questionnaire were incarcerated there 

before being returned to the Tule Lake 

Segregation Center or moved to DOJ camps. 

The second population included 243 Nikkei 

from other WRA centers who came to Tule 

Lake as strikebreakers and were employed 

to harvest crops. The third group included 

approximately 800 prisoners of war of 

German and Italian ancestry. In contrast, 

Honouliuli’s population transitioned from 

serving as an internment camp for civilians, 

predominantly of Japanese heritage, to 

a prisoner of war camp for soldiers and 

conscripts from Korea, Okinawa, Taiwan, 

Japan and Italy. These overlapping groups 

were all housed at Honouliuli but were 

segregated into different compounds. The 

POW population at Honouliuli was also 

significantly larger, totaling nearly 4,000 

individuals. 

ŐThe POWs at Camp Tulelake worked to 

improve the camp and then provided critical 

agricultural labor to neighboring onion 

and potato farmers. Following World War 

II, several of the German POWs stayed in 

the local area, integrating into the rural 

agricultural community. The POWs at 

Honouliuli were isolated from Hawai‘i’s 

population and returned to their homelands 

following the war.

While similarities exist between Camp 

Tulelake and Honouliuli, the many differences 

are essential to understanding the national 

significance and suitability of the Honouliuli 

Internment Camp in the context of U.S. 

mainland incarceration sites.

U.S. IMMIGRATION STATION, HONOLULU

The role of the U.S. Immigration Station in 

Hawai‘i’s World War II incarceration history 

is entirely different than both the mainland 

WRA and DOJ facilities and the Honouliuli 

Internment Camp. The U.S. Immigration 

Station was not a “camp” built to imprison 

individuals for large stretches of time. Rather 

it was an existing facility and detention site 

where prisoners were held, interrogated, 

and tried in hearings run by the U.S. military 

before being released or sent to Sand Island, 

Honouliuli Internment Camp, or the mainland 

incarceration sites. 

Honolulu’s U.S. Immigration Station played a 

similar but different role to U.S. immigration 

stations along the West Coast during World 

War II. The mainland stations, such as the 

U.S. Immigration Station at Angel Island in 

the San Francisco Bay (a National Historic 

Landmark and part of Angel Island State Park) 

and the U.S. Immigration Station at Ellis Island 

in New York (part of the Statue of Liberty 

National Monument) functioned as prisons 

in the months following Pearl Harbor where 

individuals deemed a threat to national security 

were temporarily imprisoned. In contrast, the 

Honolulu U.S. Immigration Station played a 

more central role in the incarceration history of 

Hawaiʻi, being used continuously throughout 

World War II to imprison and try citizens and 

foreign nationals in military run courts. It served 

as a holding and hearing center for all civilians 

arrested on Oʻahu and for every resident 

arrested in the Hawaiian Islands and transferred 

to Honolulu. The U.S. Immigration Station was a 

transfer point for internees before being sent to 

other incarceration sites in Hawai‘i or shipped 

to the mainland, and as a point of reentry, 

where internees were required to complete 

compulsory paperwork before release. 

In addition, the U.S. Immigration Station 

in Honolulu served as a primary portal for 

immigrants entering the United States from 

Asia and the Pacific throughout its history 

and assisted in shaping the rich multicultural 
 Chapter 4: Suitability  Comparative Analysis of U.S. Mainland and Hawai‘i Incarceration Sites 79

identity of Hawaiʻi. An examination of the U.S. 

Immigration Station’s role in the immigration 

history of Hawai‘i and the U.S. is needed to 

determine its national significance related to this 

theme.

National park system units and National Historic 

Landmarks that represent the dual history of 

incarceration and immigration on the mainland:

ANGEL ISLAND IMMIGRATION STATION (SAN FRANCISCO

BAY, CALIFORNIA)

Known as the “Ellis Island of the West,” the 

immigration station at Angel Island processed 

one million immigrants between 1910 and 1940, 

the majority of whom came from China and 

Japan. The Angel Island Immigration Station 

enforced the Chinese Exclusion Acts of the 

late 19th and early 20th centuries, as well as the 

Immigration Act of 1924, all of which restricted 

the number of Asian immigrants who could 

enter the United States. During World War II, 

Angel Island Immigration Station was used 

as a temporary prison and transfer point for 

internees and POWs of Japanese, German, 

and Italian ancestry. All internees who were 

transferred to the mainland from Hawai‘i were 

interned at Angel Island before being sent to 

WRA and DOJ camps. 

ELLIS ISLAND, STATUE OF LIBERTY NATIONAL

MONUMENT (NEW YORK, NEW YORK)

From 1892 to 1924, Ellis Island was America’s 

largest and most active immigration station, 

where over 12 million immigrants were 

processed. For the vast majority of immigrants, 

Ellis Island truly was an “Island of Hope”—the 

first stop on their way to new opportunities 

and experiences in America. For the rest, it 

became the “Island of Tears”—a place where 

families were separated and individuals were 

denied entry into this country. During World 

War II, Ellis Island was used for the detention of 

Japanese, German, and Italians deemed enemy 

aliens from the East Coast, and it became a 

transfer point between incarceration camps. At 

its peak in December 1941, it likely held over 

600 people of Japanese, German, and Italian 

ancestry.

Photos (top to bottom): 1. The U.S. Immigration Station at Angel 

Island served as a temporary detention center for internees and 

POWs during World War II. From 1910–40, harsh and restrictive 

immigration policies intended to exclude Asians resulted in 

the long-term detention of many potential immigrants here. 

Photo: Roger Wagner. 2. Young visitors to the U.S. Immigration 

Station, Angel Island, stand in front of poetry carved into walls 

by detainees. Photo: Brian Turner, National Trust for Historic 

Preservation. 3. Closer view of carved poetry, U.S. Immigration 

Station, Angel Island.Photo: Jacquie Klose.
80 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

COMPARISON OF QUALITY AND 

QUANTITY

A comparative analysis of resource quality and 

quantity is required to determine the suitability 

of a potential addition to the national park 

system. 

When evaluated against mainland incarceration 

sites, Honouliuli Camp and the U.S. 

Immigration Station possess a distinct quality 

and increased quantity of resource values. 

Honouliuli contains a large number of extant 

components, including building foundations, 

circulation routes, water and wastewater 

infrastructure, and retaining walls (Burton and 

Farrell 2007, 16, 73) in comparison with many 

of the mainland incarceration sites. These 

remnants, as well as archeological resources, 

have been protected by the site’s natural 

isolation and are currently overgrown with a 

thick layer of largely invasive plant material. 

Besides this overgrowth, the site of the camp 

has remained “virtually unchanged since World 

War II” (Burton and Farrell 2011, 35). Further 

archeological research may yield additional 

resources. Moreover, Honouliuli is remarkably 

well-preserved when compared to mainland 

POW camps, most of which have been 

substantially altered by modern developments 

(Burton and Farrell 2011, 35).

The U.S. Immigration Station is exceptionally 

well-preserved and looks much as it did during 

World War II. The fountain constructed 

by Alfredo Guisti, and the holding cells 

and courtyard where civilian Japanese and 

Europeans were held are still extant. The 

intact historic buildings at the Honolulu U.S. 

Immigration Station are comparable to the 

quality and quantity of resources at Angel Island 

and Ellis Island. 

OPPORTUNITIES FOR INTERPRETATION 

AND EDUCATION

The proximity of internment sites on Oʻahu 

to significant World War II-related resources, 

especially World II Valor in the Pacific National 

Monument, offers an exceptional opportunity 

to interpret Hawaiʻi’s incarceration history 

within the broader context of World War II. 

Honouliuli Internment Camp and the U.S. 

Immigration Station are located within a 10-

mile radius of the Pearl Harbor Visitor Center, 

part of World War II Valor in the Pacific 

National Monument. Japanese American 

history during World War II is further 

supported by the nearby Japanese Cultural 

Center of Hawaiʻi, the U.S. Army Museum, 

and the Brothers in Valor Memorial in Waikiki, 

which commemorates Japanese Americans who 

served in the armed forces during the war.

This concentration of related resources is a 

tangible representation of the impact of the 

war at island, national, and international scales. 

The experience of the war on O‘ahu was unlike 

anywhere else in the United States, and to date 

the full breadth of this history has received 

little interpretation. Educational programs 

that engage both the story of Pearl Harbor 

and its aftermath—as manifested by the U.S. 

Immigration Station and Honouliuli Internment 

Camp—would allow for a more comprehensive 

and complex portrait of the island’s strategic 

importance in the war and its impact on civil 

liberties and military and civilian life.

Photos (top to bottom): 1. Dr. Suzanne Falgout, anthropologist 

at the University of Hawai‘i–West O‘ahu, leads a multidisciplinary 

research and education project at Honouliuli. Photo: Valentino 

Valdez. 2. Honouliuli Day of Remembrance, 2011. Photo: NPS.
 Chapter 4: Suitability  Comparative Analysis of U.S. Mainland and Hawai‘i Incarceration Sites 81

A comparison of the U.S. Immigration 

Station alone to interpretive and educational 

opportunities at Angel Island and Ellis Island 

yields different findings. Both Angel Island 

and Ellis Island have been preserved for 

their national significance associated with 

U.S. immigration, contain authentic historic 

buildings and features, and are managed as 

historic sites. Both Angel Island and Ellis Island 

have interpretive staff and offer a wide variety 

of interpretive and educational information 

through various media (exhibits, websites, 

tours, etc.). Visitors come to Angel Island and 

Ellis Island to learn about the sites’ stories. 

In 2012, Ellis Island received 1.89 million 

visitors, and approximately 200,000 people 

visit Angel Island. In contrast, Honolulu’s U.S. 

Immigration Station is still in use today by the 

Department of Homeland Security. There are 

limited opportunities for onsite interpretation 

and education because of its use as an active 

immigration station. 

NPS Thematic Framework—

Cultural Themes

In evaluating the suitability of cultural resources 

within or outside the national park system, the 

NPS uses its “thematic framework” for history 

and prehistory. The framework is an outline 

of major themes and concepts that help us to 

conceptualize American history. It is used to 

help identify cultural resources that embody 

America’s past and to describe and analyze the 

multiple layers of history encapsulated within 

each resource. 

The framework draws upon the work of 

scholars across disciplines to provide a structure 

for capturing the complexity and meaning of 

human experience and for understanding that 

past in coherent, integrated ways. Through 

eight concepts that encompass the multifaceted and interrelated nature of human 

experience, the thematic framework reflects a 

more interdisciplinary, less compartmentalized 

approach to American history. Five of the eight 

concepts apply to the civilian incarceration at 

Honouliuli Camp and the U.S. Immigration 

Station, as well as to the mainland incarceration 

sites described above. These five concepts are:

ŐPeopling Places

ŐCreating Social Institutions and Movements

ŐExpressing Cultural Values

ŐShaping the Political Landscape

ŐThe Changing Role of the United States in 

the World Community

Each of the concepts identified rest on a 

framework of topical sub-themes that are used 

to describe and explain the significance of the 

primary theme.

Each of the concepts is described along with 

how Honouliuli Internment Camp and the 

U.S. Immigration Station are relevant to the 

theme. Similar national park system units and 

national historic landmarks are described as 

comparisons. The sites selected as comparisons 

are drawn from historic sites with themes 

related to World War II, Asian American 

and Pacific Islander history, places of forced 

confinement, and cultural resilience in the face 

of discrimination. In addition, the comparable 

sites may be nationally significant related 

to other concepts described in this section. 

The five concepts also apply to the mainland 

incarceration sites, though they are not repeated 

below for the purposes of reducing repetition.

PEOPLING PLACES

This theme examines human population 

movement and change through prehistoric and 

historic times. It also looks at family formation; 

at different concepts of gender, family, and 

sexual division of labor; and at how they 

have been expressed in the American past. 

While patterns of daily life—birth, marriage, 

childrearing—are often taken for granted, they 

have a profound influence on public life.

Life in America began with migrations many 

thousands of years ago. Centuries of migrations 

and encounters have resulted in diverse forms of 

individual and group interaction, from peaceful 

accommodation to warfare and extermination 

through exposure to new diseases. 

Communities, too, have evolved according to 

cultural norms, historical circumstances, and 

environmental contingencies. The nature of 

communities is varied, dynamic, and complex. 

Distinctive and important regional patterns join 

together to create microcosms of America’s 

history and to form the “national experience.”
82 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Topics that help define this theme include family 

and the life cycle; health, nutrition, and disease; 

migration from outside and within; community 

and neighborhood; ethnic homelands; and 

encounters, conflicts, and colonization. 

For the purposes of this study, the topics of 

1) migration from outside and within and 2) 

encounters, conflict, and colonization are most 

appropriate to the stories of internment in 

Hawaiʻi. 

Relevance of the Theme to the Sites

Honouliuli Camp illustrates that population 

movement can occur both through voluntary 

immigration and forced migration. The social 

and cultural networks established by immigrants 

to Hawaiʻi were adversely impacted by the 

incarceration of community leaders: for those 

interned, these stable communities gave way 

to temporary settlements in the camp, where 

imprisonment severely disrupted accepted 

social and cultural structures. Likewise, 

prisoners of war from Korea, Okinawa, Taiwan, 

Japan, and Italy were forcibly moved to the 

camp and experienced it only a short time 

before they were transferred again to POW 

camps on the mainland. 

The U.S. Immigration Station in Honolulu is a 

testament to the experience of immigration and 

the U.S. government’s treatment of immigrants 

in times of peace and conflict. The station 

played a direct role in welcoming immigrants 

to the United States, while its wartime use as 

a temporary detention center and point of 

transfer for internees illustrates the ambivalent 

relationship that existed between Hawaiʻi’s 

government and immigrant communities.

Many of the comparably managed sites that 

are most relevant to Honouliuli and the U.S. 

Immigration Station and that reflect the theme 

of Peopling Places are concentrated on the West 

Coast and reflect America’s diverse cultures, 

specifically Asian American heritage.

Units of the national park system that reflect the 

theme of Peopling Places:

WING LUKE MUSEUM OF THE ASIAN PACIFIC

AMERICAN EXPERIENCE NPS AFFILIATED AREA

(SEATTLE, WASHINGTON)

Founded in 1967, the Wing Luke Museum is 

located in Seattle’s Chinatown-International 

District, a National Register-listed historic 

district. It offers a uniquely American story 

of Asian Pacific people and how they came to 

thrive in the United States, illustrating how 

initially temporary immigrant settlements 

were made permanent through the creation 

of community and the nurturing of social and 

cultural values.

KALAUPAPA NATIONAL HISTORICAL PARK (MOLOKA‘I, 

HAWAI‘I)

Kalaupapa National Historical Park honors the 

moʻolelo (story) of individuals with Hansen’s 

disease (leprosy) who were forcibly exiled to 

a remote peninsula between 1866 and 1969. 

Photos (top to bottom): 1. Wing Luke Museum, Seattle. Olson 

Kundig Architects. 2. The installation Letter Cloud, in the Wing 

Luke Museum, evokes the experience of Asian Pacific emigrants 

to the United States and shares hundreds of individual stories 

about building a life in a new country, far from loved ones. 

Created by artists Erin Shie Palmer and Susie Kozawa, the 

exhibit suspends reproductions of letters home, handwritten by 

immigrants. Photos © Lara Swimmer / www.swimmerphoto.

com.
 Chapter 4: Suitability  Comparative Analysis of U.S. Mainland and Hawai‘i Incarceration Sites 83

Kalaupapa, once a community in isolation, 

now serves as a place for education and 

contemplation, where past suffering has given 

way to personal pride about accomplishments 

made in the face of great adversity. 

National Historic Landmarks and National 

Register Districts that reflect the theme of Peopling 

Places: 

AUBURN–CHINESE SECTION (AUBURN, CALIFORNIA)

This site was home to Chinese laborers working 

on the transcontinental railroad in the 1850s 

and contains buildings associated with the 

Chinese community. The Auburn Chinese 

Section is listed on the Historic American 

Buildings Survey.

CREATING SOCIAL INSTITUTIONS AND 

MOVEMENTS

This theme focuses on the diverse formal and 

informal structures such as schools or voluntary 

associations through which people express 

values and live their lives. Americans generate 

temporary movements and create enduring 

institutions in order to define, sustain, or reform 

these values. Why people organize to transform 

their institutions is as important to understand 

as how they choose to do so. Thus, both the 

diverse motivations people act on and the 

strategies they employ are critical concerns of 

social history. This category also encompasses 

temporary movements that influenced 

American history but did not produce 

permanent institutions. 

Topics that help define this theme include clubs 

and organizations, reform movements, religious 

institutions, and recreational activities. 

Topics relevant to this study are 1) clubs and 

organizations, 2) reform movements, and 3) 

recreational activities. 

Relevance of the Theme to the Sites 

Honouliuli Internment Camp was a 

government-created and -forced social 

institution that incarcerated many prominent 

leaders in the Japanese American community. 

These individuals had worked to create 

organizations to uphold Japanese cultural 

values, and their internment disrupted both 

the social configuration of the community and 

its value systems. Though Honouliuli did not 

possess the social and recreational institutions 

that existed in mainland sites, internees 

arranged athletic activities in a designated field 

to help alleviate the tedium and discomfort 

of life in the camp (Territory of Hawaii n.d., 

2). Also, while at Sand Island, detainees 

organized their own evening entertainment, 

known as the “Blackout Show” (Sugita 1978, 

2); similar internee-created programs may 

also have occurred at Honouliuli Camp. These 

actions represent an attempt to transform a 

government-imposed institution and illustrate 

the perseverance of internees in the face of 

adversity. Today the site strengthens Japanese 

cultural values and reaffirms constitutional 

values through pilgrimages, days of 

remembrance, and educational programs that 

acknowledge government wrongdoing. 

Like Honouliuli, the U.S. Immigration Station 

in Honolulu was purposefully used to break 

down Japanese American cultural and 

social institutions by removing their leaders. 

Individuals who were arrested, questioned, and 

detained at the station suffered the stigma of 

having been singled out as potentially disloyal. 

Furthermore, their forced absence created a 

leadership vacuum in their home communities, 

resulting in long-term adverse effects. 

Units of the national park system that reflect 

the theme of Creating Social Institutions and 

Movements:

ALEUTIAN WORLD WAR II NATIONAL HISTORIC AREA

(AMAKNAK ISLAND, ALASKA)

This National Historic Area preserves and 

interprets the deadly Aleutian Campaign of 

World War II, including the forced removal 

of Unangan (Aleut people) from nine villages 

in the Aleutian Islands. In 1942, in the face of 

increased Japanese aggression in the islands, 

the U.S. government uprooted and sent 881 

Unangan to squalid camps in Southeast Alaska, 

where 74 people died. Despite the horrors of 

this experience, the Unangan sought jobs in 

nearby towns, built new living quarters, and 

even erected a makeshift church to replace the 

church that had been destroyed during the 

evacuation.
84 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

NEZ PERCE NATIONAL HISTORICAL PARK (IDAHO, 

MONTANA, OREGON, AND WASHINGTON)

The park’s 38 sites, spreading across 

Idaho, Washington, Oregon, and Montana, 

commemorate the Nez Perce, who developed 

a distinct culture through more than 11,000 

years of interaction with the environment and 

landscape of their traditional homeland. The 

park includes the Nez Perce National Historic 

Trail, which preserves the route followed by the 

Nez Perce tribe when they were forced from 

their homelands by the U.S. Army in 1877.

National Historic Landmarks and National 

Register Districts that reflect the theme of Creating 

Social Institutions and Movements:

DANCING RABBIT CREEK TREATY SITE (NOXUBEE

COUNTY, MISSISSIPPI)

On September 27, 1830, the Choctaw tribe 

signed a forced treaty at this gathering place. 

The treaty gave up all claims to land east of 

the Mississippi River and ultimately led to 

the tribe’s removal. The treaty later served as 

a model for similar pacts of removal for the 

Chickasaw, Cherokee, Creek, and Seminole 

nations.

EXPRESSING CULTURAL VALUES

This theme covers expressions of culture—

people’s beliefs about themselves and the world 

they inhabit. For example, Boston African 

American Historic Site reflects the role of 

ordinary Americans and the diversity of the 

American cultural landscape. This theme also 

encompasses the ways that people communicate 

their moral and aesthetic values. 

Topics that help define this theme include 

educational and intellectual currents; visual 

and performing arts; literature; mass media; 

architecture, landscape architecture, and urban 

design; and popular and traditional culture.

For the purposes of this study, the topics of 

1) visual and performing arts; 2) literature; 

3) architecture, landscape architecture, and 

urban design; and 4) popular and traditional 

culture are most appropriate to the stories of 

internment in Hawaiʻi. 

Photos (top to bottom): 1. One of the few remaining U.S. Army 

defense structures in the Aleutian World War II National Historic 

Area, Amaknak Island, Alaska. Photo: David Wessel, Principal, 

Architectural Resources Group. 2. The church in the Aleutian 

village Kashega in 1938, photographed by Alan G. May during a 

Smithsonian Institution Archeological Expedition to the Aleutian 

Islands. It was never permanently resettled after the villagers 

were removed in 1942.Photo: Alan G. May papers, University of 

Alaska Anchorage. 3. Unangan children forcibly removed from 

their homes and relocated to Southeast Alaska. Photo: George 

Dale, 1942, Alaska State Library.
 Chapter 4: Suitability  Comparative Analysis of U.S. Mainland and Hawai‘i Incarceration Sites 85

Relevance of the Theme to the Sites

The World War II incarceration sites in Hawaiʻi 

reflect the persistence of Japanese cultural 

ideals—including honor and perseverance—

when faced with the loss and debasement 

of cultural identity in wartime. The effort of 

some internees to appeal their incarceration 

using legal channels also represents cultural 

values, such as perseverance and belief in the 

government and in the U.S. Constitution.

The art, poetry, and landscapes created by 

internees at Honouliuli Camp are a tangible 

expression of the experience of incarceration 

and reflect the cultural values of Japanese 

Americans and European Americans. According 

to the Swedish Vice-consul’s reports in 1943, 

detainees improved the conditions of the camp 

by “planting...trees and shrubs, arranging 

flower beds with rock borders and otherwise 

embellishing their surroundings with the 

materials at hand” (Burton and Farrell 2011, 

6). Artists, such as Dan Toru Nishikawa, filled 

notebooks with drawings, and other internees 

composed poetry as a means both of passing 

time and documenting their experience. 

These first-hand expressions reveal detainees’ 

personal responses to the internment and 

convey a sense of day-to-day life in the camp.

The design of the U.S. Immigration Station 

illustrates its role as a gateway to the United 

States and articulates Hawaiʻi’s identity as a 

geographic and cultural crossroads. Extant 

features such as the courtyard fountain, 

created by an Italian prisoner of war, reflect the 

persistence of cultural expression in the face of 

incarceration.

Units of the national park system that reflect the 

theme of Expressing Cultural Values:

CANE RIVER CREOLE NATIONAL HISTORICAL PARK

(NATCHITOCHES PARISH, LOUISIANA)

The nearly three-hundred-year relationship 

between the Cane River Creoles and their 

homeland was shaped by the river. This 

relationship was tested by flood, drought, war, 

and numerous other obstacles, but through 

resilience and resourcefulness, the Creole 

culture was able to endure and thrive. This park 

is part of the 40,000-acre Cane River National 

Heritage Area and demonstrates the history of 

colonization, frontier influences, French Creole 

architecture and culture, cotton agriculture, 

slavery, and social practices over almost three 

centuries.

NICODEMUS NATIONAL HISTORIC SITE (GRAHAM

COUNTY, KANSAS)

Established by African Americans during the 

Reconstruction Period following the Civil War, 

the town of Nicodemus is symbolic of the 

pioneer spirit of people formerly enslaved, who 

dared to leave the only region they had been 

familiar with to seek personal freedom and 

the opportunity to develop their talents and 

capabilities. Nicodemus National Historic Site 

is composed of five discontiguous properties 

containing some of the oldest surviving 

structures within the townsite: it is the oldest 

and only remaining Black settlement west of the 

Mississippi River.

Photos (top to bottom): 1. The history of Prud’homme’s Store, in 

Cane River Creole National Historical Park, exemplifies the social 

and cultural significance of the local store to communities in the 

South in the late 19th and early 20th centuries. Photo: Kevin 

Stewart. 2 Extant school building at Nicodemus National Historic 

Site, Kansas. Photo: Will Pope, NPS. 
86 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

The Kam Wah Chung Company Building was the social, cultural, 

and commercial hub of the once-thriving Chinese immigrant 

community in John Day, Oregon. Photo: Mitch Darby / www.

obsidianarchitecture.com.

National Historic Landmarks and National 

Register Districts that reflect the theme of 

Expressing Cultural Values:

PANAMA HOTEL (SEATTLE, WASHINGTON)

Designed by Japanese American architect Sabro 

Ozasa and built in 1910, the Panama was a 

working-class hotel that served generations of 

Japanese immigrants and international travelers. 

Located in the heart of Seattle’s Nihonmachi, 

or Japantown, the basement of the building 

includes the best surviving example of an urban 

Japanese-style bath house, or sento. Found in 

virtually every Nihonmachi, sentos provided 

a cultural connection with a 1,200-year-old 

tradition, remade in an urban American 

setting. The hotel stored the belongings of 

many community members who were interned 

in WRA camps. The majority never returned 

for their possessions, and many of these trunks 

remain to this day.

KAM WAH CHUNG COMPANY BUILDING (JOHN DAY, 

OREGON)

The Kam Wah Chung Company Building 

is the best known example of a Chinese 

mercantile and herb store in the United States, 

representing the Chinese role in the post-Civil 

War expansion period of the American West. 

It is significant for its association with Chinese 

immigrants in the development of the American 

West.

SHAPING THE POLITICAL LANDSCAPE

This theme encompasses tribal, local, state, and 

federal political and governmental institutions 

that create public policy and those groups that 

seek to shape both policies and institutions. 

Sites associated with political leaders, theorists, 

organizations, movements, campaigns, and 

grassroots political activities all illustrate aspects 

of the political environment. 

Topics that help define this theme include 

parties, protests, and movements; governmental 

institutions; military institutions and activities; 

and political ideas, cultures, and theories.

The sub-themes that are most relevant to 

the history of incarceration in Hawaiʻi are 

1) governmental institutions; 2) military 

institutions and activities; and 3) political ideas, 

cultures, and theories. 

Relevance of the Theme to the Sites

Honouliuli Camp illustrates the impacts of 

enacting martial law on American soil during 

WWII, in particular the authorization of the 

internment of residents of Japanese, German, 

and Italian ancestry. Legal rulings associated 

with martial law and internment shaped the 

subsequent political landscape: for example, the 

U.S. Supreme Court in Duncan v. Kahanamoku 

decided that military tribunal jurisdiction over 

civilian criminal cases was unconstitutional, 

a ruling that established a significant legal 

precedent for the protection of civil liberties in 

times of war.

In addition to its direct role in shaping the 

ethnic, cultural, and political composition 

of Hawaiʻi, the U.S. Immigration Station was 

the site of all hearings for those arrested on 

Oʻahu and possibly for all Hawaiian residents. 

It also served as a holding center; the point of 
 Chapter 4: Suitability  Comparative Analysis of U.S. Mainland and Hawai‘i Incarceration Sites 87

departure for internees who were transferred to 

Sand Island, Honouliuli, and the mainland; and 

the point of reentry.

Recognition of the injustice of the internment 

has also shaped the political landscape of the 

United States: remembering and sharing the 

stories of the incarceration acknowledges the 

fragility of constitutional rights and reasserts the 

importance of our civil liberties. 

Units of the national park system that reflect the 

theme of Shaping the Political Landscape:

ANDERSONVILLE NATIONAL HISTORIC SITE

(ANDERSONVILLE, GEORGIA)

The Camp Sumter military prison at 

Andersonville was one of the largest 

Confederate prisoner of war camps during the 

Civil War. During the 14 months the prison 

existed, more than 45,000 Union soldiers were 

confined here. Of these, almost 13,000 died. 

Today, Andersonville National Historic Site is 

a memorial to all American prisoners of war 

throughout the nation’s history.

GOLDEN GATE NATIONAL RECREATION AREA (SAN

FRANCISCO, CALIFORNIA)

Buildings 35 and 640 in the Presidio of San 

Francisco within the Golden Gate National 

Recreation Area played an important role 

related to the incarceration of Japanese 

Americans during World War II. The Military 

Intelligence Service Language School began 

classes in Building 640 on November 1, 1941 

before the attack on Pearl Harbor. The language 

school’s 60 students were predominantly 

Japanese Americans who would later be 

responsible for translating enemy documents 

and interrogating Japanese soldiers in the 

Pacific. The school was moved to Camp Savage 

in Minnesota in 1942. Lieutenant General John 

L. DeWitt, commander of the Western Defense 

Command and the U.S. 4th Army, issued the 

public proclamations and civilian exclusion 

orders that implemented Executive Order 9066 

from Building 35. 

ROSIE THE RIVETER / WORLD WAR II HOME FRONT

NATIONAL HISTORICAL PARK (RICHMOND, CALIFORNIA)

This park commemorates the efforts and 

sacrifices of American civilians on the World 

War II home front, an unprecedented scale of 

nationwide activity that resulted in profound 

changes to the country and its citizens. 

Women’s roles were forever changed, minorities 

“cracked open” the door to equal rights, and 

employer-sponsored health care programs 

began to evolve. The country itself began to 

develop a more cohesive identity, as citizens 

migrated to new areas and intermingled with 

others from around the nation. Shipyards, day 

care centers, the first managed-health-carehospital, war worker housing, and a liberty ship 

built in the shipyards are included in the park.

National Historic Landmarks and National 

Register Districts that reflect the theme of Shaping 

the Political Landscape:

HARADA HOUSE (RIVERSIDE, CALIFORNIA)

The Harada House was the object of the first 

test of the constitutionality of an alien land law 

in the United States. In California vs. Harada 

(1916–18), the right of native-born citizens 

of the United States, albeit minors, to own 

land was upheld. Directly associated with 

Japanese Americans, the case is important to all 

Americans of immigrant heritage. Though the 

Harada family was incarcerated during World 

War II, the house is still owned by a member of 

the family.

The Harada House was the subject of a California court decision 

that upheld the land ownership rights of U.S.-born children 

of immigrants. Photo: Allan Curl, National Historic Landmarks 

Program, NPS.
88 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

CHANGING ROLE OF THE UNITED 

STATES IN THE WORLD COMMUNITY

This theme explores diplomacy, trade, cultural 

exchange, security and defense, expansionism—

and, at times, imperialism. The interactions 

among indigenous peoples, between this nation 

and native peoples, and this nation and the 

world have all contributed to American history. 

Additionally, this theme addresses regional 

variations, since, for example, in the eighteenth 

century, the Spanish southwest, French and 

Canadian middle west, and British eastern 

seaboard had different diplomatic histories.

America has never existed in isolation. While 

the United States, especially in the nineteenth 

and twentieth centuries, has left an imprint 

on the world community, other nations and 

immigrants to the United States have had a 

profound influence on the course of American 

history.

The emphasis in this category is on people 

and institutions—from the principals who 

define and formulate diplomatic policy, 

such as presidents, secretaries of state, and 

labor and immigrant leaders, to the private 

institutions, such as the Carnegie Endowment 

for International Peace, that influence 

America’s diplomatic, cultural, social, and 

economic affairs. Topics that help define 

this theme include international relations, 

commerce, expansionism and imperialism, and 

immigration and emigration policies.

Relevant topics for Honouliuli Camp and the 

U.S. Immigration Station are 1) international 

relations and 2) immigration and emigration 

policies.

Relevance of the Theme to the Sites 

As sites associated with the history of 

incarceration in Hawaiʻi, Honouliuli and the 

U.S. Immigration Station engage themes of 

security and defense, immigration policies, 

cultural exchange, and diplomacy. This is 

evidenced by the government’s internment of 

immigrants—U.S. citizens as well as resident 

aliens—and its adherence to the Geneva 

Conventions in the humane treatment of 

prisoners of war.

Honouliuli Camp reflects the influence of 

martial law and illustrates the U.S. government’s 

relations with other countries, particularly 

enemy nations, during World War II. The site’s 

role as a prisoner of war camp is central to its 

history and distinguishes it from other civilian 

incarceration sites. Regular reports by the 

vice-consul of the neutral Swedish government 

constitute a significant portion of the camp’s 

historic record, and the comparatively humane 

treatment of prisoners of war in the camp 

would have a long-term beneficial impact on 

U.S.-Japanese relations. 

The U.S. Immigration Station in Honolulu 

demonstrates the changing role of the United 

States in the world community in its function as 

the entry point for thousands of immigrants to 

Hawaiʻi, who arrived in search of a better life, as 

well as for its role in detaining, questioning, and 

imprisoning members of Hawaiʻi’s immigrant 

communities. Still in active use today and 

administered by the Department of Homeland 

Security, the station continues to reflect the 

struggle to balance the ideal of America as 

a land of opportunity with concerns about 

internal safety and security. 

Units of the national park system that reflect the 

theme of the Changing Role of the United States in 

the World Community:

WORLD WAR II VALOR IN THE PACIFIC NATIONAL

MONUMENT (HONOLULU, HAWAI‘I)

This monument preserves and interprets the 

stories of the Pacific War, including the events 

at Pearl Harbor, the internment of Japanese 

Americans, the battles in the Aleutians, and 

the occupation of Japan. The United States 

responded to the Pearl Harbor attack with a 

sweeping mobilization of economic and military 

resources that fundamentally changed the U.S. 

position on the world stage.

WAR IN THE PACIFIC NATIONAL HISTORICAL PARK

(HAGÅTÑA, GUAM)

Only hours after Pearl Harbor was attacked, 

the Japanese began aerial bombings on Guam. 

Two days later the Japanese came ashore and 

the naval governor surrendered the American 

territory: the island remained under Japanese 

control until July 21, 1944. War in the Pacific 

National Historical Park was established to 

commemorate the bravery and sacrifice of 

those participating in the campaigns of the 

Pacific theater of World War II and to conserve 

and interpret outstanding natural, scenic, and 
 Chapter 4: Suitability  Conclusion—Finding of Suitability 89

historic values and objects on the island of 

Guam for the benefit and enjoyment of present 

and future generations.

National Historic Landmarks and National 

Register Districts that reflect the theme of the 

Changing Role of the United States in the World 

Community:

ATTU BATTLEFIELD AND U.S. ARMY AND NAVY

AIRFIELDS (ATTU ISLAND, ALASKA)

Attu was the site of the only World War II battle 

fought in North America. Its occupation by 

Japanese troops marked the peak of Japan’s 

military expansion in the North Pacific. Its 

recapture by Americans in 1943 was costly for 

both sides. Afterward, Attu provided a base for 

bombing missions against Japanese territories.

Conclusion—Finding of Suitability

Honouliuli Internment Camp and the U.S. 

Immigration Station in Honolulu are nationally 

significant. While the mass incarceration of 

Nikkei on the U.S. mainland during World War 

II has been recognized as a significant episode in 

U.S. history, the story of internment in Hawaiʻi 

is little known. The experience of incarceration 

in the Hawaiian Islands was distinct from the 

mainland in that it was authorized by martial 

law and targeted a small group of civilians of 

Japanese, German, and Italian ancestry, singling 

them out as disloyal. Unlike mainland camps, 

in Hawaiʻi civilian detainees were confined 

alongside prisoners of war, whose experiences 

at sites like Honouliuli represent a unique and 

important aspect of Hawaiʻi’s incarceration 

history. 

The comparative sites described above represent 

various instances of forced confinement, loss 

and reaffirmation of civil liberties, preservation 

of culture in the face of adversity, and the 

influence of immigration and conflict on 

national politics and international relations. 

While some of the sites closely represent the 

history of Nikkei incarceration in the U.S., there 

are no sites that interpret the unique history 

of World War II internment in the Hawaiian 

Islands.

Honouliuli Camp and the U.S. Immigration 

Station offer a special opportunity to expand 

our nation’s history of incarceration of civilians 

during World War II. The educational potential 

of these sites is enhanced by their quality, or 

high level of integrity, as well as the quantity of 

their extant resources. Based on the analysis 

of comparable resources and interpretation 

already represented in units of the national park 

system, or protected and interpreted by others, 

this study concludes that Honouliuli Internment 

Camp and the U.S. Immigration Station depict 

a distinct and important aspect of American 

history associated with civil liberties in times of 

conflict that is not adequately represented or 

protected elsewhere, and are therefore suitable 

for inclusion in the national park system.
90 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Photos (clockwise from top left): 1. Pacific War map, World 

War II Valor in the Pacific National Monument. 2. and 3. The 

U.S.S. Arizona Memorial, part of World War II Valor in the 

Pacific National Monument, commemorates the December 

7, 1941 bombing of Pearl Harbor. 4. U.S. Marines visit War 

in the Pacific National Historical Park, where 70 years ago 

other Marines gave their lives to protect the United States. All 

photos: NPS.
5FEASIBILITY AND NEED FOR NPS MANAGEMENT
Old road bed, looking west from Honouliuli to University of Hawai‘i parcels. Photo: NPS, 2013.
Chapter 5: Feasibility and the Need for NPS Management  Introduction 91

CHAPTER 5: FEASIBILITY 

AND THE NEED FOR NPS 

MANAGEMENT

This section describes the National Park Service’s 

analysis of whether nationally significant and 

suitable sites are feasible as a unit of the national 

park system and whether direct NPS management 

is clearly superior to other management options.

Introduction

FEASIBILITY

To be feasible as a new unit of the national park 

system, a resource must be (1) of sufficient 

size and appropriate configuration to ensure 

sustainable resource protection and visitor 

enjoyment, taking into account current 

and potential impacts from sources beyond 

proposed park boundaries, and (2) capable of 

efficient administration by the National Park 

Service (NPS) at a reasonable cost. 

In evaluating feasibility, the NPS considers 

a variety of factors for a site(s), such as the 

following:

ŐLand use, current and potential site uses, 

ownership patterns, planning and zoning

ŐAccess and public enjoyment potential

ŐBoundary size and configuration

ŐExisting resource degradation and threats to 

resources

ŐPublic interest and support

ŐSocial and economic impact 

ŐCosts associated with operation, 

acquisition, development, and restoration

The feasibility evaluation also considers 

the ability of the NPS to undertake new 

management responsibilities in light of current 

and projected availability of funding and 

personnel.

An overall evaluation of feasibility is made after 

taking into account all of the above factors. 

These evaluations, however, may sometimes 

identify concerns or conditions, rather than 

simply reaching a yes or no conclusion. For 

example, some sites may be feasible additions 

to the national park system only if landowners 

are willing to sell, or the boundary encompasses 

specific areas necessary for visitor access 

or state or local governments will provide 

appropriate assurances that adjacent land uses 

will remain compatible with the site or sites’ 

resources and values (NPS 2006).

Evaluation of Feasibility Factors

The NPS identified and studied 17 known 

sites that played a role in the history of the 

incarceration and internment of civilians and 

resident aliens in Hawaiʻi during World War 

II. Located throughout the six main islands 

of Hawaiʻi, they include internment camp 

locations, the U.S. Immigration Station in 

Honolulu, small local jails, police stations, and 

military camps. 

This analysis of feasibility focuses on the two 

sites determined to be nationally significant 

and suitable for inclusion in the national 

park system. These sites are the Honouliuli 

Internment Camp and the U.S. Immigration 

Station; both are located on the island of O‘ahu. 

The following evaluation explores the feasibility 

of these sites as potential units of the national 

park system. 

LAND USE, OWNERSHIP PATTERNS, 

PLANNING AND ZONING

Honouliuli Internment Camp 

Honouliuli Internment Camp is located 

approximately 15 miles west of downtown 

Honolulu, west of Kunia Road and north of 

Interstate H-1. The historic site, defined by the 

boundary established by the National Register 

of Historic Places (122.5 acres), is located on 

portions of three separate parcels owned by the 

Monsanto Company, identified as Honolulu 

County tax map keys (TMKs) (1) 9-2-001-

001 (Lots 16851-A and 16851-B) and (1) 9-2-

004-009 (Lot 12007). Parcel (1) 9-2-001-001 

is approximately 1,830 acres. The Monsanto 

Company has recently subdivided 116 acres 

of this parcel (Lot 16851-B), which contains 

most of the historic camp features. Lot 12007 

is 437 acres, nine of which include historic 

camp features. (See Map: Land Ownership–

Honouliuli Internment Camp). 
92 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 
Chapter 5: Feasibility and the Need for NPS Management  Evaluation of Feasibility Factors 93

The Monsanto Company purchased the 

property from the James Campbell Company 

in 2007. James Campbell acquired the land 

in 1877. Prior to 1877, the area was located 

within the ahupua‘a of Honouliuli, one of 

13 traditional land divisions of the Moku of 

ʻEwa. The Honouliuli ahupua‘a includes the 

entire watershed from Honouliuli Gulch into 

Kaihuopala‘ai, the West Loch of Pearl Harbor. 

Human habitation and farming date to as early 

as 400 A.D. (Burton and Farrell 2008).

O‘ahu Sugar Company leased the property 

from James Campbell and the successor James 

Campbell Estate starting in 1889 for use as 

a sugarcane plantation. Because of the steep 

topography along the edges of the Honouliuli 

Gulch, the area was not used for sugarcane or 

pineapple cultivation. The U.S. Army used the 

site for the internment camp from 1943–46. 

Following the war, O‘ahu Sugar Company 

resumed operations until the mid-1990s, when 

irrigable land above the gulch was converted to 

pineapple cultivation under Fresh Del Monte 

Produce Inc. Starting in 1958 and continuing 

until 2001, portions of uncultivated land in 

the gulch were leased for a cattle ranching 

operation (Integral Consulting, Inc. 2013). Since 

2001, most of Honouliuli Gulch has not been 

actively used. 

The City and County of Honolulu Board of 

Water Supply (BWS) owns three small parcels 

within the gulch. The parcels house three 

municipal water supply wells (Honouliuli II-1, 

II-2, and II-3), a concrete control building, 

and water treatment plant. The three separate 

parcels are currently fenced and maintained by 

BWS. Parcels include TMK (1) 9-2-001-008 (0.4 

acres), TMK (1) 9-2-001-009 (0.1 acres), and 

TMK (1) 9-2-001-0010 (0.1 acres). There is a 

recently paved access road entering the gulch 

from the east side across Monsanto property 

to access the BWS sites. BWS also operates two 

water reservoirs adjacent to the southernmost 

corner of the property near the H-1 Freeway 

(Honouliuli 228). BWS holds access easements 

over Monsanto parcel TMK (1) 9-2-001-001. 

The Board of Water Supply parcels within the 

gulch provide underground sources of drinking 

water for the public and require a Declaration 

of Restrictive Covenants limiting the treatment 

and disposal of wastewater within the gulch. 

This covenant would not preclude NPS 

resource management or public enjoyment of 

the site. However, it would limit the types of 

facilities permitted in the historic site.

Large satellite dishes owned by the KITV 

television station are located within a fenced 

enclosure in the southeastern area of the gulch 

on Monsanto parcel TMK (1) 9-2-001-009 

(Integral Consulting, Inc. 2013).

All adjoining properties have historically been 

in ranching or agricultural use. The nearest 

residential development is located east of 

Kunia Road, approximately one mile from 

Honouliuli Gulch. The property adjacent to the 

Monsanto Company to the south and southwest 

is primarily owned by the state of Hawaiʻi as 

part of the new campus of the University of 

Hawaiʻi—West O‘ahu (UHWO). These parcels 

include TMK (1) 9-2-002-003 (38 acres), (1) 

9-2-002-005 (12 acres), and (1) 9-2-002-007 

(860 acres). Currently zoned for agricultural 

uses, UHWO has identified these parcels for 

either university or non-university related 

Photos (top to bottom): 1. City and County of Honolulu Board 

of Water Supply water treatment plant, Honouliuli. 2. City and 

County of Honolulu Board of Water Supply well, Honouliuli. 

Photos: NPS, 2013.
94 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Photos (clockwise from top left): 1. Overlook site (Monsanto 

Parcel 3), Honuliuli. Photo: NPS, 2013. 2. Western access road 

traveling north, Honouliuli. Photo: NPS, 2013. 3. Aerial view of 

Honouliuli Gulch looking south, showing both Monsanto lands 

(left) and University of Hawai‘i–West O‘ahu lands (right) and 

Board of Water Supply facilities in the foreground. Pearl Harbor 

is visible in the upper left. Photo: Monsanto Company. 4. KITV 

satellite dishes visible from access road, Honouliuli. Photo: NPS, 

2011. 
Chapter 5: Feasibility and the Need for NPS Management  Evaluation of Feasibility Factors 95

development. The University of Hawaiʻi is 

currently working on a strategic land use plan 

that will determine the future use of its parcels 

adjacent to Honouliuli Internment Camp. 

Nestled between parcels 9-2-002-003 and 

9-2-002-005 is a separate 7-acre parcel owned 

by the Monsanto Company, TMK (1) 9-2-002-

004. This 7-acre parcel (also referred to as the 

“overlook site”) is relatively level and offers 

expansive views of Pearl Harbor, downtown 

Honolulu, and Diamond Head. Previously used 

for agricultural purposes, it is currently fallow.

Western access to the Honouliuli Internment 

Camp is through the UHWO parcels. The 

Monsanto Company parcels have a terminable 

right of entry over existing dirt roads that 

traverse UHWO lands, providing southern and 

western access routes to the site. The Monsanto 

Company also has a non-exclusive easement for 

ingress and egress over 9-2-002-007 (Easement 

6134). A separate easement (Easement 51) 

across UHWO parcel (1) 9-2-002-007 provides 

access to the H-1 Freeway via Kapolei NorthSouth Road.

In light of the interest in a potential unit of the 

national park system, the Monsanto Company 

has subdivided TMK (1) 9-2-001-001 and 

TMK (1) 9-2-001-009 to create three separate 

conservation easements that it could potentially 

transfer to the NPS. The Monsanto Company 

also created a new standalone fee parcel (Lot 

15861-B, 116 acres) over the historic site to 

transfer for conservation purposes. (See Map: 

Land Ownership–Honouliuli Internment 

Camp). The Monsanto Company has also 

expressed a desire to transfer title to the 7-acre 

overlook site (Lot 12011) to the National Park 

Service.

ZONING

State land use law (Chapter 205, Hawaiʻi 

Revised Statutes) establishes an overall 

framework of land use management whereby all 

lands in the state of Hawaiʻi are classified into 

one of four districts. The Monsanto Company 

and UHWO parcels are zoned for agricultural 

use, for which parks, community facilities, 

and sites of historical interest are considered 

permissible uses as specified in Chapter 205 

of Hawaiʻi Revised Statutes (§205-4.5 (a)(6)

(8)). City and County of Honolulu local zoning 

allows for public uses and structures in zone 

AG-1 (Revised Ordinances of Honolulu 1990). 

The recently adopted ‘Ewa Development Plan, 

the City and County of Honolulu’s long-range 

land use and infrastructure plan for the ‘Ewa 

region, identifies Honouliuli Internment Camp 

as one of ‘Ewa’s significant historic features 

and landmarks and calls for its protection and 

preservation (See Maps: Zoning—Honouliuli 

Internment Camp, State Land Use Districts, and 

‘Ewa Development Plan, Urban Land Use Map). 

Establishment of a national park unit that 

would include Honouliuli Internment Camp is 

consistent with state and local land use policies 

and guidance including, The Hawai‘i State 

Plan, the City and County of Honolulu General 

Plan and Revised Ordinances of 1990, and the 

‘Ewa Development Plan (Hawai‘i Department 

of Planning and Economic Development 1986, 

City and County of Honolulu 2002 and 2013).

U.S. Immigration Station

LAND USE AND OWNERSHIP

The U.S. Immigration Station complex at 595 

Ala Moana Boulevard is located in downtown 

Honolulu adjacent to Honolulu Harbor. As 

described in Chapter 3: Resource Significance, 

the U.S. Immigration Station was listed in the 

National Register of Historic Places in 1978. 

The U.S. Immigration Station Complex site is 

4.5 acres located on two separate parcels. The 

larger parcel (TMK 2-1-015-018) contains all 

but one of the four buildings associated with 

the complex and is currently occupied by 

the U.S. Department of Homeland Security’s 

Immigration and Customs Enforcement. The 

smaller parcel (TMK 2-1-015-019) is owned by 

the Hawai‘i Community Development Authority 

(See Map: Land Ownership–U.S. Immigration 

Station).

Three of the four buildings associated with the 

complex—the former administration building, 

lounging shed, and garage/waiting shed—are 

currently used by Department of Homeland 

Security for general office functions. These 

structures are not open to the general public. 

The fourth structure, the former Detention 

Building, was at one point determined surplus 

by the federal government and subsequently 

transferred to the Hawai‘i Community 

Development Corporation. This two-story 

building is currently occupied by the Hawaiʻi 

State Department of Health. 
96 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 
Chapter 5: Feasibility and the Need for NPS Management  Evaluation of Feasibility Factors 97
98 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 
Chapter 5: Feasibility and the Need for NPS Management  Evaluation of Feasibility Factors 99
100 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

ZONING

The U.S. Immigration Station parcels are 

located within an urban district under state 

land use law. Urban districts are typically 

regulated by county ordinances. The U.S. 

Immigration Station is within the City and 

County of Honolulu’s public use precinct 

of the Kakaako Special Design District. The 

intent of the Kakaako Special Design District 

is to guide growth towards a mix of residential, 

commercial, and industrial uses and to ensure 

that the area includes public and private 

developments that are sensitive to the physical 

environment and will encourage diversification. 

The purpose of the district’s public use precinct 

is to set aside lands to meet public requirements 

and the recreation and open space needs of the 

district. Public uses and structures are permitted 

(Honolulu Revised Ordinances, Section 21-

F.4 (e)). Surrounding land use is primarily 

commercial, public, and industrial (port) (see 

Map: Zoning–U.S. Immigration Station).

Conclusion—Land Use, Ownership 

Patterns, Planning and Zoning

Current land use, ownership patterns, and 

zoning associated with Honouliuli Internment 

Camp would not conflict with management of a 

national park unit. Primary resources associated 

with the camp are located on property owned 

by the Monsanto Company. Monsanto has 

expressed its interest in donating portions of 

the property to the NPS for establishment of a 

national park unit (Lot 16851-B and Lot 12011). 

Surrounding lands are currently in agricultural 

use which is compatible with the camp’s historic 

setting. Current land use, ownership, and 

zoning would be compatible with direct NPS 

management and ownership of the Honouliuli 

Internment Camp as a national park unit.

Existing use of the U.S. Immigration Station 

by the U.S. Department of Homeland Security 

and Hawai‘i State Department of Health would 

not be compatible with use as a national park 

unit. However, if the U.S. Immigration Station 

facilities were no longer needed by the U.S. 

Department of Homeland Security or the 

Hawai‘i State Department of Health, additional 

NPS analysis would be needed to determine 

the feasibility of management options and 

associated costs. Given the size and scale 

of the facilities, costs for maintenance and 

preservation of the historic structures would be 

a primary consideration.The U.S. Immigration 

Urban Land Use Map from the Ewa Development Plan (City and County of Honolulu, 2013).
Chapter 5: Feasibility and the Need for NPS Management  Evaluation of Feasibility Factors 101
102 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Station complex would not be feasible for direct 

NPS management and ownership as part of a 

national park unit at this time. 

ACCESS AND PUBLIC ENJOYMENT 

POTENTIAL

Honouliuli Internment Camp

ACCESS

Honouliuli Gulch is within a 30-minute drive 

of Honolulu and the major tourist areas of 

Waikiki, Ko‘Olina, and Pearl Harbor. Although 

existing transit systems do not currently provide 

stops near the site, the planned Hawaiʻi Rail 

Transit (HRT) system will provide rail passenger 

services to two nearby stops at University of 

Hawai‘i—West O‘ahu and Ho‘opili (See Map: 

Access and Circulation–Honouliuli Internment 

Camp).

Honouliuli Internment Camp is currently 

located on private land that is inaccessible 

to the public. There is no dedicated parking 

area onsite, and vehicular access is via narrow 

unpaved and paved roads. Monsanto employees 

and other agencies and private organizations 

with interests and activities in the vicinity of 

Honouliuli Internment Camp access the site 

through privately maintained roads that are 

secured by locked gates. Most of the existing 

access routes are agricultural roads which have 

steep grades and unstable surfaces, and some 

areas are overgrown with vegetation (United 

States Department of Transportation 2013). 

There are two main access points to reach 

Honouliuli Internment Camp. The first access 

route is from the east via Kunia Road along a 

recently paved road through the Monsanto 

Company offices and agricultural fields. The 

paved road extends north to the Board of Water 

Supply parcels within the gulch. Along this 

road at an intersection west of the satellite dish 

site, an older overgrown dirt road heads south 

along the gulch to a former dumping site. Public 

access on the Monsanto Company property 

east of the gulch would not be compatible with 

Monsanto employees’ use of these roads for 

agricultural research activities. 

The second access point is from the west via 

the H-1 Freeway at Kapolei North-South Road. 

From this point the historic site can be accessed 

across UHWO-owned parcels on unpaved 

agricultural roads that are controlled by 

multiple locked gates. The western access route 

traverses the 7-acre overlook site, a relatively 

flat parcel that could function as a staging area 

with parking, drop-off areas, and trail access 

Paved eastern access road and gate, Honouliuli. Photo: NPS, 2011.
Chapter 5: Feasibility and the Need for NPS Management  Evaluation of Feasibility Factors 103

into Honouliuli Gulch. This route would appear 

to be the most feasible route for public use 

of the site, assuming rights of access can be 

obtained. Existing roads have a steep surface, 

uneven grade, and overgrown vegetation and 

would require varied amounts of resurfacing, 

restoration, rehabilitation, and in some cases 

may require realignment. The roads would thus 

require considerable improvement to meet NPS 

standards for a Class II Connector Park Road. 

A Class II Connector Park Road is one that 

provides access within a park to areas of scenic, 

scientific, recreation or cultural interest such 

as overlooks, campgrounds, etc. (United States 

Department of Transportation 2013). 

The site is also accessible from the west 

via an undeveloped appurtenant easement 

(“Easement 6134”). Presently, UHWO and 

Monsanto use the existing agricultural roads to 

access land along the west side of the gulch. In 

the event a park unit was designated and NPS 

were to acquire an interest in the gulch site prior 

to development of Easement 6134, NPS would 

need to obtain a right to use existing roads 

on UHWO land. NPS would need to ensure 

use of the existing roads until such time as the 

easement was adequately developed for public 

access. 

Administrative access could be feasible from 

the southern end of the gulch along a road that 

runs north-south from the H-1 Freeway area. 

There is no legal access to the highway from this 

north-south road. Therefore, the road would 

still need to be accessed via UHWO parcels and 

access roads from the west. 

In summary, current access to Honouliuli 

Internment Camp is through private, 

undeveloped agricultural roads. Access from 

the west over UHWO lands is the most feasible 

route for providing long-term public access 

to the historic site. Rights of access from 

UHWO would be necessary to secure public 

access to the historic site. Considerable road 

improvements would also be required to 

provide for public access. 

PUBLIC ENJOYMENT POTENTIAL

As described in the suitability section, 

Honouliuli Internment Camp provides excellent 

opportunities to convey the story of World War 

II incarceration and internment in Hawaiʻi. 

The experience in Hawai‘i is markedly different 

from mainland incarceration sites. Protection of 

Honouliuli Internment Camp as a national park 

site would also expand and enhance interpretive 

opportunities for visitors to World War II Valor 

in the Pacific National Monument at Pearl 

Harbor which interprets the Japanese attack on 

O‘ahu on December 7, 1941 and the broader 

Pacific War story. Public visitation to Honouliuli 

Internment Camp could be accommodated with 

site improvements to provide vehicle access, 

parking, trails, and interpretative features where 

appropriate. 

Photos (top to bottom):1. Honouliuli Day of Remembrance, 

2011. 2. Bus stop outside the U.S. Immigration Station, 2013. 

Photos: NPS.
104 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 
Chapter 5: Feasibility and the Need for NPS Management  Evaluation of Feasibility Factors 105

Within the historic site, visitors can experience 

the physical confinement afforded by the 

topography of Honouliuli Gulch. Although 

expansive views to Honolulu and Diamond 

Head exist just outside of the historic site at the 

top of the gulch, internees and prisoners had no 

visual access to areas beyond.

Contemporary uses of the historic site such as 

the communications facilities and the Board of 

Water Supply wells and treatment plant would 

not detract from the overall visitor experience. 

From most areas within the historic camp area, 

these features are obscured by dense vegetation.

Visitor facilities within the historic site would be 

limited to protect the integrity of the resources. 

Restrictive covenants that prevent the treatment 

and disposal of wastewater within the gulch, 

given current use of the site for municipal water 

supply, also limit site development. Appropriate 

facilities within the gulch could include 

primitive access roads, trails, waysides, or vault 

toilets, to the extent that such features are sited 

in a way that would not affect the integrity of the 

historic site. 

Although most of the site is overgrown with 

vegetation, the Japanese Cultural Center 

of Hawaiʻi (JCCH) has been taking care of 

the vegetation cutting to provide access for 

occasional guided tours in a small area of the 

site. Additional clearance would be necessary 

to provide access and public enjoyment 

opportunities to other areas of the historic site. 

The 7-acre overlook site, located just west of the 

historic site at the top of the gulch, provides a 

suitable location for primary visitor access and 

facilities. The overlook site is relatively level, 

affording opportunities for parking and dropoff areas, visitor contact facilities, interpretive 

features, and restrooms. The historic site can be 

accessed from here via a historic road alignment 

that is visible in aerial photos of the Honouliuli 

Internment Camp during World War II. The 

overlook site also features expansive views 

encompassing surrounding agricultural lands, 

Pearl Harbor, and Honolulu, which provide 

greater context and setting for interpreting 

the World War II internment in Hawaiʻi. The 

Monsanto Company has offered to donate this 

parcel to the NPS, in addition to areas included 

in the National Register of Historic Places 

boundary.

Partnership opportunities with organizations 

such as JCCH and UHWO could further 

enhance public enjoyment opportunities. 

JCCH and UHWO have an interest in the site 

for research, education, and for remembrance 

and commemoration. The JCCH provides a 

variety of public education and interpretation 

programs about Honouliuli, including staffing 

occasional tours of the site and holding an 

annual day of remembrance at Honouliuli 

Internment Camp. 

U.S. Immigration Station

ACCESS

Located on Ala Moana Boulevard, a main 

thoroughfare in downtown Honolulu, the U.S. 

Immigration Station site is currently accessible 

via car and transit and is in walking distance 

to areas in downtown Honolulu. Honolulu’s 

Department of Transportation Services (lines 

8 and 20) stop directly in front of the complex. 

However, current use of the building by the 

U.S. Department of Homeland Security and the 

Hawai‘i State Department of Health does not 

allow for general public access (See Map: Access 

and Circulation–U.S. Immigration Station).

PUBLIC ENJOYMENT POTENTIAL

Given current uses of the U.S. Immigration 

Station, direct public access to the area is not 

currently feasible. 

Conclusion—Access and Public 

Enjoyment Potential

Public access from the west to Honouliuli 

Internment Camp would be feasible if 

permanent rights of access could be obtained 

over adjacent lands and with considerable 

road improvements. Additional improvements 

at the 7-acre site above the gulch for parking, 

trails and walkways, and interpretative 

features would enhance the feasibility of park 

operations. Without these lands, given the 

limited development that could occur in the 

historic site, visitor staging facilities would likely 

be located at a more remote location. Trails, 

walkways, and interpretive features within the 

gulch would also be required to facilitate public 

enjoyment opportunities on the site. 

At the present time, public access to the U.S. 

Immigration Station buildings is not feasible. 

Additional analysis of public enjoyment 
106 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

potential would be warranted if the facilities 

were no longer needed by federal and state 

agencies.

BOUNDARY SIZE AND CONFIGURATION

An acceptable boundary for an envisioned 

unit of the national park system takes into 

consideration:

Őinclusion and protection of the primary 

resources; 

Ősufficient surrounding area to provide a 

proper setting for the resources or to interrelate a group of resources; and 

Ősufficient land for appropriate use and 

development. 

Honouliuli Internment Camp 

A suitable national park unit boundary for 

Honouliuli Internment Camp would include the 

area within the national register boundary and 

parcels west of the national register boundary 

to provide for site access and facilities to 

accommodate visitor use. 

The 122.5-acre area in the National Register 

of Historic Places boundary for Honouliuli 

Internment Camp (national register boundary) 

contains over 130 features related to the 

internment and incarceration of American 

civilians, resident aliens, and prisoners of 

war during World War II. Remaining features 

include scattered artifacts and remnants of 

structures such as building foundations, guard 

towers, aqueducts, walkways, and roads (Burton 

and Farrell 2011). 

The 122.5-acre historic site is currently 

bounded on four sides by the steep slopes of 

Honouliuli Gulch. Outside of the gulch the area 

is surrounded by agricultural lands, which are 

consistent with the surrounding land use during 

the site’s period of significance (Burton and 

Farrell 2011). 

In addition to the lands within the national 

register boundary, a suitable boundary would 

include the 7-acre overlook site to the west, 

currently owned by Monsanto, and 22.5 acres 

of land owned by Monsanto surrounding 

the drainage to the south of the national 

register boundary. These lands may contain 

archeological artifacts related to the internment 

camp.

Aerial view of the U.S. Immigration Station, 2013. A cruise ship dock is on the upper left, and downtown Honolulu is to the right. Base 

photo: Google Earth imagery. 
Chapter 5: Feasibility and the Need for NPS Management  Evaluation of Feasibility Factors 107

Portions of the large UHWO parcel west of the 

overlook site could also be included to provide 

for public access. These parcels are agricultural 

lands either actively farmed or fallow. The 

University of Hawaiʻi is currently completing 

a land use plan for its lands west of Honouliuli 

Internment Camp. If the university were to 

identify new road alignments as part of that 

planning process, which could be used to access 

Honouliuli Internment Camp, then a small 

boundary adjustment for this alignment could 

be considered to allow NPS to expend funds 

on road maintenance. The NPS would not need 

to directly own or manage UHWO lands to 

achieve these purposes.

U.S. Immigration Station

The 4.6-acre site boundary in the U.S. 

Immigration Station National Register of 

Historic Places designation consists of four 

main buildings located around an inner 

courtyard. Each of the four structures identified 

in the national register nomination remain 

on site, in their original locations, and the 

structures and grounds maintain their historic 

integrity. 

A boundary that would include, at a minimum, 

the federally owned parcel of U.S. Immigration 

Station complex would be sufficient to protect 

the significance of the buildings and their 

setting as they relate to the incarceration of 

civilians and resident aliens during World War 

II and would allow for appropriate use and 

development of the site as a national park unit. 

However, this property is not currently available 

to NPS.

Conclusion—Boundary Size and 

Configuration

Honouliuli Internment Camp and the U.S. 

Immigration Station sites each provide for 

the inclusion and protection of the primary 

resources, in this case, nationally significant 

resources associated with the incarceration 

and internment of civilians, alien residents, and 

prisoners of war in Hawaiʻi during World War 

II. Both sites include sufficient surrounding area 

to provide a proper setting for the resources. 

For Honouliuli Internment Camp, there is 

sufficient land available for appropriate use and 

development of the site . The U.S. Immigration 

Station is located in a highly developed area 

adjacent to an active port and a mix of other 

commercial uses. Its location, structures, and 

site arrangement would allow for protection of 

resources and appropriate public use of the site.

EXISTING RESOURCE DEGRADATION 

AND THREATS TO RESOURCES

The two nationally significant sites and 

resources are generally of high quality and 

have a high degree of integrity. Nevertheless, 

development plans and underutilization may 

pose a threat to some of these resources.

Honouliuli Internment Camp

An environmental site assessment was 

conducted for the historic site of the Honouliuli 

Internment Camp in May 2013 to identify 

“recognized environmental conditions.” 

“Recognized environmental conditions” 

include the presence of hazardous substances 

or petroleum products on the property from 

the property itself and from surrounding lands. 

No recognized environmental conditions 

were identified for the property. Pesticide and 

herbicide compounds remaining from former 

sugar cane and pineapple cultivation and 

potential Monsanto agricultural operations 

were found to be below regulatory levels. 

Although two World War II-era incinerator 

remnants were documented in archeological 

surveys, the environmental site assessment 

found no evidence of environmental impacts 

associated with metals and organic compounds 

typically associated with incinerator ash 

(Integral Solutions, Inc. 2013).

The remains of the foundations and other 

features at Honouliuli Gulch face threats from 

erosion and other sources of deterioration. 

Although no major actions are proposed for 

the property, current uses of the site have the 

potential for ground disturbance and potential 

impacts to archeological resources. 

The area surrounding Honouliuli Gulch is one 

of the fastest growing areas on O‘ahu. However, 

surrounding areas are primarily zoned for 

agricultural use. Agricultural zoning does allow 

for development of structures for agricultural, 

educational, or recreational purposes. Future 

development of such facilities on surrounding 

lands would likely have a minimal impact on 

the visitor experience within the historic site as 

the steep sides of the gulch and dense visitation 

greatly limit views to the surrounding landscape. 
108 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Development could also be sited away from 

Honoululi Gulch to minimize impacts on park 

operations, visitor access, and experience.

U.S. Immigration Station

At the U.S. Immigration Station, most of the 

remaining historic structures are located on 

federal property, and therefore must comply 

with preservation standards as required by the 

National Historic Preservation Act, Section 106 

and 110 requirements. Section 106 requires 

federal agencies to take into account the effects 

of their undertakings on historic properties. 

It should be noted that the NPS study team was 

only able to conduct a brief visual inspection 

of the U.S. Immigration Station for purposes 

of this special resource study. During this visit, 

facilities appeared to be in good condition with 

a high level of historic integrity. Although some 

modifications have been made to the building to 

accommodate current uses, such modifications 

are reversible and the overall integrity of the site 

and structures is high. If ownership and public 

access to the structures were to become feasible 

in the future, further analysis and evaluation 

of the facility conditions would be necessary 

to determine whether there are threats or 

resource degradation that would preclude NPS 

management of the site.

Conclusion—Existing Threats and 

Resource Degradation

There are no current threats to Honouliuli 

Internment Camp that would preclude 

management of the site as a unit of the national 

park system. Honouliuli Internment Camp 

contains resources with integrity sufficient for 

national historic landmark designation and NPS 

designation.

The U.S. Immigration Station is currently owned 

and maintained by federal and state agencies. 

While historic integrity appears high, additional 

analysis would be needed to evaluate potential 

threats or resource degradation that would 

preclude NPS management.

PUBLIC INTEREST AND SUPPORT

Public involvement efforts conducted in 2011 

identified strong public support for the idea 

of establishing of a unit of the national park 

system that would preserve and interpret 

resources associated with the incarceration of 

Japanese Americans and European Americans 

Remaining structures, Honouliuli Internment Camp. Photo: NPS, 2010.
Chapter 5: Feasibility and the Need for NPS Management  Evaluation of Feasibility Factors 109

in Hawaiʻi during World War II. Most 

public comments conveyed a desire for NPS 

management and for preservation of the sites 

and interpretation of the history, particularly 

at the Honouliuli Internment Camp. This 

would include developing key partnerships 

necessary to preserve the sites and leverage 

funding, interpreting the broader story through 

educational programs and designating a 

national park unit.

While commenters as a whole supported 

recognition of sites significant to the World 

War II internment in Hawai‘i , some expressed 

concern as to whether such recognition would 

have any adverse effects on local sites and 

communities. More detailed information about 

public scoping comments is included in Chapter 

8: Consultation and Coordination. 

Local organizations and institutions have been 

active in documentation, preservation, and 

interpretation efforts for Honouliuli Internment 

Camp. The JCCH conducted research that 

uncovered the location of historic site which 

was found as recently as 2002. The JCCH is also 

the largest repository of archives and collection 

items related to Honouliuli and the internment 

history in Hawai‘i. UHWO faculty are actively 

researching the history of Honouliuli. UHWO 

also participates with the Monsanto Company 

and JCCH on summer archeology field school 

programs at Honouliuli Internment Camp.

The state of Hawaiʻi has been supportive of 

efforts to preserve and interpret Honouliuli 

Internment Camp. The Hawaiʻi legislature 

commissioned a group, called the Honouliuli 

Park Site Advisory Committee, to support 

preservation of the Honouliuli site. The 

committee is directed to: 1) provide state 

support toward preservation of the Honouliuli 

site; 2) establish a mechanism to leverage 

county, state, federal, and private funding for 

an educational resource center at the site; and 

3) memorialize the struggle for civil rights by 

Hawaiʻi’s people.

Conclusion—Public Interest and 

Support

Outreach for this study has demonstrated 

significant public interest and support for 

an NPS park unit at Honouliuli Gulch in 

partnership with other organizations and local 

communities.

Photos (top to bottom):1. Flag marking the Japanese Cultural 

Center of Hawai‘i interpretive tour route, Honouliuli, 2013. 2.

Honouliuli Day of Remembrance, 2011. 3. Remnants of stone 

steps in the guard camp compound, Honouliuli. All photos: NPS.
110 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

SOCIAL AND ECONOMIC IMPACT

O‘ahu/Honolulu County Socioeconomic 

Setting

POPULATION

O‘ahu is the most populous island of Hawaiʻi, 

with over 970,000 residents, almost 70% of the 

state’s population. Racial and ethnic diversity 

on O‘ahu is high. Approximately 43% identify 

themselves as Asian; while most others identify 

themselves as white (22%) or Native Hawaiian 

(10%). Over 20% identify themselves as 

representing two or more races (U.S. Census 

Bureau 2013). 

EMPLOYMENT AND INCOME

The median household income in Honolulu 

County is approximately $71,263 per year. 

Over 9% of the population lives in a household 

with income below the federally-determined 

poverty threshold (U.S. Census 2012). Almost 

5% percent of the county’s labor force was 

unemployed in June 2013 (U.S. Department of 

Labor: Bureau of Labor Statistics 2013). 

TOURISM

Tourism in Hawaiʻi is an $11 billion dollar 

industry, representing one-third of Hawaiʻi’s 

Gross State Product. O‘ahu is the state’s primary 

economic and tourism center, with Honolulu 

and Waikiki being the primary destination, with 

over four million annual visitors. The island 

had over 34,000 visitor units in 2009, including 

hotels, condominium hotels, timeshares, bed 

and breakfast, and individual vacation units. 

An estimated 81,000 visitors are on O‘ahu on 

any given day. Demand for eco, cultural and 

historical tourism, in particular, continues to 

increase (Helber Hastert and Fee Planners, Inc. 

2010). Additional context on the socioeconomic 

environment of West O‘ahu is included in 

Chapter 7: Environmental Consequences.

Potential Impacts

Social and economic impacts of NPS 

designation could vary depending on the 

size and scope of the park unit, management 

approach and external variables such as local, 

regional and national economic forces, and 

actions of local public and private organizations 

and individuals.

Recognition or designation of a national park 

unit would likely have beneficial economic 

and social impacts on the area. Possible 

socioeconomic beneficial effects could include: 

expenditures from park operations and park 

staff, expenditures by visitors at local businesses, 

sales and hotel tax revenues from visitor 

expenditures, and growth in visitor-related 

businesses such as tourism. Additional analysis 

of social and economic impacts is provided in 

Chapter 7: Environmental Consequences.

Conclusion—Social and Economic 

Impact

The social and economic impacts of NPS 

designation or other support/coordination 

role appear to be largely beneficial and would 

support the feasibility of NPS designation.

COSTS ASSOCIATED WITH OPERATION, 

ACQUISITION, DEVELOPMENT, AND 

RESTORATION

Costs associated with a national park unit 

include annual operations costs and periodic 

costs of land acquisition, development of 

facilities, and resource restoration. Because the 

U.S. Immigration Station would not be feasible 

for direct public access and NPS management, 

costs are only analyzed for Honouliuli 

Internment Camp.

Land Acquisition Costs

The Monsanto Company has expressed 

the intent to donate lands associated with 

Honouliuli Internment Camp and the 

7-acre overlook site to the National Park 

Service, should such a unit be established. 

The Monsanto Company has subdivided 

the land associated with the historic site into 

transferable interests at its own expense. No 

land acquisition costs are anticipated other 

than the administrative costs associated with 

land acquisition due diligence (title review, 

environmental compliance, etc.). 

Development and Restoration Costs

Development costs of new national park units 

vary widely, depending on existing and desired 

conditions and facilities. New national park 

units frequently inventory and document the 

resources in the park; develop management or 

treatment plans for those resources; and plan 

for the desired visitor use, resource protection 
Chapter 5: Feasibility and the Need for NPS Management  Evaluation of Feasibility Factors 111

objectives, and facilities to support visitors 

and park operations. It is difficult to provide 

detailed cost estimates for facilities prior to 

specific site planning that would occur following 

designation. However, since expenditures 

on site access would be necessary under any 

scenario, broad estimates for such costs are 

included in this section.

Assets that the NPS would manage include 

over 130 features related to the incarceration 

of American civilians, resident aliens, and 

prisoners of war during World War II. These 

features include two standing buildings, 

numerous building foundations, rock walls, 

fence remnants, artifact scatters, and other 

features. There are a several non-contributing 

features at the site, primarily from previous 

ranching and other agricultural uses. This 

includes corrals, a loading chute, remnants 

of a chicken farm, a road, and a rock wall. 

Board of Water Supply parcels and associated 

facilities would remain as inholdings and would 

continue to be managed by the City and County 

of Honolulu for municipal water supply. The 

communications site would not be included in 

the land available for donation to the NPS.

There may be opportunities for sharing facilities 

with partner organizations such as UHWO and 

JCCH for public access, visitor interpretation, 

museum collections, and storage. Specific visitor 

and operational facilities would be determined 

through future management planning for the 

national historic site or monument. 

VISITOR AND ADMINISTRATIVE ACCESS

The primary development costs for operation 

of a national park unit at Honouliuli Gulch 

would be for visitor and administrative access. 

The Federal Highway Administration (FHA) 

analyzed several scenarios for public access to 

Honouliuli Internment Camp across UHWO 

parcels using existing road alignments. The 

study also analyzed administrative access to the 

gulch from the south along existing agricultural 

roads. The administrative access evaluated 

would enter the site near the H-1 Freeway and 

provide access to the middle of the historic site. 

Because evaluation was cursory without 

the benefit of a full survey of existing roads, 

the FHA and NPS study team was unable 

to determine how much reconstruction 

and realignment of existing roads would 

be necessary. Estimates were provided for 

both 3R work (resurfacing, restoration, and 

rehabilitation) and 4R (resurfacing, restoration, 

rehabilitation, and reconstruction, or 

realignment). Reconstruction and realignment 

adds considerably to the cost for road 

improvements. The costs analyzed are based on 

standards for an NPS Class II Park Connector 

Road for public access from the west and an 

NPS Administrative Road Standard for the road 

from the south.

The analysis made several assumptions 

about public access: 1) easements would 

allow access to the site, 2) public access 

would be controlled via a gate, 3) the public 

access road would be paved, and 4) parking 

would be provided for less than 20 vehicles 

including bus stalls and turn around areas 

at the overlook site (Monsanto Parcel 3). 

Estimated costs range from $3 to $20 million 

for construction. The higher end of the range 

would be incurred if additional reconstruction 

or realignment is necessary for a portion of 

the road improvements (U.S. Department of 

Transportation 2013). 

TRANSIT SCENARIOS

The Federal Highway Administration also 

evaluated potential costs for transit options to 

Honouliuli Gulch originating from World War II 

Valor in the Pacific National Monument at Pearl 

Harbor (VALR) and UHWO. Costs to operate 

a bus connection from VALR three times 

per week was estimated at $25,000 to 30,000 

annually. A second scenario evaluated transit 

service between UHWO and Honouliuli Gulch. 

It was assumed that the close proximity to the 

campus and the future light rail stop planned 

for that location could increase demand to visit 

the site. The total cost for this scenario was 

estimated at $91,000 to $112,000 annually.

VEGETATION REMOVAL

With the exception of the Board of Water 

Supply facilities and the KITV satellite dish 

site, Honouliuli Gulch has not been actively 

used for over ten years. Thus thick vegetation, 

primarily nonnative, invasive species such as 

Guinea grass (Panicum maximum), haole koa 

(Leucaema sp.), and Chinese banyan trees (Ficus 

microcarpa) have populated the site, obscuring 

roads and historic features and inhibiting 

access. Significant vegetation clearance would 
112 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

be necessary to make the site accessible for 

visitation. Further evaluation of the site as a 

cultural landscape would inform appropriate 

measures for vegetation clearance in keeping 

with the site’s historic setting. 

Operational Costs

Operational costs of national park units 

vary widely, depending on site management, 

partnership opportunities, the amount and 

type of resources managed, number of visitors, 

level of programs offered, and many other 

factors. Given the close proximity of Honouliuli 

Internment Camp to existing NPS operations 

at World War II Valor in the Pacific at Pearl 

Harbor, some park operations could be shared 

with and supported by this existing park unit.

This section provides comparative budget 

figures for the operational costs of national 

park units that would be similar to those at 

Honouliuli Internment Camp. Comparable 

examples include national historic sites which 

share administration and resources with other 

nearby national park units. These examples 

include: 1) Minidoka National Historic Site 

located near Twin Falls, Idaho, 2) Eugene 

O’Neill National Historic Site in Danville, 

California, and 3) Muir Woods National 

Monument in Marin County, California. 

Manzanar National Historic Site is also 

provided for comparison, as a national park 

unit that interprets incarceration history during 

World War II. 

Minidoka National Historic Site, established 

in 2001, preserves the features and history of 

the former Minidoka Relocation Center, which 

held 13,000 Nikkei from Washington, Oregon, 

California, and Alaska during World War II. 

Administration and operations for Minidoka 

are currently based out of the Hagerman Fossil 

Beds National Monument headquarters, located 

40 miles from the Minidoka site in Hagerman, 

ID. Hagerman Fossil Beds provides support 

to Minidoka for administration, operations, 

and planning efforts. The second comparable 

unit is Eugene O’Neill National Historic site 

in Danville, CA, which was established as a 

memorial to Nobel Prize-winning playwright 

Eugene O’Neill and a park for the performing 

arts and related education programs. Eugene 

O’Neill NHS shares administrative staff and 

resources with three other park units located 

in the East San Francisco Bay Area. These 

parks include Rosie the Riveter World War 

II Homefront National Historical Park, Port 

Chicago Naval Magazine National Memorial, 

and John Muir National Historic Site. Similarly, 

Muir Woods National Monument, established 

in 1908 to protect an uncut stand of oldgrowth redwood, receives operational and 

administrative support from the Golden Gate 

National Recreation Area, headquartered in San 

Francisco, CA.

Operational and visitation information for 

World War II Valor in the Pacific National 

Monument, Pearl Harbor is also provided 

because this national park unit would likely 

support operations at Honouliuli. It is also likely 

that some percentage of visitors to Pearl Harbor 

would also visit Honouliuli, which is currently 

interpreted through exhibits on display at the 

national monument.

Visitation numbers are also provided for 

comparison purposes. It should be noted that 

visitation at Minidoka National Historic Site 

is much lower than visitation at Manzanar 

National Historic Site, an internment camp in 

southern California. This is primarily because 

Minidoka National Historic Site is still in the 

process of developing facilities to accommodate 

visitors on site. 

Staffing requirements for the Honouliuli 

National Historic Site or National Monument 

would depend upon the configuration of 

the site. Staffing approaches are described in 

Chapter 6: Alternatives. Based on evaluation of 

comparable park units, the annual operating 

base budget for the NPS could ranges from 

$450,000 to $750,000. More specific operational 

costs would be identified through completion of 

a management plan for the site.
Chapter 5: Feasibility and the Need for NPS Management  Feasibility Conclusion 113

Table 5-1: Operating Budgets for Comparable and Related National Park Units (FY 2012)

National Park Unit

FTE (Full Time 

Equivalent) 

Staff

Acres Annual 

Visitation

FY2012 

NPS Annual 

Operating 

Budget

Muir Woods National Monument 13 554 972,300 $446,000

Eugene O’Neill 8 13 2,800 $687,000

Minidoka National Historic Site 3 201 4,060* $438,000

Manzanar National Historic Site 16 814 72,831 $1,309,000

World War II Valor in the Pacific 

National Monument, Pearl Harbor

30 59 1,751,200 $3,529,00

Source: (NPS 2013)

* Data is from 2010, updated information is pending

Conclusion—Costs 

With support from World War II Valor in 

the Pacific National Monument at Pearl 

Harbor, operational costs for establishing a 

national park unit appear to be feasible. Land 

acquisition costs would be minimal and limited 

to the administrative costs associated with a 

land transfer to the NPS. Cost would also be 

incurred from developing the infrastructure 

necessary to support public access to the site.

Feasibility Conclusion

This study finds that Honouliuli Internment 

Camp is feasible as an addition to the national 

park system conditional upon securing public 

access to the site. Current land use, ownership 

patterns, and zoning associated with the 

Honouliuli Internment Camp are compatible 

with management of a national park unit. 

Primary resources associated with the historic 

site are located on property owned by the 

Monsanto Company, which has expressed 

interest in donating the property to the NPS. 

There are exceptional opportunities for public 

enjoyment of the site provided that public 

access can be secured from neighboring 

landowners. An appropriate boundary 

configuration would include the historic camp 

area and would allow for access and visitor 

facilities such as parking. Costs for establishing 

a national park unit at Honouliuli Gulch are 

feasible provided that the national park unit 

would be supported with operational capacity 

at World War II Valor in the Pacific National 

Monument, Pearl Harbor.

The U.S. Immigration Station complex is 

not feasible as a national park unit because 

of existing uses by the U.S. Department of 

Homeland Security and the Hawai‘i State 

Department of Health. However, if the U.S. 

Immigration Station facilities were no longer 

needed by the U.S. Department of Homeland 

Security or the Hawai‘i State Department 

of Health, additional NPS analysis would 

be needed to determine the feasibility of 

management options and associated costs. 

Given the size and scale of the facilities, costs 

for maintenance and preservation of the historic 

structures would be a primary consideration. 

The public enjoyment potential of the facilities 

is high given its accessible and prominent 

location in downtown Honolulu. 
114 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

 Table 5-2: Feasibility Analysis, Summary Table

Feasibility Factors Issues and Conclusions

Land use, current and 

potential site uses, 

ownership patterns, 

planning and zoning

Current land use, ownership patterns, and zoning associated with Honouliuli 

Internment Camp would support NPS management of a national park unit. 

Existing use of the U.S. Immigration Station complex by the U.S. Department 

of Homeland Security and Hawaiʻi State Department of Health make it 

incompatible with NPS management as part of a national park unit. If the U.S. 

Immigration Station buildings were no longer used by the U.S. Department 

of Homeland Security or the Hawai‘i State Department of Health, additional 

NPS analysis would be needed to determine the feasibility of management 

options and associated costs. Given the size and scale of the facilities, costs for 

maintenance and preservation of the historic structures would be a primary 

consideration.

Access and public 

enjoyment potential

There is a high potential for public enjoyment at Honouliuli Internment Camp. 

However, public visitation to the site is only feasible if public access to the site 

can be secured. Site improvements to provide for vehicle access, parking, trails/

walkways, interpretative features, and other facilities would also be necessary. 

Currently, public access to the U.S. Immigration Station buildings is not feasible. 

Boundary size and 

configuration

Honouliuli Internment Camp and the U.S. Immigration Station sites each 

provide for the inclusion and protection of nationally significant resources 

associated with the incarceration and internment of civilians, alien residents, 

and prisoners of war in Hawaiʻi during World War II. Both sites include 

sufficient surrounding area to provide a proper setting for the resources and 

opportunities for visitor services and facilities.

Existing resource 

degradation and threats to 

resources

There are no current threats to Honouliuli Internment Camp that would 

preclude management of either site as a unit of the national park system. The 

historic site contains resources with integrity sufficient for national historic 

landmark designation and national park unit designation. The U.S. Immigration 

Station buildings appear to be in excellent condition with high levels of historic 

integrity. However, additional analysis would be needed to determine whether 

any threats or resource degradation would preclude NPS management.

Public interest and support Outreach for this study has demonstrated significant public interest and 

support for a national park unit at Honouliuli in partnership with other 

organizations and local communities.

Social and economic impact The social and economic impacts of NPS designation appear to be largely 

beneficial and would support the feasibility of NPS designation.

Costs associated with 

operation, acquisition, 

development, and 

restoration

Costs for establishing a national park unit at Honouliuli Gulch appear to be 

feasible, provided that national historic site or national monument would 

be supported with operational capacity at World War II Valor in the Pacific 

National Monument. Partnership opportunities could also be pursued to 

support NPS operations and programs.
Chapter 5: Feasibility and the Need for NPS Management  Determination of Need for NPS Management 115

Determination of Need for NPS 

Management

The need for direct NPS management is the final 

criterion for evaluating resources for potential 

designation as a new unit of the national 

park system. The criterion requires a finding 

that NPS management would be superior to 

alternative management arrangements by other 

entities.

Evaluation of the need for NPS management 

pertains to those resources that are determined 

to be nationally significant, suitable, and feasible 

for inclusion in the national park system. 

Based on these findings, the need for NPS 

management focuses on Honouliuli Internment 

Camp. Associated sites would continue to be 

owned and operated by nonprofit organizations, 

private property owners, and other government 

agencies. The owner of the Honouliuli site, the 

Monsanto Company, has expressed interest 

in donating the site to the United States for its 

long-term preservation. Other organizations 

have not been identified that would be willing 

to take on direct ownership and management 

of the site for public use, or to which Monsanto 

would be willing to transfer the site.

The incorporation of Honouliuli Internment 

Camp into the national park system would 

offer a visitor experience that allows the 

broadest understanding of the resources and 

stories relating to the internment of Japanese 

Americans and European Americans in 

Hawai‘i during World War II. NPS planning 

and research capabilities, as well as historic 

preservation, cultural resource management 

and interpretive and educational programming 

expertise, would offer superior opportunities 

for the site to be preserved and interpreted. 

In addition, NPS partnerships with 

organizations and private property owners 

of the associated sites would provide 

enhanced opportunities for interpretation and 

coordinated site management. Development 

and cooperative management of interpretive 

programs and comprehensive visitor services 

with the NPS would be beneficial. 

NEED FOR NPS MANAGEMENT 

CONCLUSION 

The NPS finds that there is a need for NPS 

management in partnership with others to 

fully protect resources and to enhance visitor 

appreciation of the nationally significant 

resources and important stories associated 

with the Honouliuli Internment Camp. The 

incorporation of Honouliuli Internment 

Camp into the national park system would 

offer a visitor experience that allows the 

broadest understanding of the resources and 

stories relating to the internment of Japanese 

Americans and European Americans in 

Hawai‘i during World War II. Although local 

organizations have been active in pursuing 

preservation of the historic site, no other agency 

or organization has been identified that could 

take on direct management and ownership for 

public enjoyment and long-term conservation 

of the resources.
116 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 
6ALTERNATIVES
Participants, Honouliuli Internment Camp Field Study, July 2010. Photo: Valentino Valdez.
Chapter 6: Alternatives  Introduction 117

CHAPTER 6: ALTERNATIVES 

This chapter describes the range of management 

alternatives analyzed in the study.

Introduction

The legislation authorizing this study directs 

the NPS to determine whether any of the sites 

evaluated meet the criteria for inclusion in 

the national park system and the appropriate 

methods for preserving and interpreting 

such sites. The methods for management are 

described as alternatives for the purposes of this 

study.

Overview of the Alternatives 

The study team developed two alternatives 

for the draft study report/environmental 

assessment (EA), based on information 

gathered from public and stakeholder input, 

internal NPS discussions, evaluation of special 

resource study criteria, historical research, and 

NPS management models. The two alternatives 

considered include a “No Action” alternative, 

which serves as a baseline for comparison, 

and an “action” alternative, which is also the 

preferred alternative. 

Ő#NVGTPCVKXG#: Continuation of Current 

Management (No Action) 

Ő#NVGTPCVKXG$: Honouliuli National Historic 

Site or National Monument—A Unit of the 

National Park System

For each alternative there is a description of 

the overall concept and key elements of the 

alternative, including management approaches, 

resource protection, visitor services, and the 

role of organizations and public agencies. Maps 

of the alternatives are included to illustrate the 

alternatives.

The Selected Alternative

NATIONAL HISTORIC SITE OR 

NATIONAL MONUMENT—A NEW UNIT 

OF THE NATIONAL PARK SYSTEM

The recommendations encompassed in the 

selected alternative are the same as those 

identified and analyzed in alternative B in the 

draft study report/EA, with the exception of 

modifications made as a result of information 

and comments derived from public review of 

the draft study report/EA, as follows:

ŐThe proposed national historic site or 

monument boundary has been reduced at 

the request of the University of Hawaiʻi. 

Discussions between the NPS and the 

University of Hawaiʻi have identified 

approaches to public access that do not 

require inclusion of University of Hawaiʻi 

land in an NPS boundary at this time. 

The University of Hawaiʻi is committed to 

working with the NPS on granting access 

to the site over university lands should a 

national park unit be established. Future 

road access could be added to the national 

historic site or monument boundary once a 

more permanent road alignment has been 

determined. 

ŐMinor modifications have also been made 

to address concerns regarding universal 

access to the site, potential partnerships, 

and technical assistance opportunities.

The above modifications would not constitute a 

change in environmental impacts beyond what 

was analyzed in the environmental assessment.

Management Alternatives No 

Longer Under Consideration

Two alternative approaches to preservation and 

interpretation of sites were initially considered: 

a national park unit consisting of all the sites 

contributing to the World War II incarceration 

and internment history in Hawaiʻi, and 

a national affiliated area for Honouliuli 

Internment Camp that would be owned and 

operated by a private nonprofit. A national park 

unit consisting of all of the sites evaluated in 

this study was dismissed because only two sites 

met the NPS criteria for national significance, 

and only one site, Honouliuli Internment Camp, 

met NPS criteria for significance, suitability, and 

feasibility. Affiliated area status for Honouliuli 

Internment Camp was dismissed from 

consideration because no organization was 

identified that would be able to take on direct 

management of the site.
118 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Description of the Alternatives

ALTERNATIVE A: CONTINUATION OF 

CURRENT MANAGEMENT (NO ACTION 

ALTERNATIVE)

%QPEGRVSites, organizations, and programs 

significant to the internment history in Hawaiʻi 

would continue to operate independently by 

existing landowners, agencies, or organizations 

without additional NPS management or 

assistance other than what is currently available 

through existing authorities and grant programs.

Definition

Under a “no action” alternative, current 

management of resources would continue. 

Existing programs and policies of federal, state, 

county, and nonprofit organizations would 

remain in place. 

Management of Sites Related to 

Internment in Hawai‘i 

Local organizations and institutions have 

been active in documentation, preservation, 

and interpretation efforts for Honouliuli 

Internment Camp. The Japanese Cultural 

Center of of Hawai‘i (JCCH) has conducted 

extensive research and uncovered the location 

of Honouliuli Internment Camp and other 

related sites. The JCCH maintains the largest 

repository of archives and collection items 

related to Honouliuli and the internment 

history in Hawai‘i. University of Hawai‘i—West 

O‘ahu faculty and students have also played 

a significant role in researching the history 

of Honouliuli and conducting archeological 

surveys. In 2012, the Hawaiʻi State Legislature 

commissioned an advisory group, called the 

Honouliuli Park Site Advisory Committee, to 

support preservation of the Honouliuli site. The 

advisory group was directed to: 1) provide state 

support toward preservation of the Honouliuli 

site; 2) establish a mechanism to leverage 

county, state, federal, and private funding for 

an educational resource center at the site; and 

3) memorialize the struggle for civil rights by 

Hawaiʻi’s people

Sites related to World War II internment 

in Hawai‘i would continue to be managed 

separately by their public and private 

landowners. With the exception of the Kilauea 

Military Camp at Hawaiʻi Volcanoes National 

Park, there would be no NPS staffing or 

operational support at sites identified in the 

study other than technical assistance under 

existing authorities if requested. Organizations 

and programs devoted to commemorating and 

preserving Hawaiʻi’s internment history would 

continue to operate independently without 

NPS management or assistance other than that 

available through existing authorities. Table 

6-1: Existing Management of Sites Evaluated 

in the Study includes a summary of current 

management and visitor opportunities for each 

of the sites evaluated in the study.

HONOULIULI INTERNMENT CAMP

Under the no action alternative, Honouliuli 

Internment Camp would remain in private 

ownership and would continue to be 

inaccessible to the general public. Interest by the 

existing landowner, public agencies, educational 

institutions, nonprofit organizations, 

and individuals may result in additional 

opportunities to interpret the site (See Map: 

Alternative A—Continuation of Current 

Management). 

Although the site would not be managed 

expressly to provide visitor opportunities, 

existing landowners may continue to allow 

the Japanese Cultural Center of Hawai‘i’s 

(JCCH) site tours and educational activities on 

occasion when permission is granted by the 

landowner. The University of Hawaiʻi—West 

O‘ahu (UHWO) would continue to conduct 

field schools at Honouliuli Internment Camp, as 

allowed by the current landowner.

OTHER ASSOCIATED SITES

Sites identified as potentially eligible for 

national historic landmark (NHL) nomination 

or nomination to the National Register of 

Historic Places (NRHP) would continue to be 

owned by various public and private entities. 

These sites would continue to function for 

private and public uses, most of which are not 

related to World War II internment history. 

Interpretation and conservation of such sites 

would be uncoordinated and at the discretion 

of the current landowner. 

Partner organizations and agencies would 

take the lead in developing interpretation and 

education materials and visitor opportunities. 
 Chapter 6: Alternatives  Description of the Alternatives 119
120 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Such opportunities would occur at locations 

such as the JCCH. 

Resource Protection

The primary responsibility for preserving 

nationally significant and associated sites 

would fall to the current owners and managers 

of those sites. Resource protection would 

be voluntary and dependent upon property 

owners’ initiative. 

Sites in federal ownership would be managed 

in compliance with the National Historic 

Preservation Act (U.S. Immigration Station, 

Kilauea Military Camp). Sites not in federal 

ownership and currently listed in the National 

Register of Historic Places, such as the 

Honolulu Police Department, Yokohama Specie 

Bank, Kauaʻi County Courthouse, and Maui 

County Courthouse and Police Station, would 

have some opportunities for technical assistance 

and grants for preservation.

For sites not listed on the NRHP nor protected 

by local preservation ordinances, any efforts 

for preservation would be at the discretion of 

existing landowners. Resources could suffer 

from a loss of integrity due to changes in use or 

ownership in accordance with local planning 

and zoning ordinances over time. Existing 

owners may also lack funding to maintain or 

preserve sites. 

Visitor Experience

Organizations that provide visitor opportunities 

to learn about the internment history could 

continue to provide such opportunities. 

The JCCH could continue to provide visitor 

opportunities at the annual pilgrimage to 

Honouliuli, if the property owner was willing. 

Hawaiʻi Volcanoes National Park could provide 

interpretation at Kilauea Military Camp in 

coordination with the U.S. Army. World War 

II Valor in the Pacific National Monument 

at Pearl Harbor would continue to interpret 

the internment experience in Hawaiʻi as one 

component of the larger Pacific War story that it 

is mandated to convey. 

Most other associated sites identified as 

significant to internment in Hawai‘i are 

not managed expressly to provide visitor 

opportunities to learn about or experience 

these sites. 

Japanese American Confinement Sites 

(JACS) Grant Program 

Honouliuli Internment Camp and other 

associated sites would continue to be eligible 

for grants through the Japanese American 

Confinement Sites (JACS) Grant Program. 

Public Law 109-441 (16 USC 461) established 

the JACS Grant Program for the preservation 

and interpretation of U.S. confinement sites 

where Japanese Americans were incarcerated 

during World War II. The law authorized up to 

$38 million for the life of the grant program to 

identify, research, evaluate, interpret, protect, 

restore, repair, and acquire historic confinement 

sites in order that present and future 

generations may learn and gain inspiration from 

these sites and that these sites will demonstrate 

the nation’s commitment to equal justice under 

the law.

Grants are awarded to organizations and 

entities working to preserve historic Japanese 

American confinement sites and their history, 

including private nonprofit organizations; 

educational institutions; state, local, and tribal 

governments; and other public entities. Grants 

are awarded through a competitive process and 

require a two-to-one federal to non-federal 

match ($2 federal to $1 non-federal). Since its 

establishment in 2006, the JACS Grant Program 

has awarded more than $15 million in grants as 

of fiscal year 2014. To date, JCCH has received 

five grants totaling $375,700. Projects funded 

include a documentary film, educational 

tours, a youth program, traveling exhibits, and 

multimedia virtual tours. The University of 

Hawai‘i has received four grants to date, totaling 

$168,700. Projects funded include collection 

of oral histories, archival research, and 

archeological field schools. California-based 

CyArk received a grant of $39,020 to digitally 

document Honouliuli. Under the no action 

alternative, organizations would continue to 

apply for JACS grants for the life of the program.

Operations 

Operations and maintenance of existing 

sites would be assumed to remain at existing 

levels. With the exception of Kilauea Military 

Camp in Hawai‘i Volcanoes National Park, 

there would be no NPS staffing or operational 

responsibilities at nationally significant or 

potential NHL or NRHP sites associated with 

internment in Hawai‘i. 
 Chapter 6: Alternatives  Description of the Alternatives 121

Table 6-1: Existing Management of Sites Evaluated in the Study

Site Site Type Ownership and 

Management

Current Visitor 

Opportunities or 

Interpretation 

Nationally Significant Sites

Honouliuli Internment 

Camp

Primary, O‘ahu Private Currently not accessible to 

the general public. Site tours 

and use for educational 

purposes occur on occasion 

with landowner permission.

U.S. Immigration Station Primary, O‘ahu Public, Department 

of Homeland Security 

and Hawaiʻi State 

Department of Health

None. Currently not 

accessible to the general 

public.

Sites Listed or Potentially Eligible for Listing in the National Register of Historic Places

*QPQNWNW2QNKEG

Department

Secondary, O‘ahu Public, City and County 

of Honolulu

None

Kauaʻi County Courthouse Secondary, Kaua‘i Public, County of Kaua‘i None

Kilauea Military Camp Primary, Island of 

Hawaiʻi

Public, National Park 

Service

Active military recreation 

camp. However, 

opportunities for 

interpretation exist.

Yokohama Specie Bank Secondary, O‘ahu Private None

Lānaʻi City Jail and 

Courthouse

Secondary, Lānaʻi Private None

Potentially Significant Sites—Additional Research Needed

Waiākea Prison Camp Secondary, Island of 

Hawaiʻi

Private None

Hilo Independent Japanese 

Language School

Secondary, Island of 

Hawaiʻi

Unknown None

Līhuʻe Plantation 

Gymnasium 

Secondary, Kaua‘i Privately-owned 

structure adjacent to 

Isenberg Park

None

Kalāheo Stockade Primary, Kaua‘i Private None

Haʻikū Military Camp Secondary, Maui Private None

Maui County Courthouse 

and Police Station

Secondary, Maui Public, Maui County None

Other Related Sites—No Integrity Remaining

Sand Island Detention 

Camp

Primary, O‘ahu Public, State of Hawaiʻi None/Non-Extant

Wailua Jail Primary, Kaua‘i Public None/Non-Extant

Waimea Jail Primary, Kaua‘i Public None/Non-Extant

Kaunakakai Jail and 

Courthouse

Secondary, 

Molokaʻi

Public None/Non-Extant

Maui County Jail Primary, Maui Public, Maui County None/Non-Extant

“Primary” sites are those that housed at least 10 prisoners, generally for more than several weeks. “Secondary” sites are those that 

were used as prisons for fewer prisoners, usually for shorter periods of time. Also included in the “secondary” category are sites 

where no internees were imprisoned, but where activities related to the internment occurred, such as hearings. Note: The Honolulu 

Police Department was inadvertently omitted from the printed versions of this table in the newsletter and draft report.
122 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

ALTERNATIVE B (SELECTED 

ALTERNATIVE): HONOULIULI NATIONAL 

HISTORIC SITE OR NATIONAL 

MONUMENT—A NEW UNIT OF THE 

NATIONAL PARK SYSTEM

Concept: Congress would establish Honouliuli 

National Historic Site as a new unit of the 

national park system. Alternatively, a national 

monument managed by the National Park 

Service could be established. The national 

historic site or national monument would 

include the historic site of the Honouliuli 

Internment Camp and adjacent lands that 

would allow for access and visitor facilities. In 

collaboration with partners, the National Park 

Service would preserve the site and interpret 

the internment of Japanese Americans and 

European Americans in Hawaiʻi during World 

War II. The national historic site or monument 

would be supported by operational capacity 

at World War II Valor in the Pacific National 

Monument, Pearl Harbor. The National Park 

Service could respond to requests to provide 

technical assistance for the preservation and 

interpretation of other sites, features, and 

stories related to internment in Hawaiʻi during 

World War II. 

Definition

A national historic site usually contains a single 

historical feature that is directly associated 

with its subject. National historic sites preserve 

places and commemorate persons, events, and 

activities important in the nation’s history. 

Examples of national historic sites include 

Minidoka in Idaho and Manzanar in California, 

both of which protect resources related to the 

mainland incarceration of Japanese Americans 

during World War II. A national monument 

is intended to preserve at least one nationally 

significant resource. It is usually smaller 

than a national park and lacks its diversity of 

attractions. 

National park units are typically established by 

an act of Congress. However, the Antiquities Act 

of 1906 gives the President of the United States 

the authority to establish national monuments 

on federally owned lands.

Proposed Area 

The Honouliuli National Historic Site or 

National Monument would total approximately 

155 acres. The historic Honouliuli Internment 

Camp and the adjacent overlook parcel (totaling 

approximately 123 acres) would be acquired by 

the NPS through a donation by the Monsanto 

Company. Additional Monsanto-owned lands 

(31.5 acres) with related resources could be 

protected through conservation easements, 

land transfer, or other measures at Monsanto’s 

discretion. All private property rights would be 

respected. 

The University of Hawaiʻi has committed 

to providing the NPS with public access to 

Honouliuli, initially through granting the NPS 

a right of entry over existing roads from the 

west. The University of Hawaiʻi is currently 

undergoing planning efforts for its lands 

adjacent to Honouliuli. This process and 

subsequent planning by the NPS should a 

national park unit be established may identify 

a new road alignment for public access. Once 

a desired road alignment for public access has 

been determined, this road alignment could be 

included in the national historic site or national 

monument through a boundary adjustment. 

This would allow the National Park Service to 

expend funds on the development maintenance 

of the access road.

Three parcels owned by the City and County 

of Honolulu Board of Water Supply (totaling 

0.6 acres) would be inholdings within the 

proposed area and would remain under 

current ownership and management. The 

communications facilities, non-contributing 

features within the historic site, would not be 

included in the proposed boundary. 

Management

The NPS would have direct management 

responsibility for the Honouliuli National 

Historic Site or National Monument including: 

1) interpretation and education associated 

with the Honouliuli Internment Camp and 

its resources, including the development 

of interpretive media and programs; 2) 

preservation and resource management for the 

historic site; and 3) operational facilities and 

infrastructure such as roads, restrooms, and 

trails.
 Chapter 6: Alternatives  Description of the Alternatives 123
124 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Resource Protection

NPS staff would protect and preserve resources 

related to Honouliuli Internment Camp. 

Management plans would guide appropriate 

historic preservation documentation and 

treatments. As described below, there are 

opportunities to partner with local institutions 

and organizations in the protection of 

resources.

Visitor Experience

Visitors would have opportunities to learn 

about Honouliuli Internment Camp, World 

War II internment in Hawaiʻi, martial law, civil 

liberties, and peace and reconciliation through 

a wide variety of interpretive and educational 

programs onsite and at offsite locations. 

Interpretation would be accessible and relevant 

to diverse audiences and multiple generations. 

Virtual visitor experiences would be explored 

so that people could learn about and experience 

Honouliuli and related sites without actually 

visiting the sites. Programs could be provided 

by NPS rangers, partners, and volunteers. 

Information could be presented in multiple 

languages.

Partnerships

Other entities, specifically the University of 

Hawaiʻi—West O‘ahu and the Japanese Cultural 

Center of Hawaiʻi, have done significant work 

to document, preserve, and interpret the 

Honouliuli Internment Camp and the larger 

history of internment in Hawai‘i during World 

War II. The NPS would seek to maintain these 

partnerships for future management of the 

Honouliuli National Historic Site or Monument. 

In addition, the NPS would explore, develop, 

and maintain new partnerships for the 

preservation and interpretation of Honouliuli 

Internment Camp and related sites, features, 

and stories in Hawaiʻi. 

There are substantial opportunities for 

partnerships related to Honouliuli National 

Historic Site or Monument with public agencies, 

educational institutions, nonprofit entities, and 

individuals. Potential partnership projects are 

numerous and could include the development 

of educational programs, development of 

facilities, resource stewardship activities 

such as preservation of historic features and 

vegetation clearing, and research projects. 

Partnerships could also include shared facilities 

for interpretation, curatorial storage, operations, 

and maintenance. 

Technical Assistance

World War II-era internment and incarceration 

sites in Hawai‘i other than Honouliuli 

Internment Camp would continue to be owned 

and managed by their respective public and 

private owners. Any recognition or technical 

assistance related to the associated sites would 

be voluntary on the part of the landowner. The 

associated sites illustrate the broad-reaching 

effects of internment on the six major islands 

in Hawai‘i and are valuable in accurately 

interpreting this history. 

Upon request, the NPS could work 

cooperatively with associated site owners 

and managers to explore opportunities for 

interpretation and/or preservation of the 

associated sites. Any request for technical 

assistance related to the associated sites would 

be voluntary on the part of the landowner.

Where appropriate, the NPS could also conduct 

research and respond to requests for assistance 

to related sites that have yet to be identified.

OPERATIONS 

STAFFING

Honouliuli National Historic Site or Monument 

would be managed through World War II 

Valor in the Pacific National Monument at 

Pearl Harbor, given its close proximity and 

related history. Some staff positions at World 

War II Valor in the Pacific National Monument 

would be shared. However, management of the 

site would require additional staff as funding 

became available. A management plan would 

identify priorities, management emphases, and 

required staffing for a 15 to 20 year timeframe. 

Based on comparisons of staffing levels for 

existing national historic sites of similar scale 

and management models, the following types of 

staff would be recommended:

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 Chapter 6: Alternatives  Description of the Alternatives 125

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Positions could be permanent, temporary, or 

seasonal. In addition, partner organizations 

could provide staff or volunteers, with types 

and numbers dependent upon the functions 

provided. 

OPERATIONAL AND VISITOR FACILITIES

Comprehensive management planning 

would guide the development of facilities for 

Honouliuli National Historic Site or National 

Monument. Facilities would be needed to 

support public access, circulation, orientation, 

and learning about the history of internment in 

Hawaiʻi. The 7-acre overlook site could serve 

as a visitor staging area with ample space to 

provide for parking, visitor drop-off, interpretive 

features, and restrooms. The site is located 

just outside of the historic camp and offers 

views to Pearl Harbor, downtown Honolulu, 

and Diamond Head. Within the gulch, visitor 

facilities would be minimal to preserve the site’s 

historic integrity. Facilities might include trails, 

interpretive waysides, primitive roads, and vault 

toilets. Implementation planning would also 

explore opportunities for persons of all abilities 

to access and experience Honouliuli Internment 

Camp.

Currently there is no public access to 

Honouliuli Internment Camp. Rights of access 

would be required to provide public access 

to the 7-acre overlook parcel and the historic 

site. Existing roads would require considerable 

improvement to accommodate visitor access. 

As noted above, the University of Hawaiʻi has 

indicated its commitment to working with the 

National Park Service with regard to providing 

public access on existing and future roads 

through its lands.

Japan America Society tour of Honouliuli in 2012. Photo: University of Hawai‘i—West O‘ahu Archeological Field School.
126 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Specific costs would be reevaluated in 

subsequent, more detailed planning for the unit. 

Planning would consider facility and site design, 

detailed identification of resource protection 

needs, and changing visitor expectations. Actual 

costs to the NPS would vary depending on 

timing and implementation and contributions 

by partners and volunteers. It is assumed that 

the long-range financial needs of Honouliuli 

National Historic Site or Monument would not 

just rely upon federally appropriated funds. 

A variety of other public and private funding 

sources could be sought by the NPS to assist in 

implementation efforts. Other NPS units have 

successfully found partners to help with funding 

major projects, and some of the costs associated 

with actions in the alternatives may prove to be 

less expensive if donated materials, labor, and 

other support can be secured.

The Federal Highway Administration (FHA) 

estimated construction costs for public and 

administrative access using existing road 

alignments would range from $3 to $ 20 million. 

This dollar amount would also include parking 

and turnaround areas for buses. The higher end 

of the range would be incurred if additional 

reconstruction or realignment is necessary 

for road improvements. Costs would need 

to be reevaluated after a formal site survey 

and through completion of a comprehensive 

management plan. 

Shuttle or bus service from either World War 

II Valor in the Pacific National Monument or 

UHWO was also evaluated by the FHA. Costs 

to operate a bus connection from World War 

II Valor in the Pacific National Monument 

three times per week were estimated at $25,000 

to $30,000 annually. Costs to operate a bus 

or shuttle from University of Hawaiʻi—West 

O‘ahu twice daily were estimated at $91,000 to 

$112,000 annually.

NPS management of a national historic site at 

Honouliuli Gulch would be funded through 

federal appropriations as part of the annual 

NPS budget and through potential partners and 

grants. The national historic site or monument 

could share administrative, visitor, and 

operational facilities with World War II Valor 

in the Pacific National Monument or partner 

entities. 

Non-federal entities would continue to be 

eligible for the grants through the Japanese 

American Confinement Sites Grant Program 

for preservation, interpretation, and 

documentation projects associated with 

Honouliuli Internment Camp.

Based on the size and scope of this site, and the 

types of services and assistance proposed, the 

annual cost of NPS operations for the national 

historic site could be expected to be $400,000 

to $750,000. The estimated operational budget 

would primarily fund NPS staff, programs, 

projects, and outreach. 
7ENVIRONMENTAL CONSEQUENCES
Chinese banyan tree, Honouliuli. Photo: NPS, 2011.
 Chapter 7: Environmental Consequences  Introduction 127

CHAPTER 7: ENVIRONMENTAL 

CONSEQUENCES

Analysis of the environmental impacts associated 

with the study alternatives. 

Introduction

NPS policy requires that a special resource 

study be accompanied by an environment 

compliance document that is prepared in 

accordance with the requirements of the 

National Environmental Policy Act (NEPA), 

its implementing regulations (36 CFR 1500-

1508), and Director’s Order #12, Conservation 

Planning, Environmental Impact Analysis, and 

Decision-Making (2011).

Since a special resource study presents 

management alternatives at a broad level, an 

accompanying environmental assessment is also 

performed at a broad or general level. If the site 

is designated for ownership and management 

by the NPS, more detailed planning and analysis 

through a management planning process would 

result.

The National Environmental Policy Act 

requires that environmental documents disclose 

the environmental impacts of the proposed 

federal action, reasonable alternatives to 

that action, and any adverse environmental 

effects that cannot be avoided should the 

proposed action be implemented. This section 

analyzes the environmental impacts of project 

alternatives on affected resources. This analysis 

provides the basis for comparing the effects of 

the alternatives. NEPA requires consideration 

of context, intensity and duration of impacts, 

indirect impacts, cumulative impacts, and 

measures to mitigate impacts. Impact analysis 

for historic properties is based on National 

Historic Preservation Act (36 CFR Part 800) 

criteria of effect as detailed below.

The first part of the chapter discusses the 

methodology used to identify impacts and 

includes definitions of terms. The impact topics 

are then analyzed with reference to each of the 

alternatives. The discussion of each impact topic 

includes a description of the beneficial and 

adverse effects of the alternatives, a discussion 

of cumulative effects, if any, and a conclusion. 

IMPACT TYPE

The impact type classifies the effects as 

beneficial or adverse and direct or indirect.

Beneficial: A change that improves the 

condition or appearance of the resource or 

a change that moves the resource toward a 

desired condition.

Adverse: A change that would deplete or 

detract from the condition or appearance of the 

resource or a change that moves the resource 

away from a desired condition.

Direct: An effect that is caused by an action and 

occurs in the same time and place.

Indirect: An effect that is caused by an action 

but is later in time or farther removed in 

distance, but is still reasonably foreseeable.

CONTEXT

The context describes the area or location in 

which the impact will occur. 

Site Specific: Impacts would occur at the 

location of the action.

Localized: Impacts are limited in extent and 

would occur in the vicinity of the site being 

discussed. 

Regional or Widespread: Impacts would 

occur across an area or habitat, such as affecting 

the resource within a watershed or park 

unit (beyond the boundary of the site being 

discussed). Widespread impacts are often 

detectable on a landscape or regional scale.

DURATION

Describes the length of time an effect will occur, 

either short-term or long-term:

Short-term impacts generally last only during 

construction, and the resources resume 

their pre-construction conditions following 

construction. Short-term impacts are often 

quickly reversible and associated with a specific 

event and may last from one to five years.

Long-term impacts last beyond the 

construction period, and the resources may not 

resume their pre-construction conditions for a 

longer period of time following construction. 

Long-term impacts may be reversible over a 
128 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

much longer period, or may occur continuously 

based on normal activity, or for more than five 

years.

INTENSITY

Intensity describes the degree, level, or strength 

of an impact. For this analysis, intensity has 

been categorized into negligible, minor, 

moderate, and major. Beneficial impacts are 

described but are not assigned intensity levels.

Negligible: Measurable or anticipated degree 

of change would not be detectable or would be 

only slightly detectable and localized.

Minor: Impacts would be slightly detectable or 

localized within a small portion of the project 

area.

Moderate: Impacts would be measurable or an 

anticipated degree of change is readily apparent 

and appreciable. They may be localized or 

widespread and would be noticed by most 

people.

Major: Impacts would be substantial, highly 

noticeable, and widespread. Changes to the 

character of the landscape would occur.

REDUCING THE LEVEL OF IMPACTS

To reduce their occurrence or intensity, impacts 

may be avoided, minimized, or mitigated. 

Managers may:

Avoid conducting management activities in an 

area of the affected resource,

Minimize the type, duration, or intensity of the 

impact to an affected resource, or

Mitigate the impact by:

ŐRepairing localized damage to the affected 

resource immediately after an adverse 

impact.

ŐRehabilitating an affected resource with 

a combination of additional management 

activities.

ŐCompensating a major long-term adverse 

direct impact through additional strategies 

designed to improve an affected resource to 

the degree practicable.

CUMULATIVE IMPACT SCENARIO

The Council on Environmental Quality (CEQ) 

regulations, which implement the National 

Environmental Policy Act of 1969 (42 USC 

4321 et seq.), require assessment of cumulative 

impacts in the decision-making process for 

federal projects. 

The CEQ describes a cumulative impact as 

follows (Regulation 1508.7): 

A “cumulative impact” is 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 (federal or 

non-federal) or person undertakes 

such other actions. Cumulative impacts 

can result from individually minor but 

collectively significant actions taking 

place over a period of time.

The cumulative projects addressed in this 

analysis include past and present actions, as 

well as any planning or development activity 

currently being implemented or planned for 

implementation in the reasonably foreseeable 

future. Cumulative actions are evaluated in 

conjunction with the impacts of an alternative 

to determine if they have any additive effects 

on a particular resource. Because most of the 

cumulative projects are in the early planning 

stages, the evaluation of cumulative impacts was 

based on a general description of the project. 

Ongoing or reasonably foreseeable future 

projects were identified for the surrounding 

area. 

The geographic scope for the cumulative 

impacts analysis is Honouliuli Gulch and 

adjacent areas. It is difficult to determine 

cumulative impacts for the associated sites given 

the range of locations and property owners. 

Projects Included in the Cumulative 

Effects Analysis for this Environmental 

Assessment

UNIVERSITY OF HAWAI‘I—WEST O‘AHU (UHWO)

The University of Hawaiʻi recently developed 

a regional plan for a new campus in West 

O‘ahu south of the H-1 Freeway and south of 

the Monsanto property and Honouliuli site. 

Construction of the new university has been 
 Chapter 7: Environmental Consequences  Impact Topics 129

underway for two years and will likely continue 

into the next decade. The University also owns 

the parcel adjacent to Honouliuli known as 

the UHWO Mauka parcel and has indicated 

that master planning for the Mauka parcel 

will be initiated in the near future. There will 

be opportunities for the NPS and UHWO to 

work together in developing plans for adjoining 

properties. 

HONOLULU RAIL TRANSIT PROJECT

The Honolulu Rail Transit Project is a 20-mile 

elevated rail line that will connect west O‘ahu 

with downtown Honolulu and, ultimately, the 

University of Hawaiʻi’s Manoa Campus. The 

Honolulu Authority for Rapid Transportation 

and the U.S. Federal Transit Administration have 

completed major planning phases of the project, 

with some construction already initiated in the 

UHWO area. The rail system, once completed, 

has the potential for transporting visitors from 

the primary visitor lodging areas in Waikiki 

to the UHWO area, enhancing access to 

Honouliuli Gulch. 

MONSANTO COMPANY HAWAI‘I AGRICULTURAL

RESEARCH FACILITY

The Monsanto Company operates seed 

research, development, and manufacturing 

on several hundred acres of land immediately 

adjacent to Honouliuli Gulch. The Monsanto 

Company owns the Honouliuli Gulch property 

but does not utilize the area for agricultural 

purposes. As an agricultural research facility, 

Monsanto utilizes both field and laboratory 

areas for agricultural purposes. These activities 

include discing and planting fields, installing 

irrigation systems, and developing erosion 

control modifications to their field system.

ASSUMPTIONS

Given the broad nature of this study, the 

impact analysis must also be broad, by 

necessity, and avoid speculation as to sitespecific impacts. The findings of this study will 

inform a recommendation by the Secretary 

of the Interior to Congress. If a national park 

unit is designated, then new environmental 

analysis would be undertaken prior to specific 

implementation actions. This planning would 

propose specific actions, and alternatives to 

them, whose site or area specific impacts would 

be assessed prior to plan implementation. 

Current economic conditions limit the nearterm potential for increased local, state, and 

federal funding for conservation and historic 

preservation. 

The majority of the analyses in this document 

addresses the Honouliuli Gulch area in more 

detail than the other associated sites because 

Honouliuli Gulch is the area under alternative 

B (preferred) that would be managed by the 

National Park Service. 

The other associated sites would continue to 

be managed by existing ownership entities, 

regardless of which alternative is selected. 

Under alternative B, the NPS could, with 

a willing landowner, provide community 

outreach and technical assistance for the 

preservation and interpretation of these other 

locales. A cooperative partnership between 

the NPS and the private landowners is neither 

required nor assumed, and the manner in which 

alternative B’s actions could affect these sites is 

undetermined. 

Impact Topics

Specific impact topics were developed to 

address potential physical, natural, cultural, 

recreational, and social impacts that might result 

from the proposed alternatives as identified 

by the public, NPS, and other agencies and to 

address federal laws, regulations and executive 

orders, and NPS policy. Impact topics are the 

resources of concern that may be affected by the 

range of alternatives considered in this EA. 

An Environmental Screening Form was 

used to identify initial resources of concern. 

Environmental Screening Forms were 

mandated by NPS DO-12: Conservation 

Planning, Environmental Impact Analysis and 

Decision-making. Comments received from the 

public during scoping were also considered in 

the screening process. A brief rationale for the 

selection or dismissal of each impact topic is 

provided in Table 7-1 and Table 7-2.
130 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

IMPACT TOPICS ANALYZED

Potential impact topics are reviewed here as to their applicability in this analysis. The rationale for this 

review stems from the essential purpose of an environmental assessment: to determine whether there 

would be significant impacts requiring the preparation of an environmental impact statement in order 

to proceed with the action. The dismissal of topics, with rationale, demonstrates there is no concern 

in those areas.

Table 7-1: Impact Topics Analyzed

Impact Topic Retained Discussion and Rationale

Land Use 

(including Prime and 

Unique Farmland)

Management Policies (NPS 2006) states: “...the Service will cooperate with 

federal agencies; tribal, state, and local governments; nonprofit organizations; and 

property owners to provide appropriate protection measures. Cooperation with 

these entities will also be pursued, and other available land protection tools will be 

employed when threats to resources originate outside boundaries.” Because the 

alternatives may affect land use, including ownership, occupancy and activities, 

land use has been retained as an impact topic.

The Farmland Protection Policy Act of 1981, as amended, requires federal agencies 

to consider adverse effects to prime and unique farmland that would result in the 

conversion of these lands to non-agricultural uses. Prime or unique farmland is 

classified by the USDA, Natural Resources Conservation Service and is defined as 

soil that particularly produces general crops such as common foods, forage, fiber, 

and oil seed; unique farmland produces specialty crops such as fruits, vegetables, 

and nuts. Prime farmland is one of several kinds of important farmland defined by 

the USDA. It is of major importance in meeting the nation’s short- and long-range 

needs for food and fiber. Because the supply of high-quality farmland is limited, 

the USDA recognizes that responsible levels of government, as well as individuals, 

should encourage and facilitate the wise use of our nation’s prime farmland. 

ALISH (Agricultural Lands of Importance to the State of Hawaiʻi) is a Hawaiʻi state 

classification system that identifies agriculturally important lands and is intended to 

provide decision makers with a tool for use in agricultural preservation, planning, 

and development.The criteria for classification of prime agricultural land are 

identical to the criteria established by Soil Conservation Service, U.S. Department 

of Agriculture for national application. The criteria for unique agricultural and 

other important agricultural lands were established cooperatively by the Soil 

Conservation Service in Hawai‘i, the College of Tropical Agriculture, and the State 

Department of Agriculture. Based on planning maps available through the State of 

Hawaiʻi Office of Planning website, areas immediately adjacent to Honouliuli Gulch 

are considered prime farmland.

The potential for an introduction of visitors to an area surrounded by ALISH lands 

may present an impact to agricultural operations, therefore this topic has been 

retained.

Water Resources (Water 

Quality and Hydrology) 

Management Policies (NPS 2006) provides direction for the preservation, use, and 

quality of water in national parks. Minor construction projects have the potential 

to contaminate ground and/or surface water and may have impacts to streams, 

including water quality. Potential effects to hydrology could also occur from the 

construction of structures, such as culverts or bridges; therefore this topic has been 

retained. The Honolulu Board of Water Supply maintains wells and pumping/

storage facilities in and immediately adjacent to the Honouliuli Gulch site. Potential 

effects to hydrology could occur from the construction of structures, such as 

culverts or bridges. Therefore this topic has been retained.
 Chapter 7: Environmental Consequences  Impact Topics 131

Table 7-1: Impact Topics Analyzed

Impact Topic Retained Discussion and Rationale

Vegetation NEPA calls for examination of the impacts on the components of affected 

ecosystems. Management Policies (NPS 2006) calls for protecting the natural 

abundance and diversity of park native species and communities, including 

avoiding, minimizing or mitigating potential impacts from proposed projects. 

Potential effects to native vegetation, including the introduction of non-native 

species, could occur from the construction of roads and/or structures, such as 

culverts or bridges. Therefore this topic has been retained. 

Prehistoric and Historic 

Archeology

Compliance with the Archeological Resources Protection Act in protecting 

known or undiscovered archeological resources is necessary. Management 

Policies (NPS 2006) calls for ongoing inventory and analysis of the significance 

of archeological resources. In addition to the NHPA and Management Policies, 

NPS DO 28B Archaeology affirms a long-term commitment to the appropriate 

investigation, documentation, preservation, interpretation, and protection of 

archeological resources within units of the national park system. As one of the 

principal stewards of America’s heritage, the NPS is charged with the preservation 

of the commemorative, educational, scientific, and traditional cultural values 

of archeological resources for the benefit and enjoyment of present and future 

generations.

Historic Structures/

Cultural Landscapes

Consideration of the impacts to cultural resources is required under provisions 

of Section 106 of the NHPA as amended, and the 2008 Programmatic Agreement 

among the National Park Service, the National Conference of State Historic 

Preservation Officers, and the Advisory Council on Historic Preservation (ACHP). It 

is also required under NPS Management Policies 2006. 

Federal land management agencies are required to consider the effects proposed 

actions have on properties listed in, or eligible for inclusion in, the National 

Register of Historic Places (i.e., Historic Properties), and allow the ACHP a 

reasonable opportunity to comment. The National Register is the nation’s 

inventory of historic places and the national repository of documentation on 

property types and their significance. Agencies are required to consult with federal, 

state, local, and tribal governments/organizations, identify historic properties, 

assess adverse effects to historic properties, and negate, minimize, or mitigate 

adverse effects to historic properties while engaged in any federal or federallyassisted undertaking (36 CFR Part 800). 

Historic properties may be objects, structures, buildings, or cultural landscapes. 

Cultural landscapes are settings humans have created in the natural world. They 

reveal the ties between the people and the land. These ties are based on the need 

to grow food, build settlements, recreate, and find suitable land to bury their dead. 

They range from prehistoric settlements to cattle ranches, from cemeteries to 

pilgrimage routes and are the expressions of human manipulation and adaptation 

of the land. 

Museum Collections Management Policies (NPS 2006) and other cultural resources laws identify the 

need to evaluate effects on NPS collections if applicable. Requirements for proper 

management of museum objects are defined in 36 CFR 79.
132 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Table 7-1: Impact Topics Analyzed

Impact Topic Retained Discussion and Rationale

Visitor Experience According to Management Policies (NPS 2006), the enjoyment of park resources 

and values by people is part of the fundamental purpose of all park units. The 

NPS is committed to providing appropriate, high-quality opportunities for 

visitors to enjoy the parks, and will maintain within the parks an atmosphere that 

is open, inviting, and accessible to every segment of society. The parks provide 

opportunities for forms of enjoyment that are uniquely suited and appropriate 

to the superlative natural and cultural resources found in the parks. Management 

Policies (NPS 2006) also states that scenic views and visual resources are considered 

highly valued associated characteristics that the NPS should strive to protect. 

Among the impacts that may be considered in this section are visitor access, 

opportunities and experience, soundscape, and scenic resources as well as 

interpretation and education. Therefore this topic has been retained for analysis.

Socioeconomics Socioeconomic impact analysis is required, as appropriate, under NEPA and 

Management Policies (NPS 2006) pertaining to host or gateway communities. The 

local and regional economy and some business of the communities surrounding 

the sites may be based on tourism and resource use. Manufacturing, professional 

services, and education also contribute to regional economies. Because the 

alternatives, if implemented, could affect local or regional economies, including 

minority and low-income populations, this impact topic has been retained for 

additional analysis. Included in socioeconomics is a brief analysis of impacts on 

minority and low-income populations.

Looking north into Honouliuli Gulch from the proposed administrative access road. Photo: NPS, 2013.
 Chapter 7: Environmental Consequences  Impact Topics 133

IMPACT TOPICS DISMISSED FROM FURTHER ANALYSIS

The topics listed below (Table 7-2) either would not be affected by the alternatives evaluated in 

this EA, or there would be negligible to minor effects on them. Therefore, these topics have been 

dismissed from further analysis. Negligible/minor effects are localized effects that would not be 

detectable over existing conditions or would not have lasting consequences. There would be no 

apparent change in the resource.

Table 7-2: Impact Topics Dismissed

Impact Topic 

Dismissed

Discussion and Rationale 

Federally Listed Species The Endangered Species Act (ESA) requires an examination of impacts to all 

federally listed threatened or endangered species. Management Policies (NPS 2006) 

calls for an analysis of impacts to state-listed threatened or endangered species 

and federal candidate species. Under the ESA, the NPS is mandated to promote 

the conservation of all federal threatened and endangered species and their critical 

habitats within the parks. Management Policies includes the additional stipulation 

to conserve and manage species proposed for listing. There are no threatened 

or endangered species in the area; therefore, this topic has been eliminated from 

analysis.

Wildlife NEPA calls for examination of the impacts on the components of affected 

ecosystems, including terrestrial and aquatic wildlife and fish. NPS policy 

is to protect the natural abundance and diversity of park native species and 

communities, including avoiding, minimizing, or mitigating potential impacts from 

proposed projects. Although potential future actions could have a minor effect on 

wildlife from disturbance associated with rehabilitation, construction, or visitor 

use, these site specific impacts are currently unknown and would undergo future 

environmental analysis. Therefore this topic has been dismissed from further 

analysis.

Air Quality Under the Clean Air Act (CAA) (42 USC 7401 et seq.), no air quality designation is 

associated with the Honouliuli site. If national park unit designation occurred it is 

likely that the areas would fall under the Class II designation. Class II areas allow 

only moderate increases in certain air pollutants, while Class I areas (primarily large 

national parks and wilderness areas) are afforded the highest degree of protection. 

While negligible to minor effects could occur if a site was designated, these impacts 

would be undetectable because of the location of the site in suburban areas 

currently affected by vehicular, agricultural and other air quality impacts.

Geological / 

Paleontological 

Resources

Management Policies (NPS 2006) calls for analysis of geology and geological 

hazards should they be relevant. Geological resources, including paleontological 

resources (fossils; both organic and mineralized remains in body or trace form) will 

be protected, preserved, and managed for public education, interpretation, and 

scientific research (NPS 2006). Because there are no major geological resources 

associated with the site, this topic has been dismissed from further analysis.
134 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Table 7-2: Impact Topics Dismissed

Impact Topic 

Dismissed

Discussion and Rationale 

Floodplains Floodplains are areas of low-lying land that are subject to inundation by the lateral 

overflow of waters from rivers or lakes with which they are associated. EO 11988 

(Floodplain Management) requires an examination of impacts to floodplains, 

including the potential risk involved in placing facilities within floodplains. It states 

that federal agencies must:

...take action to reduce the risk of flood loss, to minimize the impact of floods on 

human safety, health and welfare, and to restore and preserve the natural and 

beneficial values served by floodplains...

Accordingly, agencies must determine whether a proposed action is located in or 

would impact the 100-year floodplain. The 100-year floodplain is designated by the 

Federal Emergency Management Agency (FEMA) as those low-lying areas that are 

subject to inundation by a 100-year flood (i.e., a flood that has a one percent chance 

of being equaled or exceeded in any given year). Because, according to initial 

investigations, no areas of existing development at the sites are within the 100-year 

floodplain, this topic has been dismissed from further environmental analysis. 

The Honouliuli Gulch lies in a “D Zone” which corresponds to unstudied 

areas where flood hazards are undetermined but are possible. Given that the 

predominant morphological land feature is, essentially, a drainage coming off of 

the Waianae Range, it is very likely that intermittent flooding occurs, even to the 

point of threatening structures and other features. Specific proposed placement of 

facilities in the floodplain are not within the scope of this study, therefore this topic 

is dismissed from further analysis.

Wetlands EO 11990 Protection of Wetlands requires federal agencies to avoid, where possible, 

adversely impacting wetlands. In addition, §404 of the CWA authorizes the ACOE 

to prohibit or regulate, through a permitting process, discharge or dredged or fill 

material or excavation within waters of the United States. 

The ACOE identifies three criteria for the identification of wetlands including 

hydrophytic vegetation, hydric soil, and positive indicators of wetland hydrology 

(ACOE 1987). The ACOE and EPA jointly define wetlands (under their 

administration of the CWA) as: 

Those areas that are inundated or saturated by surface or groundwater at a frequency 

and duration sufficient to support, and that under normal circumstances do support, a 

prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands 

generally include swamps, marshes, bogs and similar areas (33 CFR 3 § 328.3, 2004).

DO 77-1: Wetland Protection requires that the NPS use the Classification of Wetlands 

and Deepwater Habitats of the United States (Cowardin et al. 1979) as the standard 

for defining, classifying, and inventorying wetlands. This system generally requires 

that a positive indicator of wetlands be present for only one of the indicators 

(vegetation, soils, or hydrology) rather than for all three parameters as mandated by 

ACOE and EPA. As with the ACOE, NPS policies for wetlands protection require a 

Statement of Findings for proposed actions that have the potential to adversely affect 

0.10 acre or more of wetlands. As stated in Management Policies (NPS 2006) and 

DO 77-1 Wetlands Protection, strive to prevent the loss or degradation of wetlands 

and to preserve and enhance the natural and beneficial values of wetlands. Because, 

according to initial investigations, no areas of existing development at the sites 

contain wetlands, this topic has been dismissed from additional environmental 

analysis.
 Chapter 7: Environmental Consequences  Impact Topics 135

Table 7-2: Impact Topics Dismissed

Impact Topic 

Dismissed

Discussion and Rationale 

Ethnography / 

Traditional Cultural 

Resources 

Analysis of impacts to known ethnographic resources is important under the 

NHPA and other laws. The NPS defines ethnographic resources as any “site, 

structure, object, landscape, or natural resource feature assigned traditional 

legendary, religious, subsistence, or other significance in the cultural system of a 

group traditionally associated with it” (DO-28, Cultural Resource Management 

Guideline:181). 

Traditional Cultural Properties or other sites are associated with the cultural 

practices and beliefs of a living community that are rooted in that community’s 

history and are important in maintaining the continuing cultural identity of the 

community. No traditional cultural properties or ethnographic resources associated 

with the sites have been identified to date. Therefore this topic has been dismissed 

from additional environmental analysis. If, at a later date, ethnographic resource 

concerns were identified from ongoing consultation with individuals and groups 

associated with the internment sites in Hawai‘i and Native Hawaiians, these would 

be investigated further to avoid impacts.

Soundscape In accordance with Management Policies (NPS 2006) and DO 47 Sound Preservation 

and Noise Management, an important component of the NPS mission is the 

preservation of natural soundscapes associated with national park units. No 

impacts to soundscapes have been identified from the alternatives; therefore this 

impact topic has been dismissed from further environmental analysis.

Wilderness NPS wilderness management policies are based on provisions of the 1916 NPS 

Organic Act, the 1964 Wilderness Act, and legislation establishing individual 

units of the national park system. These policies establish consistent service-wide 

direction for the preservation, management, and use of wilderness and prohibit the 

construction of roads, buildings, and other man-made improvements and the use 

of mechanized transportation in wilderness. All management activities proposed 

within wilderness are subject to review following the minimum requirement 

concept and decision guidelines. The public purpose of wilderness in national parks 

includes the preservation of wilderness character and wilderness resources in an 

unimpaired condition, as well as for the purposes of recreational, scenic, scientific, 

education, conservation, and historical use. Because there is no wilderness in 

or associated with the proposed site, there would be no impacts to wilderness. 

Therefore this topic has been dismissed from additional environmental analysis.

Human Health and 

Safety / Hazardous 

Materials

Management Policies (NPS 2006) states that the NPS and its concessioners, 

contractors, and cooperators will seek to provide a safe and healthful environment 

for visitors and employees. Inherent risks associated with visiting or working in 

this site relate to its tropical location, its dry environment,vegetation, and relative 

isolation. Surrounding agricultural uses and nearby water pumping facilities present 

an undetermined level of risk. If an NPS unit were later established, NPS standard 

safety policies and guidelines would be employed and would be used to minimize 

risk. Because no specific risks associated with the proposed alternatives that have 

been identified, this topic has been dismissed from additional environmental 

analysis.

Energy Consumption Except as associated with travel to the site, implementation of the proposed actions 

would not cause substantial increases or decreases in the overall consumption of 

electricity, propane, wood, fuel oil, gas, or diesel. As a result, energy consumption 

has been dismissed from additional analysis.
136 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Table 7-2: Impact Topics Dismissed

Impact Topic 

Dismissed

Discussion and Rationale 

Lightscapes In accordance with Management Policies (NPS 2006), the NPS strives to preserve 

natural ambient lightscapes, which are natural resources and values that exist 

in the absence of human-caused light. No impacts on natural lightscapes have 

been identified as a result of the actions proposed in the alternatives. Therefore, 

lightscapes, or night sky, will not be addressed further as an impact topic.

Wild and Scenic Rivers Under the Wild and Scenic Rivers Act (16 U.S.C. 1271-1287), “...certain 

selected rivers of the Nation, which with their immediate environments, possess 

outstandingly remarkable scenic, recreational, geologic, fish and wildlife, historic, 

cultural, or other similar values, shall be preserved in free-flowing condition, and 

that they and their immediate environments shall be protected for the benefit 

and enjoyment of present and future generations.” There are no wild and scenic 

rivers in or proposed within any of the sites; therefore this impact topic has been 

dismissed from further analysis.

Environmental Justice EO 12898 requires all federal agencies to incorporate environmental justice into 

their missions by identifying and addressing disproportionately high and adverse 

human health or environmental effects of their programs and policies on minorities 

and low-income populations and communities. The actions evaluated in this EA 

would not adversely affect socially or economically disadvantaged populations. 

There would be no disproportionately high and adverse human health or 

environmental effects on minorities or low-income populations or communities. 

Potential beneficial effects to these communities, however, are discussed within the 

Socioeconomics section. Proposed actions would not exclude or separate minority 

or low-income populations from the broader community or disrupt community 

cohesiveness and economic vitality. Therefore, environmental justice has been 

dismissed from additional analysis.

Indian Trust Resources Indian trust assets are owned by Native Americans but held in trust by the United 

States. Secretarial Order 3175 (“Identification, Conservation and Protection of 

Indian Trust Assets”) requires that any anticipated impacts to Indian trust resources 

due to a proposed project or action by agencies within the Department of the 

Interior be explicitly addressed in environmental documents. The federal Indian 

trust responsibility is a legally enforceable fiduciary obligation on the part of the 

United States to protect tribal lands, assets, resources, and treaty rights, and it 

represents a duty to carry out the mandates of federal law with respect to American 

Indian and Alaska Native tribes. The sites does not hold or contain areas that are 

held in trust by the Secretary of the Interior for the benefit of Indians due to their 

status as Indians, therefore this topic was dismissed from detailed analysis.

Public Health and Safety Implementation of some of the proposed actions could potentially benefit public 

health. The alternatives would preserve open space which would contribute to 

improved health and recreational opportunities. The benefits to public health and 

safety would be undetermined, however, and therefore have been dismissed from 

further analysis.
 Chapter 7: Environmental Consequences  Land Use 137

Table 7-2: Impact Topics Dismissed

Impact Topic 

Dismissed

Discussion and Rationale 

Climate Change and 

Sustainability

The long-term effects of global climate change are uncertain; however it is clear 

that the Earth is experiencing a warming trend that affects ocean currents, sea 

levels, polar sea ice, and global weather patterns. Although these changes may affect 

precipitation patterns and amounts in Hawaiʻi, it would be speculative to predict 

localized changes in temperature, precipitation, or other weather changes, in part 

because there are many variables that are not fully understood and there may be 

variables not currently defined. Analysis of the degree to which effects may occur 

over the timeframe of this plan would be speculative and would not change actions 

associated with the alternatives. Therefore the effects of future climate change or 

speculation about changes that would occur are not discussed further.

Soils Management Policies (NPS 2006) require that the NPS understand and preserve, 

and prevent, to the extent possible, the unnatural erosion, physical removal, or 

contamination of the soil. Although potential future actions could have a minor 

effect on soils from disturbance associated with rehabilitation or construction, 

these site specific impacts are currently unknown and would undergo future 

environmental analysis. Therefore this topic has been dismissed from further 

analysis.

Land Use

Honouliuli Gulch is in the Kunia area of 

central O‘ahu, approximately 15 miles west 

of Honolulu, north of the H-1 Freeway and 

west of Kunia Road. Current and potential 

infrastructure (access roads being investigated 

for inclusion in the potential park unit) are 

located on three additional parcels to the 

southwest of the property owned by the 

University of Hawaiʻi (See Map, Chapter 

5: Ownership and Land Use–Honouliuli 

Internment Camp) and are agricultural land 

either actively farmed or fallow. The current 

land owners purchased the property from the 

James Campbell Company in 2007. Because 

of the steep topography along the edges of the 

Honouliuli Gulch, it was not used for sugar cane 

or pineapple cultivation. However, starting in 

1958, portions of uncultivated land in the gulch 

were leased for a cattle ranching operation.

The aggregate parcels owned by the Monsanto 

Company constitute Monsanto’s “Kunia Farm” 

and are mostly dedicated to growing seed corn 

and other crops. Some areas are currently 

fallow while other areas are covered by thick 

vegetation (grasses, mostly guinea grass). Only 

a small portion of the subject property (7-acre 

parcel) is outside of the gulch and in cultivation. 

At present, the Honouliuli Gulch is mostly 

overgrown with grasses and brush. Vegetation 

is routinely cut around some remnant historical 

features of the former internment camp. Several 

years ago, the Japanese Cultural Center of 

Hawaiʻi (JCCH) started offering guided tours 

of the former internment camp, and has been 

cutting vegetation to provide access for the 

tours. 

Other uses of the area include three small 

parcels owned by the City and County of 

Honolulu Board of Water Supply (BWS) that 

house municipal water supply wells (Honouliuli 

II-1, II-2, and II-3), a concrete control building, 

and a water treatment plant within the fenced 

area at the Honouliuli II-1 well site. These 

parcels are currently fenced and maintained 

by BWS. There is a recently paved access road 

entering the gulch from the east side of the 

subject property. Large satellite dishes owned by 

the KITV television station have been installed 

on the slope of the gulch, near the access road, 

in the southern part of the gulch. The remnant 

structures within the gulch associated with the 

former internment camp consist primarily of 

building foundations, rock walls, and fence 

remnants.

Parcels owned by the Monsanto Company 

surround Honouliuli Gulch to the northwest, 

north, and east, while parcels owned by the 
138 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

University of Hawaiʻi bound it to the south 

and southwest. These agricultural lands are 

either actively cultivated or fallow. The nearest 

residential development to the subject property 

is located east of Kunia Road at a distance of 

approximately 1 mile, and south of highway H-1 

at a distance of approximately 1 mile.

Within the extent of Monsanto Parcel 1, east of 

the subject property, there are three additional 

parcels owned by BWS, and one small parcel 

owned by Hawaiian Electric. BWS operates 

two municipal water supply wells (Honouliuli 

I-1 and I-2) on its parcels, located just east of 

the access gate to the gulch access road, where 

Hawaiian Electric operates a substation. BWS 

wells were completed between 1986 and 1989. 

BWS also operates two water reservoirs near the 

southernmost corner of the subject property, 

near the H-1 Freeway (Honouliuli 228). Both 

BWS and Hawaiian Electric hold easements 

on Monsanto Parcel 1 to allow access to their 

properties.

Agricultural (i.e., ‘cane haul’) roads exist 

throughout the area and, in some cases, 

terminable rights of access are associated with 

certain parcels. 

PRIME AND UNIQUE FARMLAND

Based on the ALISH (Agricultural Lands 

of Importance to the State of Hawaiʻi) 

classification system, most areas within the 

historic internment camp, as defined by the 

National Register of Historic Places, are not 

considered prime or unique farmland. Only two 

small areas, one in the far north of the historic 

site, and one in the far east near the current 

entry road, are classified as prime farmland. 

No lands are classified as unique farmland. 

These two areas are owned by the Monsanto 

Company, but are currently fallow. Areas 

to the west of the historic site owned by the 

University of Hawaiʻi, and the 7-acre overlook 

parcel owned by the Monsanto Company are 

classified as prime farmland. The 7-acre site is 

currently fallow. However, most of the UHWO 

lands are under cultivation (see Map: Prime and 

Unique Farmland). The University of Hawai‘i 

is currently working on a strategic land use 

plan that will determine the future use of these 

agricultural lands which could include either 

university or non-university related land uses. 

IMPACTS OF ALTERNATIVE A

There would be no changes in land 

ownership, occupancy, or use as a result of 

implementation of this alternative. Sites, 

organizations, and programs significant to 

the internment in Hawai‘i would continue to 

operate independently. Honouliuli Gulch is 

not managed to provide visitor opportunities—

although intermittent controlled access by 

interested agencies and organizations would 

continue to be expected. 

To the immediate west of the Honouliuli Gulch 

is a large (over 900 acres) parcel owned by the 

University of Hawaiʻi—West O‘ahu (referred 

to as the Mauka property). The University of 

Hawaiʻi has designated approximately 294 

acres within the Mauka property (the area 

nearest to the H-1 Freeway) for future campus 

expansion or University-related development 

(including scientific and research activities), 

as required under the land transfer agreement 

with the Estate of James Campbell. A land 

use plan and campus plan have not yet been 

completed for the Mauka property and, once 

completed, will guide the development of this 

property. The University of Hawaiʻi has issued 

agriculture permits for grazing and cultivation 

on the Mauka parcel. The 294 acres could be 

developed and characteristics that identify it 

with the Japanese American internment history 

could be modified or lost. This could result 

in moderate to major adverse impacts. Direct 

effects to prime farmland adjacent to Honouliuli 

Internment Camp would be dependent on 

future use of the land as determined by the 

University of Hawai‘i in its strategic land 

planning process. Occasional use of Honouliuli 

Gulch for interpretive tours and research as 

permitted by the current landowner would have 

no direct effects on prime farmland.

Except for other sites in Hawaiʻi already 

listed on local or national historic registers 

(for example Kilauea Military Camp in 

Hawaiʻi Volcanoes National Park and the U.S. 

Immigration Station in Honolulu), there may 

be no coordination related to preservation of 

the internment of Japanese Americans and 

European Americans. Over time, there could be 

systematic loss of this and related sites, where 

not already protected by private or municipal 

preservation organizations, and a long-term 

indirect minor to moderate adverse effect could 
 Chapter 7: Environmental Consequences  Land Use 139
140 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

occur because there would be no effort made 

to link these sites as part of a group, potentially 

leading to less collective desire for protection. 

Pending continued protection of sites 

designated or eligible as NHLs or listed in the 

National Register of Historic Places (NRHP), 

effects would remain moderate.

IMPACTS OF ALTERNATIVE B 

(PREFERRED ALTERNATIVE)

Designation of Honouliuli Internment Camp 

as a national historic site would be coordinated 

with national, regional and local organizations. 

The site would be owned and managed by the 

National Park Service. Possible changes to 

zoning could occur through City and County 

of Honolulu (and adjacent landowner) land 

use plans to reflect the historic preservation of 

Honouliuli Gulch and visitor uses. Similarly, 

land use or management plans for the remaining 

sites within the network of internment locations 

in Hawaiʻi may be modified to preserve, protect 

and/or recognize the historic significance of 

these areas. 

Long-term beneficial effects and additional 

localized preservation initiatives could result 

from recognizing the Honouliuli Gulch site 

as part of a network of broader Hawaiian 

sites related to World War II and internment 

history. Recognition would result in longterm beneficial effects on protection of the 

Honouliuli Gulch site, and potentially the 

other locales. NPS technical assistance and 

applicable historic preservation grants could 

be used to preserve these other internment 

sites where current owners/managers do not 

have the resources to showcase its significance, 

resulting in long-term beneficial effects on 

land use from historic preservation efforts and 

new opportunities to provide visitors with a 

better understanding of the importance of the 

site. There could be better protection of the 

Honouliuli Internment Camp cultural landscape 

and increased use by visitors.

Coordination with the University of Hawaiʻi 

provides the opportunity to share and 

provide physical, educational, and interpretive 

resources. Depending on the extent of future 

anticipated visitor use, there could be changes 

to the UHWO regional plan to enhance aspects 

of the University of Hawaiʻi—West O‘ahu 

campus and agricultural fields adjacent to 

Honouliuli Gulch for visitors if Honouliuli 

Gulch were to be designated a unit of the 

national park system. Direct effects to prime 

farmland could result from road improvements 

required for visitor access. The extent of such 

effects would need to be reassessed should the 

University of Hawai‘i’s strategic land planning 

process identify future activities and uses other 

than agriculture for these parcels.

MEASURES TO AVOID, MINIMIZE OR 

MITIGATE IMPACTS

Development of visitor-related (and some 

administrative) infrastructure would be 

limited within the boundary of the Honouliuli 

Internment Camp National Register 

property due to infrastructure capacity and 

environmental constraints. Likely support for 

visitor facilities would be in the vicinity of the 

UHWO campus to take advantage of existing 

development plans and more easily manage 

access methods (i.e., shuttle buses). The 7-acre 

parcel adjacent to the Honouliuli Gulch area is 

an agricultural field under recent cultivation. 

This site could be an appropriate location for 

limited visitor transition facilities (i.e. limited 

parking, interpretive wayside exhibits, shade 

structures, vault toilets) that require no new 

utilities. 

Initial plans for access into the Honouliuli 

Gulch area would require rights of access from 

UHWO and coordination with neighboring 

agricultural operations. 

CUMULATIVE EFFECTS

Under alternatives A and B, there could be 

cumulative impacts on land use resulting 

from the campus development on the UHWO 

lands to the west of Honouliuli Gulch and 

construction of the Honolulu rail line. Impacts 

would largely be associated with developing 

agricultural lands, which was the historic setting 

for Honouliuli Internment Camp. However, 

this development could also support increased 

visitation to the Honouliuli site which would 

result in greater public understanding about the 

internment history. 

Alternative B would have increasing levels 

of beneficial cumulative effects on land use 

for agricultural purposes. For example, rezoning of the surrounding agricultural lands 

for activities other than agriculture may have a 
 Chapter 7: Environmental Consequences  Water Resources 141

negative impact on the preservation of cultural 

resource values (i.e., diminished viewsheds). 

Alternative B would support continued use of 

the agricultural zoning as a method to promote 

open space and a more ‘historic’ land use 

pattern that sets the context for Honouliuli 

Gulch. Honouliuli Gulch, by virtue of its 

location in an ‘out of sight’ drainage surrounded 

by agricultural lands, became a remote and 

inaccessible place—precisely fitting the 

perceived need to keep internees away from the 

rest of the O‘ahu Japanese American population 

(and vice versa). 

CONCLUSION

Alternative A would have no direct effects on 

land use, but lack of a specific preservation 

direction for Honouliuli Gulch could result in 

incremental changes to use of the agricultural 

lands surrounding the gulch, resulting in longterm moderate to major adverse impacts to the 

Honouliuli Internment Camp.

Alternative B would have long-term beneficial 

effects from linking the site and resultant 

preservation initiatives to the National Park 

Service. With a reliance on ‘offsite’ visitor 

contact infrastructure (in the vicinity of 

UHWO), and utilization of existing roads, 

visitor impacts to existing agricultural 

operations surrounding Honouliuli Gulch 

would be limited. Impacts to UHWO’s parcels 

in the immediate vicinity of the Honouliuli 

Gulch area would need to be reassessed should 

the university’s planning process identify an 

activity other than agriculture for these parcels. 

Water Resources

Honouliuli Gulch is a riparian corridor running 

between Pearl Harbor’s West Loch and the 

Waianae Range with an ephemeral stream. 

The elevation of Honouliuli Gulch ranges 

from approximately 600 feet above mean sea 

level at the north to 220 feet above mean sea 

level at the south. The gulch is about 500 to 

700 feet wide with steep slopes; the depth 

of the gulch floor below the gently sloping 

adjacent land is approximately 70 to 100 ft. 

There are no permanent streams within the 

subject property or adjacent parcels. However, 

following heavy precipitation on the Waianae 

mountain range and the Kunia area, surface 

water drains through the gulch, forming 

the ephemeral Honouliuli Stream. At the 

northern end of the gulch, the U.S. Geological 

Survey (USGS) maintains a stream flow gauge 

(station number 16212480 Honouliuli Stream 

Tributary). To the north of the gulch, Reservoir 

#155 receives water from Waiahole Ditch, the 

primary irrigation water source to the area. The 

Waiahole Ditch originates on the windward 

side of O‘ahu and terminates just north of the 

subject property, on Monsanto’s parcel 9-2-001-

001. Historically, water from the Waiahole Ditch 

was transported through the subject property 

by way of an aqueduct and siphon (pipeline) 

system. Topography of the land surrounding 

the gulch is gently sloping towards the southsoutheast towards Pearl Harbor’s West Loch 

area. Elevation and water features are identified 

on the Map: Water Resources.

The Hawai‘i State Department of Health 

has required recordation of a Declaration of 

Restrictive Covenants (Domestic Waste Water 

Treatment and Disposal) in connection with the 

Monsanto Company’s actions to subdivide the 

property. 

IMPACTS OF ALTERNATIVE A

There would be no known changes to water 

resources as a result of implementation of this 

alternative. Because no changes would occur in 

management of the existing site, there would be 

no new impacts to water resources.

IMPACTS OF ALTERNATIVE B

Although modifications could be made to 

accommodate visitor parking and walking trails 

through the gulch, the known water resources 

located at this site (i.e. ground water pumping 

station used to support existing Bureau of Water 

Supply operations, the ephemeral stream, the 

USGS Water Gauge) would not be adversely 

impacted. 

If Honouliuli Internment Camp was to be 

designated a National Park Service site, there 

would eventually be minor impacts to water 

resources if modifications to the drainage 

were made. Among the modifications that 

could be considered would be small bridges 

(similar to the six small bridges used during the 

confinement period) or box culvert to avoid 

impacting the stream crossing from repeated 

vehicle crossings of the creek during ephemeral 

flows. At other times of the year, this area is a 

dry wash. 
142 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 
 Chapter 7: Environmental Consequences  Biological Resources 143

A vegetation management plan would be 

expected to be developed, potentially impacting 

the use of groundwater by large woody plants in 

the gulch. The reduction of this vegetation may 

result in more regular flows and longer periods 

of groundwater presence in the stream. 

Long-term beneficial effects on hydrology 

and water quality could occur over time 

by improved attention to the existing 

(and potential) infrastructure and relative 

geomorphological impacts to the ephemeral 

stream. Construction would have short-term 

minor adverse impacts from the potential for 

sedimentation from excavation around the 

stream channel for placement of infrastructure 

improvements.

MEASURES TO AVOID, MINIMIZE OR 

MITIGATE IMPACTS

Measures that would be included to minimize 

impacts to water resources include the 

utilization of best management practices 

associated with near stream activities (i.e., 

barriers to prevent sedimentation of streams, 

erosion prevention measures, etc.). Limited data 

from the USGS water gauge shows that water 

flow in the ephemeral stream occurs in the form 

of flash floods with fast draw down periods. 

There do not appear to be regular ‘seasons’ 

of high/low flow in the stream, although it 

is expected that the wet season period will 

likely result in the more consistent flows (i.e., 

November through April). 

The National Park Service would ensure that 

wastewater facilities improvements would not 

impact groundwater resources presently utilized 

by the Board of Water Supply. There are no 

water waste systems currently in place in the 

gulch. If the site were designated a unit of the 

national park system, to the extent possible, 

such facilities would be located outside of 

Honouliuli Gulch in the vicinity of the overlook 

parcel and would be consistent with the 

Department of Health covenant associated with 

the property. 

CUMULATIVE EFFECTS

Because Honouliuli Internment Camp is 

located in an agricultural area it is likely that 

these actions will contribute negligible to 

minor adverse effects during runoff to area 

water quality. Because there would be no 

direct actions associated with alternative A, 

there would be no contribution to cumulative 

impacts. Alternative B likely contributes 

negligible to moderate localized adverse impacts 

as a result of increased visitation over alternative 

A because of the stream crossing, if deemed 

necessary for access into the gulch. 

CONCLUSION

Alternative A would have no direct effects 

and ongoing minor adverse effects on water 

resources. Alternative B would have initial, 

primarily short-term, negligible to moderate 

adverse effects followed by long-term beneficial 

effects on water resources. 

Biological Resources

VEGETATION (INCLUDING NONNATIVE 

SPECIES)

The entire site was cleared for the construction 

of the internment and POW camp in 1943. Prior 

to use as an internment site, the gulch supported 

ranching activities and irrigation infrastructure 

development. Existing vegetation represents 

over half a century’s growth of mostly 

introduced vegetation. 

Much of the Honouliuli Gulch area is 

overgrown with vegetation, most notably 

invasive species such as guinea grass (Panicum 

maximum) and haole koa (Leucaena sp.), with 

Chinese banyan trees (Ficus microcarpa) near 

the creek drainage that runs north to south 

through roughly the center of the gulch. Other 

species observed at the site include sandalwood 

(Santalum ellipticum), monkeypod (Samanea

sp.), sisal (Agave sisalana), mock orange 

(Murraya paniculata), allamanda (Allamanda 

cathartica), wild bitter melon (Momordica 

charantia), and kukui (Aleurites moluccana). 

After discussion with the U.S. Fish and Wildlife 

Service, a determination was made that there 

were no listed species present in the vicinity 

of the Honouliuli Gulch, so the NPS decided 

to dismiss threatened and endangered species 

from further consideration. 

Impacts of Alternative A

Where bare ground exists there would continue 

to be the potential for colonization by nonnative 

invasive plants, a long-term minor impact that 
144 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

could range to moderate associated with the 

agricultural operations in the area.

Impacts of Alternative B

Management of the cultural landscapes 

associated with the Honouliuli Internment 

Camp would undoubtedly require a vegetation 

management plan promoting reduction of 

canopy and brush. Historic period photographs 

of the gulch show an area with limited to no 

overhead vegetation and very low lying ground 

cover (grasses). It is unknown at this point 

what impact a vegetation management program 

would have on native flora and fauna habitat, 

however, through a continued presence by the 

National Park Service, greater attention to, 

and awareness of, the vegetation and wildlife 

resources in Honouliuli would exist. 

A vegetation management plan may result in 

moderate adverse effects on native vegetation 

if that plan emphasized brush and canopy 

reduction and if there were strong assemblages 

of native vegetation reliant on brush and canopy 

plants. Similarly, because the site ecosystem is 

located in an area that has been largely modified 

by the presence of roads, buildings, structures, 

utilities, and other facilities associated with 

agricultural activity and water resource use, very 

little native wildlife habitat exists. 

Alternative B anticipates visitor access and 

would therefore require infrastructure 

support outside of the gulch, and some level 

of vegetation management inside the gulch. 

Impacts to native and nonnative flora and fauna 

would also be limited and would primarily have 

minor to moderate short-term adverse impacts 

from disturbance. Long-term minor adverse 

impacts, such as from removal of nonnative 

vegetation, could also occur as landscape plans 

are implemented and native plants impacted. 

The extent of the native plant community in the 

gulch is not clearly understood at this time. 

Although native vegetation could be used in 

future landscaping efforts, it is likely that the site 

would continue to be comprised primarily—

though at a significantly lower level—of 

nonnative landscaping that is true to its historic 

period of significance. This would include 

eliminating large nonnative trees and shrubs 

as senescence or die-off occurred or through 

active removal. 

Summer archeological field school, Honouliuli. Photo: Jeffery Burton.
 Chapter 7: Environmental Consequences  Cultural Resources 145

Measures to Avoid, Minimize, or 

Mitigate Impacts

With a proposed active NPS management role 

in alternative B, Honouliuli Gulch would be 

monitored for protected species and noxious 

species. These two categories of flora and fauna 

would be managed in keeping with the guidance 

identified in NPS Management Policies 2006 

and under laws and policies regulating federal 

management of these resources. 

Cumulative Effects

Alternative A would have no new effects and 

no new contributions to cumulative effects. 

Ongoing cumulative effects would continue to 

be present from existing development. Overall 

cumulative effects would remain moderate to 

major from previous alteration of vegetation 

and wildlife habitat and presence at these sites. 

Alternative B would have minor to moderate 

cumulative adverse effects from vegetation 

management activities needed to preserve the 

historic landscape features (irrigation ditches, 

concrete slabs, pier footings, etc.), as well as 

historic viewsheds documented in period 

photographs. The likely removal of extensive 

portions of the (primarily nonnative) vegetation 

will impact the existing flora and fauna habitats 

found in Honouliuli Gulch. A vegetation 

management plan (as a component of a cultural 

landscape report) would need to be developed 

under alternative B and would require further 

environmental compliance review and include 

a more in-depth survey of biological resources 

and potential impacts. 

Conclusion

Alternative A would have negligible to minor 

short-term adverse effects on native vegetation 

and wildlife. Alternative B would likely 

have minor to moderate, primarily shortterm adverse impacts on existing biological 

resources, with further refinement of this 

conclusion through steps such as developing 

a cultural landscape report, conducting 

vegetation surveys, and/or preparing a 

vegetation management plan. 

Cultural Resources

This section includes the assessment of effects 

to prehistoric and historic archeology, historic 

structures, cultural landscapes, and museum 

collections. 

The Honouliuli Internment Camp is listed 

in the National Register of Historic Places 

and is nationally significant under criteria A 

—the property is associated with events that 

have made a significant contribution to the 

broad patterns of our history, and criteria D 

—the property has yielded, or is likely to yield 

information important in prehistory or history. 

Other sites that were found to be nationally 

significant and retain a high degree of integrity 

include the U.S. Immigration Station, currently 

listed in the National Register of Historic Places 

and Kilauea Military Camp, eligible to be listed 

in the National Register of Historic Places.

For detailed descriptions of the cultural 

resources see Chapters 2 and 3. 

Assessment of effects to cultural resources 

includes the use of determinations as defined 

in Section 106 of the National Historic 

Preservation Act. Table 7-3 is a crosswalk of the 

NEPA effects with the Section 106 effects.
146 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

ARCHEOLOGY

This section refers to both prehistoric and 

historic archeological resources. Much of the 

archeological resources that remain and have 

been studied at Honouliuli are historic. More 

research is needed to better understand the 

extent of the prehistoric resources within the 

Honouliuli Gulch.

Development related to Honouliuli Internment 

Camp occurred prior to the advent of or 

just as cultural and archeological resources 

protection laws and guidelines were instituted. 

As a result, it is both unknown and unlikely 

that archeological resources were surveyed for 

during development of the internment camp. 

Systematic archeological surveys and research at 

the Honouliuli Internment Camp were initiated 

in 2006. This effort is being coordinated by 

UHWO and JCCH. Archeological resources at 

Honouliuli are described in detail in Chapters 2 

and 3.

Impacts of Alternative A 

Under alternative A, there would be no 

anticipated new actions that would affect 

prehistoric or historic archeological resources. 

Although no new actions would occur, use 

of the site by current landowners could 

have the potential for ground disturbance 

and consequent impacts to archeological 

resources, particularly where some remnant 

native vegetation and soils exist. Therefore, 

although no new actions are proposed, current 

landowners could continue to modify areas 

under their control and could affect known 

and previously undiscovered archeological 

resources. Depending on the significance 

of these and the extent of disturbance, this 

Table 7-3: Crosswalk for NEPA and Section 106 Effects

NEPA Section 106 Description

Negligible to Minor No Effect A determination of no historic properties affected means that 

either there are no historic properties present or there are historic 

properties present in the area of potential effects (APE) but the 

undertaking will have no effect upon them (36 CFR 800.4(d)(1)).

Minor to Moderate No Adverse Effect A determination of no adverse effect means there is an effect, but 

the effect would not meet the criteria of an adverse effect [36 CFR 

Part 800.5(a) (1)], i.e. diminish the characteristics of the cultural 

resource that qualify it for inclusion in the National Register (36 

CFR 800.5(b)). In addition, the undertaking may start out as an 

adverse impact but may be mitigated in design, or is modified, 

reduced, and/or avoided such that it no longer would produce an 

adverse effect on historic resources. This category of effects may 

have effects that are considered beneficial under NEPA, such as 

restoration, stabilization, rehabilitation, and preservation projects. 

Major Adverse Effect An adverse effect occurs whenever an impact alters, directly or 

indirectly, any characteristic of a cultural resource that qualifies it 

for inclusion in the National Register, e.g. diminishing the integrity 

(or the extent to which a resource retains its historic appearance) 

of its location, design, setting, materials, workmanship, feeling, or 

association. Adverse effects also include reasonably foreseeable 

effects caused by the alternatives that would occur later in time, 

be farther removed in distance or be cumulative (36 CFR 800.5(a) 

(1)). An adverse effect may be resolved in accordance with the 

2008 Programmatic Agreement, or by developing a memorandum 

or program agreement in consultation with the SHPO, ACHP, 

American Indian tribes, other consulting parties, and the public 

to avoid, minimize, or mitigate the adverse effects (36 CFR Part 

800.6(a)). 
 Chapter 7: Environmental Consequences  Cultural Resources 147

could be a negligible to major adverse effect. 

Additionally, lack of preservation management 

of the archeological resources could result in 

erosion or natural disturbances. Archeological 

resources could also continue to receive 

some beneficial effects from zoning, historic 

preservation, and landowner stewardship. 

Under Section 106, alternative A would have no 

effect to adverse effect.

Impacts of Alternative B

Under alternative B, impacts to known and 

undiscovered archeological resources would 

be negligible to minor given that the intent of 

managing the site as a national park unit would 

be to preserve the cultural resources present. 

Development of some areas within the site to 

accommodate visitors, including placement 

of navigational and interpretive signs could 

have minor adverse effects from disturbance of 

archeological resources. Federal preservation 

laws would require the assessment of any areas 

proposed for disturbance and subsequent 

planning efforts to avoid or minimize impacts to 

cultural resources. Overall effects would likely 

be minor and under Section 106 would have 

no effect or no adverse effect on archeological 

resources. Beneficial effects could also 

occur from additional survey, research, and 

documentation of new archeological sites. 

In addition, enhanced NPS involvement at 

Honouliuli could result in additional staffing 

and funding to protect archeological resources, 

a long-term beneficial effect. 

Measures to Avoid, Minimize or 

Mitigate Impacts

Measures to minimize impacts to prehistoric 

and historic archeological resources would 

include:

ŐLocation of primary visitor and operational 

facilities outside of the historic camp 

boundary.

ŐSurvey of project areas by a professional 

archeologist for prehistoric and historic 

cultural remains.

Immediate work stoppage and/or relocation 

to a non-sensitive area would occur should 

unknown archeological resources be uncovered 

during ground disturbing projects at the site. 

The site would be secured and consultation with 

the Hawaiʻi State Historic Preservation Officer 

would occur to determine appropriate actions 

to be taken. 

Cumulative Effects

Archeological resources within the Honouliuli 

Internment Camp may have been previously 

disturbed to varying degrees from past 

disturbances including pre-World War II 

agricultural practices, the development of the 

internment camp, erosion, and other natural 

processes. Because mitigation measures 

would be employed to minimize impacts to 

potentially unidentified cultural resources 

in other proposed and future projects, it is 

likely that these would protect archeological 

resources from additional impacts. There would 

be no construction-related contributions to 

cumulative impacts from new actions proposed 

under alternative A; ongoing impacts from 

landowner actions, however, could continue 

to occur. It is unknown whether there would 

be contributions to cumulative impacts on 

resources from proposed actions that would 

be implemented by others as identified in 

the vicinity of the sites. It is likely that under 

alternative B, if archeological remains were 

inadvertently discovered during construction, 

these alternatives could contribute additional 

negligible to minor adverse impacts which 

would be mitigated by additional investigation 

of the find immediately upon discovery or 

relocation of the work to a non-sensitive area.

Conclusion

Under alternative A, if the site continued to be 

undeveloped, there would be a minor long-term 

adverse effect to archeological resources from 

erosion and natural processes. If the landowner 

implemented development in the site without 

proper precautions to protect archeological 

resources, there would be a minor to major 

long-term adverse effect to the resources. Under 

Section 106, impacts could range from no 

effect to an adverse effect. Alternative B would 

include a plan for managing and preserving 

archeological resources, therefore it would have 

no effect or no adverse effect.
148 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

HISTORIC STRUCTURES / CULTURAL 

LANDSCAPES

Honouliuli Internment Camp contains over 

130 features related to the incarceration 

of American civilians, resident aliens, and 

prisoners of war during World War II. 

Contributing resources in the archeological 

site include two standing buildings, numerous 

building foundations, rock walls, fence 

remnants, artifact scatters, and other features. 

At least four of the associated sites no longer 

have extant structures that date to the events 

that occurred during their association with 

internment at Honouliuli. None of the 

associated sites are presently being managed for 

their relationship with internment. 

Impacts of Alternative A

Under alternative A, some of the structures 

at the Honouliuli Internment Camp would 

continue to receive some protection from 

landowner stewardship. Others would continue 

to be neglected. Over time, buildings and 

structures would likely be demolished or 

disappear through benign neglect. Depending 

on the significance of these structures and the 

extent of disturbance, this could be a minor 

to major adverse effect. Historic structures 

could also continue to receive some beneficial 

effects from zoning, historic preservation, and 

landowner stewardship. Under Section 106, 

alternative A would have no effect to adverse 

effect.

For other sites associated with internment 

during World War II, alternative A would 

continue existing management approaches 

taken by the variety of landowners of such 

sites. While there may be recognition of the 

historic significance of these areas, there would 

not necessarily be an overarching approach 

taken to preserve either the cultural landscape 

integrity (such as it may exist in some locations) 

or to preserve the historic structures. With 

the exception of sites under federal or state 

ownership, protection of historic structures and 

landscapes would be voluntary and dependent 

on the owners’ initiative. 

Impacts of Alternative B 

HONOULIULI

NPS management of Honouliuli Internment 

Camp would ensure that preservation laws 

and policies would be followed to protect the 

historic structures at the site. Any remaining 

historic structures would be stabilized and 

preserved to tell the story of Honouliuli. 

Likely a cultural landscape inventory or 

cultural landscape report would be conducted 

to identify Honouliuli’s cultural landscape 

characteristics and would provide preservation 

and treatment recommendations. These would 

all be beneficial to the historic structures. There 

is a minor chance that some NPS management 

efforts needed to improve the site or provide for 

visitor and staff health and safety would result in 

impacts to the historic resources. Under Section 

106, alternative B would have no effect and no 

adverse effect on historic structures.

OTHER SITES

Alternative B would allow the National Park 

Service the opportunity to provide technical 

assistance to the other associated sites for 

preservation guidance and assistance with 

nominating sites to the National Register of 

Historic Places, if warranted. However, with 

limited recognition for many of the other 

related sites, there would likely continue to be a 

wide range of effects on these sites, ranging from 

beneficial effects where they were designated on 

the NRHP (such as Kilauea Military Camp) or 

by other municipalities (such as in Līhuʻe and 

Wailuku, Maui) and protected to no effect, no 

adverse effect and adverse effects, depending on 

the disposition of the properties and the interest 

and initiative of landowners in maintaining the 

characteristics which make the sites potentially 

eligible for the NRHP. 

Cumulative Effects

Historic structures and landscape features 

within the Honouliuli Internment Camp may 

have been previously disturbed to varying 

degrees from past activity including pre-and 

post-World War II agricultural practices, 

the development of the internment camp, 

erosion, and other natural processes. Because 

mitigation measures would be employed to 

minimize impacts to known and unidentified 

cultural resources in other proposed and future 

projects, it is likely that these would protect 
 Chapter 7: Environmental Consequences  Cultural Resources 149

the historic structures from additional impacts. 

There would be no construction-related 

contributions to cumulative impacts from new 

actions proposed under alternative A; ongoing 

impacts from landowner actions however could 

continue to occur. It is unknown whether there 

would be contributions to cumulative impacts 

on resources from proposed actions that would 

be implemented by others as identified in the 

vicinity of the sites. Under alternative A, the 

cumulative impacts would be no effect and no 

adverse effect. Under alternative B, the National 

Park Service would protect and preserve any 

significant historic structures and landscape 

features. These preservation efforts would be 

beneficial and result in no effects to historic 

properties.

Conclusion 

Under Alternative A, no specific actions 

would be taken to ensure the stabilization 

or preservation of historic structures at 

Honouliuli Internment Camp. There would be 

no systematic effort to inventory or rehabilitate 

cultural landscapes. Other sites eligible for the 

NRHP could be maintained or modified and 

there could be a variety of effects, ranging from 

no effect to no adverse effect to adverse effect. 

The preservation and management of these 

sites would continue to be dependent on the 

initiative of their private landowners. 

It is likely that the U.S. Immigration Station 

and Kilauea Military Camp would continue 

to be preserved, a long-term beneficial effect. 

It is not clear whether other associated sites 

would continue to be preserved. Under 

Alternative B, Honouliuli Internment Camp 

would receive some level of appropriate funding 

for resource protection and preservation. 

Associated internment sites and groups could 

also be eligible to receive grants to promote 

stewardship, preservation, and education 

programs related to the internment story. 

MUSEUM COLLECTIONS

The current museum collections for Honouliuli 

Internment Camp include artifacts associated 

with recent archeological excavations by Burton 

and Farrell with the University of Hawaiʻi—West 

O‘ahu, oral history collections at the University 

of Hawaiʻi, the Japanese Cultural Center of 

Hawaiʻi, and other entities focused on Japanese 

internment and archival materials related to 

the design, construction, and operation of the 

camp. Other materials include the agricultural 

records for Campbell and Del Monte. 

Impacts of Alternative A

There would be no changes to museum 

collections as a result of implementation of 

alternative A. Standards of care would vary 

among organizations and individuals holding 

objects. The lack of systematic museum 

collection management could result in minor to 

moderate adverse effects to museum collections.

Impacts of Alternative B

In alternatives B, the NPS would take on an 

expanded role for conservation and protection 

of museum collections because it could, in fact, 

acquire objects pertinent to its role in providing 

for visitor services interpretation and education 

in these alternatives. The NPS could also work 

in partnership with the JCCH in its role as 

collection center for archival materials. There 

is potential for beneficial effects to occur from 

its ability to lend management and collections 

expertise (technical assistance) to this and 

other partner foundations, organizations and 

individuals. It is also likely that, as overall 

coordinator of Japanese American internment 

history in Hawaiʻi, the NPS could become 

the recipient of donated objects or broader 

collections from individuals or organizations. 

To the extent that these were curated and 

stored by the NPS in an acceptable depository, 

there would be long-term beneficial effects on 

museum collections. 

Measures to Avoid, Minimize or 

Mitigate Impacts

Objects obtained by or donated to the NPS 

would be curated in an appropriate museum 

facility. Under alternative B, the NPS would 

identify or provide technical support for a 

repository for collections storage. Where 

requested, the NPS could provide technical 

support regarding museum collections.

Cumulative Effects

With the exception of efforts made by the 

JCCH, there has been no systematic collecting 

or documenting objects associated with the 

internment of Japanese Americans in Hawaiʻi. 

However, a range of documents, oral histories, 

art, and other objects is available to researchers 
150 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

at the Japanese Cultural Center of Hawaiʻi 

research center in Honolulu. Alternative B 

would likely also have negligible to moderate 

beneficial effects coupled with cumulative 

beneficial effects on museum collections.

Conclusion

Under alternative A, museum collections would 

continue to be collected and maintained by a 

variety of entities in a non-systematic manner. 

The lack of a uniform and systematic collection 

plan could result in minor to moderate adverse 

impacts to museum collections. Alternative B 

would result in beneficial effects to the current 

and newly obtained museum collections. 

Visitor Use and Experience

ACCESS AND TRANSPORTATION

Current access to Honouliuli Gulch is 

restricted. Any access to the site is by special 

permission only and requires compliance 

with Monsanto Company security protocols. 

Accessing the site involves traveling on the 

Monsanto property along dirt roads designed 

and used for agricultural research purposes 

and secured with locked gates. Access to the 

associated internment sites located throughout 

Hawaiʻi varies depend on the land owner. 

The U.S. Immigration Station is located on a 

busy thoroughfare (Ala Moana Boulevard) 

in Honolulu. Access to the U.S. Immigration 

Station is controlled through a guarded entry 

and is available only by appointment with 

Department of Homeland Security staff. 

Impacts of Alternative A

There would be no changes to access and 

transportation to Honouliuli as a result of 

implementation of alternative A. Without 

a national park system unit related to the 

internment in Hawaiʻi, it is anticipated that 

current limited and restricted visitation to the 

Honouliuli Internment Camp would continue. 

Existing federal, state, and county programs 

and policies would remain in place. The JCCH 

would continue to offer limited visitor activities 

in other locations, and possible activities at the 

site with the permission and concurrence of the 

landowner, such as the Day of Remembrance 

pilgrimage. Alternative A would have no new 

effects on access and transportation.

Impacts of Alternative B

Under alternative B, the NPS would plan for 

access and transportation to Honouliuli Gulch 

to provide the most effective access to the site. 

Access to the site could be via a combination of 

vehicle access roads and footpaths. Following 

designation, management planning would 

consider transportation options and would 

outline access routes to the site in a manner that 

is both sensitive to the resources and the overall 

visitor experience. Use of existing roads would 

be explored to minimize site disturbance. With 

an increased tourist awareness of a national 

park site’s presence at Honouliuli, and with 

the development of visitor amenities, it would 

be expected that Honouliuli would be viewed 

as an important location for learning about 

our nation’s Pacific War history as well as an 

opportunity to interact with O‘ahu’s natural 

environment. In addition to daily operations, 

special events and commemorations (i.e., 

pilgrimages) would likely be held at the site. 

Both daily operation needs and special events 

would be considered in the transportation and 

access planning. Coordinated planning for 

transportation and access for Honouliuli Gulch 

would have long-term beneficial effects to the 

site. 

Measures to Avoid, Minimize or 

Mitigate Impacts

Measures to minimize impacts to access 

and transportation would include a reliance 

on existing rights-of-way and roadways to, 

and in, the Honouliuli Gulch area. Nearby 

transit opportunities (located at and near the 

University of Hawaiʻi—West O‘ahu) could assist 

with reduced infrastructure development near 

the gulch. These nearby transit modes include 

both rail (under development) and bus that 

will serve the growing university campus and 

surrounding businesses. A shuttle system to 

convey visitors up to Honouliuli Gulch could 

be considered in a management plan under 

alternative B to manage vehicle and pedestrian 

circulation. 

Implementation of alternative B would 

include the development of uniform signage 

in conjunction with local transportation 

authorities, to direct visitors to the site, if an 

NPS site was created. 
 Chapter 7: Environmental Consequences  Visitor Use and Experience 151

Cumulative Effects

Alternative A would have no new actions and 

thus there would be no cumulative effects on 

visitor access and transportation. The potential 

development of the UHWO property along 

with the designation of a national park unit 

would increase the number of people that 

access the area. However, with the development 

and implementation of a management plan, 

the impacts would be reduced to negligible to 

minor long-term adverse. 

Conclusion

Alternative A would have no effect on access 

and transportation. Current conditions would 

continue. Because there would be few changes 

in levels of service at the sites, there would likely 

be no effect on transportation and no changes 

in traffic congestion. 

Alternative B would have long-term beneficial 

effects as a result of a transportation plan 

developed as part of a new national park 

designation. There would be an increase in 

visitation to the site, but the transportation 

management through implementation planning 

would account for these changes and provide 

an effective and efficient manner for which 

visitors would access and navigate the site. The 

development of a management plan that would 

identify appropriate locations for improved 

roadways and footpaths would be beneficial to 

the site.

VISITOR USE OPPORTUNITIES / 

INTERPRETATION AND EDUCATION

Current visitor use opportunities including 

interpretation and education at Honouliuli 

Internment Camp are restricted to sporadic, 

limited tours coordinated by the Japanese 

Cultural Center of Hawaiʻi. Interpretation and 

educational opportunities regarding Honouliuli 

Internment Camp are provided outside of the 

gulch using a variety of media, but these are 

virtual experiences as opposed to in-person 

experiences. For example, World War II Valor 

in the Pacific National Monument at Pearl 

Harbor provides an interpretive exhibit on 

internment during World War II.

Onsite presentation, 2011 Day of Remembrance Pilgrimage to Honouliuli Internment Camp. Photo: Brian Niiya, Japanese Cultural Center 

of Hawai‘i.
152 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Visitor use and interpretation and education 

opportunities at the associated sites are very 

limited and vary according to the property 

owner. Because many visitor use opportunities 

would be associated with interpretation and 

education, these topics have been combined 

below.

Impacts of Alternative A 

There would be no changes in visitor use 

opportunities as a result of implementation 

of this alternative. Occasional special events 

could allow for public access to Honouliuli 

Internment Camp. For instance, guided tours 

were offered on the Day of Remembrance 

in 2012, but not in 2013. Public use would 

continue to be limited and would be dependent 

on the initiative of the visitor to take advantage 

of opportunities to see related sites and on the 

agreement of the site owner to make it available 

to the public, resulting in a long-term minor to 

moderate adverse effect. 

Opportunities are also available to learn 

about Honouliuli through various websites, 

including the JCCH (www.Hawaiiinternment.

org) and websites for sites and resources 

on the mainland. The JCCH website offers 

access to teacher lesson plans, photographs 

and archives, a timeline, and links, while the 

other websites offer articles, white papers, 

timelines, photographs, and other written 

material. Visitation would be expected to 

remain at current levels, including periodic 

increases for special events. While no 

additional visitor services would be provided 

in alternative A, there would be ongoing visitor 

use opportunities to experience Honouliuli 

Internment Camp and information, a long-term 

beneficial effect. 

Impacts of Alternative B

HONOULIULI

In addition to a variety of ongoing beneficial 

effects in alternative A, there would be 

enhanced opportunities for visitor use in 

alternative B. Designation of a national historic 

site would create new opportunities for visitors 

to experience and understand the history and 

experience of Japanese American and European 

American incarceration during World War II. 

New visitor use opportunities at Honouliuli and 

Valor in the Pacific National Monument could 

be provided. At Valor in the Pacific National 

Monument, the NPS could link the two sites 

with interpretive programming, identifying 

major themes and coordinating information 

and some activities associated with the two 

sites. Educational programs developed by the 

NPS and its partners would highlight the role of 

Japanese Americans during WWII. 

Because potential development of a visitor 

center is uncertain, many of the visitor use 

opportunities in alternative B would be 

dependent on WWII Valor in the Pacific 

National Monument to develop visitor 

facilities and internet-based information. 

Expansion of existing partnerships between 

the NPS, UHWO, and JCCH could further 

enhance interpretation and education 

programs. Coordination of the site by the NPS 

under alternative B would improve visitor 

understanding and education of this era in 

history over the no action alternative. There 

would also be new information on the internet, 

including an NPS-based website for pre-visit 

planning and for those people studying the 

history of the Japanese American and European 

American incarceration during World War II. 

Such a website could offer links to other existing 

websites, such as the JCCH website, other 

NPS sites, Densho, and the Japanese American 

National Museum site.

OTHER SITES

While some locations on neighbor islands 

would continue to be viewed only from the 

outside and current unrelated uses would 

likely continue, it is also possible that over time 

these sites could become more accessible to 

the public. Nonetheless, even commemorative 

and interpretive signs indicating the events 

that transpired would improve visitor use 

opportunities and experiences. Increased 

visitation may result in increased public 

knowledge and could further encourage 

protection of resources, resulting in beneficial 

impacts over time. Combined there would be 

long-term beneficial effects by providing new 

and/or expanded visitor use opportunities 

associated with designating a new national 

historic park unit.
 Chapter 7: Environmental Consequences  Socioeconomics 153

Cumulative Effects

Current visitor use opportunities are offered 

on a limited basis by the property owner and 

the Japanese Cultural Center of Hawaiʻi. There 

would be no cumulative effects to visitor use 

opportunities under alternative A because 

these would not be coordinated or expanded. 

Alternative B would contribute an array of 

beneficial cumulative effects by providing 

additional visitor use opportunities that 

highlight the history of Japanese American, 

European American, and prisoner-of-war 

incarceration during World War II. The 

implementation of this alternative would 

result in cumulative beneficial effects over 

time, as more Americans would gather a 

better understanding of this history and the 

implications of due process and civil rights. 

Moreover, information would be available 

through an NPS website and visitor use 

opportunities on site would be advertised and 

potentially coordinated by the NPS. 

UHWO development could potentially have 

short-term impacts on the development of 

educational and interpretive programs at 

Honouliuli due to construction traffic, noise, 

and vibration, and long-term impacts from the 

noise associated with increased traffic. 

The Hawaiʻi legislature has commissioned a 

group, called the Honouliuli Park Site Advisory 

Committee, to support preservation of the 

Honouliuli site. Recent site planning efforts have 

been related to an education facility, although 

no recommendations or decisions have been 

made by the state of Hawaiʻi. The potential 

impacts to visitor use of the sites are unknown 

at this time.

Conclusion

Alternative A would have no effect on visitor 

use opportunities and interpretation and 

education about the history and experience 

of Japanese American and European 

American incarceration during World War 

II. Alternative B would have beneficial effects 

on visitor use opportunities associated with 

understanding the history and experience of 

Japanese American and European American 

incarceration during World War II. The action 

alternative would contribute to engendering 

a better understanding of these events for all 

Americans as well as for international visitors. 

Because of the inclusion of NPS involvement, 

alternative B would provide a centralized 

national location for information about the 

history and experience of Japanese American 

and European American incarceration during 

World War II that would be available to all in 

perpetuity.

Socioeconomics

WEST O‘AHU SOCIOECONOMIC 

SETTING

The west O‘ahu area was at one time used 

primarily for both agricultural production 

(sugar cane and pineapple) and military 

infrastructure (Barbers Point, Ewa Field). 

Located just beyond the more highly developed 

and populated Pearl Harbor area, and 

significantly further from the central ‘core’ of 

downtown Honolulu, west O‘ahu represents 

a primarily non-urban setting with increasing 

development opportunities and pressures. West 

O’ahu is where the ‘second city’ of Kapolei is 

being promoted as an alternative governmental 

agency center away from the high-density 

Kakaako district near downtown Honolulu. 

This community is the closest example of a 

‘gateway’ community to the Honouliuli Gulch 

area, though it is separated by over a mile on the 

H-1 Freeway. 

A recent economic study, (Identification and 

Quantification of Economic Development 

Opportunities in West O‘ahu; SMS Consulting; 

Honolulu, HI, July 2011) prepared for the West 

O‘ahu Economic Development Association, 

states that while the west O‘ahu area has 

seen rapid population increase, this surge 

will slow to just slightly above the population 

trend of the City and County of Honolulu. 

Primary employment sectors are projected to 

be in the education and health fields, arts and 

entertainment fields, and construction and 

transportation sectors. Most businesses in west 

O‘ahu are small (fewer than ten employees 

and most annual sales under $1 million 

annually). These businesses primarily serve 

immediate community residents and are mostly 

headquartered in west O‘ahu. 

Historically, settlement in the west O‘ahu 

area was strongly connected to agricultural 

plantation operations that relied on a series of 

ethnic groups as sources of labor. This is one of 

the reasons why Hawaiʻi has such a strong mix 
154 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

of Portuguese, Japanese, Chinese, and Filipino 

(among other) communities. Many were hired 

to come to Hawaiʻi and perform farm labor, 

after which a large number elected to stay. With 

the decline of agricultural production and 

greater diversification of the state economy, the 

communities near the Honouliuli Gulch area 

represent newly arrived residents attracted to 

the more suburban development plan and more 

affordable housing. Educational attainment is 

varied in west O‘ahu with Kapolei (the closest 

community to Honouliuli Gulch) having 

highest educational attainment rates for this 

part of O‘ahu. 

The dispersed nature of the associated 

internment sites located throughout Hawaiʻi, 

and their setting in either remote areas or 

settings with other primary uses (i.e., local 

government settings) makes it difficult to 

generalize the overall socioeconomic impacts 

of the two alternatives. The feasibility of 

promoting greater tourism to these locations—

and therefore enhanced economic development 

opportunities for these areas—is likely 

limited. More in-depth, site specific feasibility 

assessments on socioeconomic impacts to 

associated sites would need to be conducted 

once these individual sites engage in strategies 

to promote preservation and site stewardship of 

internment history in Hawaiʻi. 

Impacts of Alternative A 

There would be no changes to socioeconomic 

conditions as a result of implementation of 

this alternative. Under alternative A, services 

provided at the sites would continue at the same 

levels. No new direct impacts on the regional 

economy would occur with this alternative.

Impacts of Alternative B

Designation of a Honouliuli national park unit 

would likely have beneficial economic and social 

impacts on the area. Possible socioeconomic 

impacts could include visitation to the site or 

sites, surrounding areas, and other attractions; 

expenditures from park operations and park 

staff; expenditures by visitors, sales, and hotel 

tax revenues from visitor expenditures; and 

growth in visitor-related businesses that support 

the tourism economy. 

Although the western part of O‘ahu has 

historically had an agricultural-based economy, 

it includes growing retail, tourism, government, 

education, and a variety of other employment 

sectors. Establishing a new national historic 

site in west O‘ahu would have negligible effects 

on the state economy. It is likely that tourism 

numbers for the state of Hawaiʻi would not 

increase solely because of Honouliuli becoming 

a national historical site. However, additional 

visitors and NPS staff would contribute to the 

local economy by purchasing various goods 

and services, including food, gasoline, and 

lodging. Overall, beneficial impacts on the local 

economy would be expected. Interpretive tours 

for visitors would likely generate local economic 

benefits in the vicinity of the University of 

Hawaiʻi—West O‘ahu commercial development 

area—to the extent that commercial 

development provides goods and services 

needed by visitors. Over time there would likely 

be sustained economic benefits from tourism 

dollars and jobs supported by them.

Cumulative Effects

Because there would be no new actions in 

alternative A, there would be no contribution 

to cumulative impacts on socioeconomics. 

Under alternative B, the Honolulu Rail and 

UHWO campus expansion (including planned 

commercial development near the existing 

campus and future university development 

onto the Mauka parcel) would have a beneficial 

cumulative impact to the Honouliuli National 

Historic Site by providing transportation access 

and an educational portal with partnership 

opportunities for people visiting the site.

Because there would be no new actions in 

alternative A, there would be no contribution 

to cumulative impacts on socioeconomics. 

Alternative B would contribute increasingly 

beneficial effects to socioeconomics. Combined 

with past, present, and future actions, such as 

the new University of Hawaiʻi campus in West 

O‘ahu, alternative B would have negligible to 

minor beneficial contributions to cumulative 

socioeconomic impacts.

Conclusion

Alternative A would result in no direct or 

cumulative impacts on socioeconomics. 

Because it would allow the Hawai‘i internment 

history to be shared at a national park site, 
 Chapter 7: Environmental Consequences  Environmentally Preferable Alternative 155

Generally, these criteria mean the 

environmentally preferable alternative is the 

alternative that causes the least damage to the 

biological and physical environment and that 

best protects, preserves, and enhances historic, 

cultural, and natural resources (46 FR 18026 – 

46 FR 18038).

Alternative B would protect the nationally 

significant resources, including opportunities 

for protecting the Honouliuli site in perpetuity 

should the Monsanto Company donate or 

sell it to the NPS, meeting criterion 1 above. 

Alternative B would also best meet the intent 

embodied in criteria 2, 3, and 4 by providing 

opportunities for protection of the Honouliuli 

site with more opportunities for visitors to 

learn about the history and experience of 

Japanese American and European American 

incarceration during World War II. All 

alternatives would likely meet the principles 

identified in criteria 5 and 6. Although there are 

no specific actions related to these currently in 

the alternatives associated with these criteria, 

long-standing NPS policies and actions would 

apply. Based on this analysis, alternative B 

best meets the six criteria and is therefore the 

environmentally preferable alternative.

alternative B would have localized beneficial 

impacts on socioeconomics, including some 

discernible impacts on local communities, 

as well as beneficial impacts on the heritage 

documentation of some minority populations.

Environmentally Preferable 

Alternative

In accordance with NPS Director’s Order-12, 

Conservation Planning, Environmental 

Impact Analysis, and Decision-making and 

Council on Environmental Quality (CEQ) 

requirements, the NPS is required to identify 

the “environmentally preferable alternative” in 

all environmental documents, including EAs. 

The environmentally preferable alternative is 

determined by applying the criteria suggested in 

the National Environmental Policy Act (NEPA) 

of 1969, which is guided by the CEQ. The CEQ 

(46 FR 18026 - 46 FR 18038) provides direction 

that the “environmentally preferable alternative 

is the alternative that would promote the 

national environmental policy as expressed in 

NEPA’s Section 101,” including: 

ŐFulfill the responsibilities of each generation 

as trustee of the environment for succeeding 

generations;

ŐAssure for all Americans safe, healthful, 

productive, and aesthetically and culturally 

pleasing surroundings;

ŐAttain the widest range of beneficial uses of 

the environment without degradation, risk 

of health or safety, or other undesirable and 

unintended consequences;

ŐPreserve important historic, cultural and 

natural aspects of our national heritage 

and maintain, wherever possible, an 

environment that supports diversity and 

variety of individual choice;

ŐAchieve a balance between population 

and resource use which will permit high 

standards of living and a wide sharing of 

life’s amenities; and 

ŐEnhance the quality of renewable resources 

and approach the maximum attainable 

recycling of depletable resources (NEPA 

Section 101(b)).
156 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Table 7-4: Comparison of Impacts

Resource Alternative A Alternative B

Land Use There would be no direct impacts to land 

use. Existing land use plans and zoning 

would continue to guide management of 

individual areas. Over time, there could 

be systematic loss of the Honouliuli 

Internment Camp and sites related to 

the history and experience of Japanese 

American and European American 

incarceration during World War II. A longterm indirect minor to moderate adverse 

effect would occur because there would 

be no effort made to link Honouliuli to 

other NPS sites, potentially resulting in less 

desire for protection.

There would be long-term beneficial effects 

from designating Honouliuli Internment 

Camp as a unit of the national park system. 

This designation would offer a high level 

of preservation and management to the 

Honouliuli Internment Camp. Associated 

internment sites in other parts of the state 

could also be linked and therefore more 

protection initiatives would be offered 

for them. Some associated internment 

sites could be modified or lost, a minor to 

moderate long-term adverse effect.

Water Resources There would be no direct impacts on water 

resources from implementation of this 

alternative. 

This alternative would improve existing 

roadways and would limit development 

to areas outside of the historic camp 

boundary, resulting in a benefit to the 

water resources. Development of a road 

crossing through the gulch could result in 

minor temporary construction runoff and 

overall long-term beneficial impacts from 

improved protection of water quality. 

Vegetation There would be no new impacts to 

vegetation. Ongoing minor to moderate 

adverse impacts to vegetation from invasive 

species would continue to occur. No 

known federally threatened or endangered 

species occur at the Honouliuli Internment 

Camp.

Changes, such as the placement of roads, 

trails, parking areas, and signs, could occur 

to accommodate visitor use. Because 

these changes would generally occur in 

highly modified habitats, they would have 

negligible to minor short-term effects 

on native vegetation. The development 

and implementation of a vegetation 

management plan as a component of 

a historic landscape plan would direct 

changes to vegetation density and 

composition in the Honouliuli Gulch. 

Prehistoric 

and Historic 

Archeological 

Resources

If the site continued to be undeveloped, 

there would be a minor long-term adverse 

effect to archeological resources from 

erosion and natural processes. If the 

landowner implemented development 

in the site without proper precautions 

to protect archeological resources, there 

would be a minor to major long-term 

adverse effect to the resources. Under 

Section 106, impacts could be no effect, no 

adverse effect, or adverse effect. 

Placement of visitor facilities such as trails, 

parking, and signs would not be expected 

to affect archeological resources if located 

outside of the historic boundary and/or 

in areas that have already been disturbed. 

There would be long-term beneficial 

effects where state or federal archeological 

resources protection laws were invoked 

and/or from further survey or testing 

research.

There would be no effect or no adverse 

effect on archeological resources.
 Chapter 7: Environmental Consequences  Environmentally Preferable Alternative 157

Table 7-4: Comparison of Impacts

Resource Alternative A Alternative B

Historic 

Structures/ 

Cultural 

Landscapes

No specific actions would be taken to 

ensure the protection of the NRHP-listed 

Honouliuli Internment Camp. This would 

result in no adverse or adverse effects. 

Overall impacts to historic and cultural 

resources at Honouliuli would range from 

no effect to no adverse effect to adverse 

effect. With establishment of an NPS 

management unit, it is likely that actions to 

accommodate visitors would have no effect 

or no adverse effect. This could also extend 

to related sites in other areas, pending 

willingness of landowners to manage sites 

in accordance with historic preservation 

guidelines. However the NPS would retain 

only a technical assistance, coordinating, 

or advisory role. Where management 

actions to protect sites, buildings and 

structures occurred, there would be longterm beneficial effects. Where they did not, 

minor to moderate adverse effects could 

occur.

Museum 

Collections

There would be no new impacts. 

Alternative A would not add appreciably 

to protection of museum collections, 

although some objects and materials could 

continue to be protected through UHWO, 

JCCH, and others. Some objects may also 

be lost due to lack of protection options.

Alternative B would have the potential to 

add to museum collections and to provide 

for a systematic collection plan and would 

result in beneficial effects to the current 

and newly obtained museum collections.

Visitor Use and 

Experience: Access 

and Transportation

There would be no changes to access and 

transportation. Current conditions would 

continue.

Alternative B would include the 

development of a Honouliuli Gulch 

management plan that would identify 

desired visitor experiences and identify the 

most effective access and transportation 

options to the site. A management plan 

would outline access routes to the site in 

a manner that is sensitive to the resources 

as well as a way to enhance the visitor 

experience. Both daily operation needs 

and special events would be considered in 

the transportation and access planning. A 

well-developed transportation and access 

plan for Honouliuli Gulch would have 

long-term beneficial effects to the site. 

Visitor Use and 

Experience: Visitor 

Use Opportunities/ 

Interpretation and 

Education

There would be no effect on visitor use 

opportunities and interpretation and 

education. 

Alternative B would have beneficial effects 

on visitor use opportunities associated 

with understanding the history of the 

Japanese American internment during 

WWII. Because of the National Park 

Service presence, alternative B would 

provide a centralized national location 

for information about the history of the 

Japanese American internment during 

WWII in Hawaiʻi that would be available to 

all in perpetuity.
158 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Table 7-4: Comparison of Impacts

Resource Alternative A Alternative B

Socioeconomic 

impacts, including 

minority and 

low-income 

populations

There would be no direct or cumulative 

impacts on socioeconomics. 

Alternative B would have localized 

beneficial impacts on socioeconomics, 

including some discernible impacts on 

local communities, as well as beneficial 

impacts on the heritage documentation 

of some minority populations from 

sharing this story at a national park site. 

Commercial services available in the still 

developing University of Hawaiʻi—West 

O‘ahu area may benefit from increased 

heritage-related tourism. 
8CONSULTATION AND COORDINATION
Honouliuli Day of Remembrance and first annual Pilgrimage. Photo: NPS, 2010.
Chapter 8: Consultation and Coordination  Public Involvement 159

CHAPTER 8: CONSULTATION 

AND COORDINATION

Public Involvement

Congress directed the National Park Service to 

complete a special resource study of sites that 

are significant to the incarceration of Japanese 

Americans and European Americans during 

World War II, and to determine whether one 

or more of these sites are eligible and suitable 

to be managed as a unit of the national park 

system. The study team provided opportunities 

for elected officials, local governments, 

organizations, and residents in Hawaiʻi to learn 

about and contribute to the study process 

through public meetings, stakeholder meetings, 

a newsletter, and the study website. 

As directed in the legislation, the NPS consulted 

with the state and local historical associations 

and societies, including state historic 

preservation offices, Native Hawaiian and 

local government entities, and other interested 

parties.

SCOPING 

The NPS study team launched public scoping 

for this study in February 2011. The NPS 

produced and distributed newsletters to 

the media, individuals, organizations, and 

government officials. The purpose of the 

newsletter was to introduce the study, explain 

the process to community members, and solicit 

comments on issues the study should address. 

The newsletter also contained information on 

the schedule of public scoping meetings. 

The newsletter was published and made 

available for comment on the National Park 

Service’s Planning, Environment and Public 

Comment (PEPC) website. The comment 

period extended to June 1, 2011, 30 days after 

publication of the notice of scoping in the

Federal Register. Comments received after the 

closing date were also accepted.

Press releases announcing the beginning of the 

study process and the public meeting schedule 

were distributed to local media. Numerous 

articles and opinion pieces about the study have 

appeared in area newspapers. All information 

sent by mail or e-mail was also available on the 

special resource study website at www.nps.gov/

pwro/honouliuli. 

In February and March 2011, the study team 

held a series of public scoping meetings on 

the six main islands in Hawaiʻi (Table 8-1). 

The meetings were attended by more than 100 

people. The presentation included an overview 

of the study purpose and process, identification 

of the sites associated with the internment, and 

potential management ideas and outcomes. 

After the presentation, the NPS staff facilitated 

group discussions to capture public comments 

related to the study. 

In addition to comments received at the public 

scoping meetings, the NPS received comments 

via written letters and through e-mail. 

Local, state, and federal government officials 

and associated organizations and individuals 

were contacted. Numerous telephone 

conversations were held when face-to-face 

meetings were not possible. The NPS met with 

the following entities during scoping:

Japanese Cultural Center of Hawaiʻi

University of Hawaiʻi—West Oʻahu

University of Hawaiʻi—Mānoa

Historic Hawaiʻi Foundation

Hawaiʻi Judiciary History Center

Hawaiʻi Department of Land and Natural 

 Resources

Honouliuli Day of Remembrance, 2011.Photo: NPS.
160 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Table 8-1: Public Scoping Workshops, 2011

Location Date Attendance

Waipahu, HI 

Honouliuli Day of Remembrance

February 27, 2011 18

Kailua-Kona, HI March 1, 2011 6

Hilo, HI March 10, 2011 10

Kaunakakai, Molokaʻi, HI March 17, 2011 6

Lānaʻi City, HI March 22, 2011 3

Kahului, Maui, HI March 24, 2011 12

Līhuʻe, Kaua‘i, HI March 29, 2011 26

Honolulu, HI March 31, 2011 23

TOTAL 104

SUMMARY OF PUBLIC SCOPING 

COMMENTS 

Public comments predominantly expressed 

the desire to commemorate the internment 

experience in Hawai‘i. People felt that 

internment and incarceration during World War 

II is an important part of Hawaiian history and 

noted the differences between the experiences 

of Japanese Americans on the mainland. Most 

stated that there are important lessons to be 

learned from this history. 

Management

When asked if the NPS should be involved 

in managing the internment sites, most 

respondents expressed strong support for 

NPS management and involvement at the sites, 

particularly at Honouliuli Gulch. This support 

was structured around the perception that 

preservation of the sites and interpretation 

about this part of history aligns more closely 

with the mission of the National Park Service 

than with that of any other organization. The 

public also stated that the NPS is the entity 

most able to manage the sites, rather than other 

entities who could contribute as partners, but 

not also as land managers.

Partnerships

Commenters expressed strong support for 

partnerships, especially for education, research, 

and collecting oral histories. The partners that 

were mentioned with greatest frequency were 

the Japanese Cultural Center of Hawai‘i, the 

University of Hawai‘i, the local government, 

veterans’ associations or veterans’ centers on 

the islands, and businesses.

Honouliuli Gulch Preservation

Public comments related to Honouliuli Gulch 

supported the designation of the site as a unit 

of the national park system. The public also 

supported the NPS acceptance of the donation 

of Honouliuli Gulch from the Monsanto 

Company. 

There were numerous comments about how 

best to share the story and what types of 

experiences visitors could have at Honouliuli 

Gulch. Suggestions for interpretation included: 

1) a visitors center with oral histories, videos, 

educational displays, and programs; 2) 

reconstruction of representative structures 

including barbed wire, guard towers, a tent 

or barracks, and mess hall; and 3) external 

educational and research resources including 

websites, links to other educational institutions, 

and confinement sites.

Many people thought Honouliuli Gulch 

would be the best location for the NPS’s 

preservation and interpretive efforts related to 

the internment in Hawai‘i. There was support 

for preservation and interpretation at the other 

sites as well, recognizing that these efforts could 

be accomplished in partnership with the NPS. 

Some people thought that Honouliuli Gulch 

could be linked to World War II Valor in the 

Pacific National Monument on Oʻahu. Such 

a connection could tie this part of Hawaiian 

history to the larger World War II story and help 

bring attention and visitation to the site because 

of the name recognition and association with 

World War II Valor in the Pacific National 

Monument.
Chapter 8: Consultation and Coordination  Agency Consultation 161

Other Sites 

At public meetings throughout Hawai‘i, people 

generally focused their comments on their 

local sites. Thus, there was strong support for 

recognizing the sites on the neighbor islands. 

At a minimum, participants said that each site 

could (and should) be marked with a plaque 

or other commemorative marker. Technical 

assistance could be provided by the NPS for 

preservation and interpretive programs. 

There was also strong support expressed 

for providing wider access to Kilauea 

Military Camp for all visitors, and for onsite 

interpretation and a guided or self-guided 

walking tour.

Interpretation

Many public comments focused on 

interpretation and history of the sites. 

Suggestions included interpretation on martial 

law and civil rights in Hawai‘i, redress and 

reconciliation after the war, the lives of the 

Japanese Americans in the camp and within the 

local communities, and the relationship of this 

part of history to current affairs. There was also 

interest in the history of the prisoners of war at 

Honouliuli and Kilauea Military Camp. 

Agency Consultation

SECTION 106 OF THE NATIONAL HISTORIC

PRESERVATION ACT

The State of Hawai‘i Department of Lands 

and Natural Resources Historic Preservation 

Division was notified by JCCH in 2011 about 

the Honouliuli Gulch special resource study. 

They provided a letter to the NPS dated May 4, 

2011 indicating that the area of potential effect 

would be the gulch itself and access roads to the 

gulch. They stated that the “acquisition of the 

property will have no adverse effect on historic 

property.” To comply with NPS responsibilities 

for Section 106, at the time of release of the 

draft study in May 2014, the NPS requested 

consultation by the State Historic Preservation 

Division to seek concurrence on 1) recognition 

of the special resource study undertaking, 2) 

the area of potential effect, 3) identification 

of historic properties within the Honouliuli 

Gulch area, and 4) finding of No Adverse 

Effect to historic properties. The State Historic 

Preservation Division concurred with these 

findings in a letter dated September 23, 2014.

SECTION 7 OF THE ENDANGERED SPECIES ACT

The study team initiated consultation under 

Section 7 with the Pacific Island field office of 

the U.S. Fish and Wildlife Service in June 2011 

with regard to an updated list of any threatened 

and endangered species associated with the 

study sites. The U.S. Fish and Wildlife Service 

found that the study would have “no effect” 

on federally listed species. Further evaluation 

would be warranted if major construction 

projects were proposed as a result of study 

outcomes and implementation. The U.S. Fish 

and Wildlife Service was invited to comment on 

the draft study.

Honouliuli Day of Remembrance, 2011.Photo: NPS.
162 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

List of Draft Study Recipients 

The draft study, executive summary newsletter, 

or announcement that the study is available 

online was sent to contacts on the study mailing 

list. The draft study and an executive summary 

newsletter are available at www.nps.gov/pwro/

honouliuli. 

The draft study was sent to the following 

agencies and organizations:

FEDERAL AGENCIES AND ELECTED 

OFFICIALS

Advisory Council on Historic Preservation

Congressional Representatives

 Senator Brian Schatz

 Senator Mazie K. Hirono

 Congresswoman Tulsi Gabbard

 Congresswoman Colleen Hanabusa

U.S. Department of Homeland Security

U.S. Department of Interior

 National Park Service

 Ala Kahakai National Historic Trail

 Haleakalā National Park

 Hawaiʻi Volcanoes National Park

 Kaloko-Honokōhau National Historical 

 Park

 Kalaupapa National Historical Park

 Manzanar National Historic Site

 Minidoka National Historic Site

 National Park of American Samoa

 Puʻuhonua O Hōnaunau National 

 Historic Site

 Puʻukoholā Heiau National Historic Site

 Tule Lake Unit

 War in the Pacific National Historical 

 Park

 World War II Valor in the Pacific 

 National Monument

Office of Native Hawaiian Relations

U.S. Fish and Wildlife Service

STATE AND LOCAL AGENCIES AND 

ELECTED OFFICIALS

City and County of Honolulu Planning

Governor Neil Abercrombie

Honolulu County

Honouliuli Park Site Advisory Committee

Senator Mike Gabbard

Senator Will Espero

Representative Richard Lee Fale

Department of Business, Economic 

Development, and Tourism

Department of Land and Natural Resources 

 State Historic Preservation Division

 State Parks Division

Department of Hawaiian Home Lands

BUSINESSES, INSTITUTIONS, AND 

ORGANIZATIONS 

‘Ahahui Siwila Hawai‘i o Kapolei

Bishop Museum

Hawai‘i Historical Society

Historic Hawaiʻi Foundation

Japanese American Citizens League

Japanese American National Museum

Japanese Cultural Center of Hawaiʻi

Kapolei Community Development Corporation

Monsanto Company

National Parks Conservation Association

National Parks Foundation

National Trust for Historic Preservation

Office of Hawaiian Affairs

Pacific Historic Parks

Society of Hawaiian Archaeology

University of Hawai‘i–Mānoa

University of Hawaiʻi–West Oʻahu

Select public libraries in the Hawaiian Islands
Public Review of Draft Study Report  Public Meetings 163

PUBLIC REVIEW OF DRAFT 

STUDY REPORT

The National Park Service (NPS) released the 

Honouliuli Gulch and Associated Sites Draft 

Special Resource Study and Environmental 

Assessment (draft study report/EA) on May 8, 

2014. The public comment period was open 

from May 8 to July 15, 2014.

 The NPS announced the release of the draft 

study report, public comment period, and 

public meetings through press releases, e-mail 

announcements, and through the distribution 

of a newsletter. The NPS sent study reports 

to agencies, organizations, government 

representatives, and stakeholders. Paper and 

e-newsletters were sent to approximately 800 

contacts. The project was launched on the NPS 

Planning, Environment, and Public Com ment 

(PEPC) website and project website (www.

nps.gov/pwro/honouliuli). These websites 

provided downloadable versions of the draft 

study report/EA, background information about 

the study, and an online form to receive public 

comments. The public was invited to submit 

comments by mail, e-mail, fax, online, at public 

workshops, and during an online meeting 

where individuals could participate through a 

conference line and internet website.

 The NPS received more than 3,100 comments 

on the draft study report.

Public Meetings

The public meetings in the Hawaiian Islands 

and the online public meeting were attended 

by 256 people (see table 8-2). At each meeting, 

the study team described the study purpose and 

process, findings of the study, and presented the 

two alternatives Following this presentation, 

NPS staff facilitated a question-and-answer 

session and group discussions where attendees 

provided public comments.

Table 8-2: Public Meeting Attendance, Draft Study Review

Location Date Attendance

Kapolei, Oʻahu 

University of Hawaiʻi—West Oʻahu

May 27, 2014 50

Honolulu, Oʻahu 

Japanese Cultural Center of Hawaiʻi

May 28, 2014 92

Honolulu, Oʻahu 

Japanese Cultural Center of Hawaiʻi

May 29, 2014 53

Līhuʻe, Kauaʻi 

Līhuʻe Neighborhood Center

May 29, 2014 15

Kaunakakai, Molokaʻi 

Kaunakakai Elementary School

June 2, 2014 —

Kahului, Maui 

Maui Arts and Cultural Center

June 2, 2014 9

Lānaʻi City, Lānaʻi 

The Lānaʻi Senior Center

June 3, 2014 4

Hilo, Island of Hawaiʻi 

Hawaiʻi Japanese Center

June 4, 2014 25

Online public meeting June 17, 2014 8

TOTAL 256
164 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Public Comments

The NPS received comments from over 3,100 

individuals, agencies, elected officials, and 

organizations. Approximately 95% of the 

comments were submitted as a result of an 

organized campaign initiated by the National 

Parks Conservation Association in support of 

alternative B, which proposes the designation 

of Honouliuli Internment Camp as a unit of 

the national park system. Sixty-five individual 

comments were submitted via written letters, 

comment forms, e-mail, and through the PEPC 

online comment system. Comments analyzed 

also included the notes from the small group 

discussions held at each public meeting.

List of Agencies and 

Organizations Commenting

Comments, both through public workshops or 

written correspondence, were received from the 

following organizations, affiliates, and elected 

officials:

AGENCIES AND ORGANIZATIONS 

SUBMITTING OFFICIAL COMMENTS

City and County of Honolulu

Councilmember Carol Fukunaga, Honolulu 

City Council

Hawaiʻi Department of Land and Natural 

 Resources, State Historic Preservation 

 Division

Historic Hawaiʻi Foundation

Japanese Americans Citizens League

Japanese Cultural Center of Hawaiʻi

National Parks Conservation Association

Office of Planning, State of Hawaiʻi

University of Hawaiʻi–West Oʻahu

U.S. Citizenship and Immigration Services 

U.S. Department of Homeland Security

U.S. Representative Colleen Hanabusa

AFFILIATIONS/ASSOCIATIONS NOTED 

BY PUBLIC MEETING ATTENDEES OR 

COMMENTERS 

Densho

Elks 616 Lodge

ʻEwa Community Church

Fukushima Kenjin Kai

Go For Broke National Education Center

Hawaiʻi United Okinawa Association

Heald College

Honouliuli Park Site Advisory Committee

Japanese Cultural Center of Hawaiʻi

Kaimuki High School

Lānaʻi Culture and Heritage Center

MIS Veterans Club of Hawaiʻi

Monsanto Company

National Park Service

National Parks Conservation Association

National WWII Museum

Nisei Veterans Memorial Center

North American Japanese Garden Association

Research Corporation of the University of 

 Hawaiʻi/Army

The Hawaiʻi Herald

University of Cincinnati

University of Hawaiʻi Center for Biographical 

 Research

University of Hawaiʻi–Kapiʻolani Community 

 College

University of Hawaiʻi–West Oʻahu

University of Hawaiʻi–Windward Community 

 College

University of New Orleans

SUMMARY OF PUBLIC 

COMMENTS

The following summary represents the full 

range of comments received. All comments 

were entered into the NPS Planning, 

Environment, and Public Comment database 

(PEPC) and analyzed. NPS responses to 

substantive comments are provided in the 

final section of this document, “Response to 

Substantive Comments on the Honouliuli Gulch 

and Associated Sites Draft Special Resource Study 

and Environmental Assessment.”

Public Review of Draft 

Alternatives: Support for 

Alternative B

The vast majority of public comments 

supported alternative B, the designation 

of Honouliuli Internment Camp as a unit 

of the national park system. Commenters 

overwhelmingly cited the need to preserve the 

story of Hawaiʻi’s World War II internment 

history and ensure protection of the site in 
Summary of Public Comments  Partnerships 165

perpetuity. Several members of the public asked 

that designation proceed rapidly in order to 

prevent further degradation of the site and loss 

of important resources, including oral histories 

from survivors who are quickly passing away.

A majority of respondents emphasized the 

need to remember the U.S. internment and 

incarceration of civilians of Japanese descent 

to guarantee that such an injustice never occurs 

again. Many of these individuals felt that a 

strong educational focus should be integral 

to NPS efforts to preserve and interpret 

Honouliuli, in particular relating to issues 

of civil rights and discrimination. Several 

described the designation as a meaningful 

gesture that could confer justice and dignity on 

those wrongfully incarcerated, while providing 

a place for descendants to honor their loved 

ones.

The story of Honouliuli Internment Camp and 

associated internment sites was described as 

significant on both a local and national level. 

Many expressed surprise to learn of the civilians 

and prisoners of war interned in Hawaiʻi, 

stating that it is a largely unknown chapter in 

the history of the islands. Several individuals 

recommended that Honouliuli Internment 

Camp be preserved in order to demonstrate 

the unique story of internment in Hawai‘i 

when compared with the mainland, noting that 

different populations were affected, including 

Public meeting following the release of the draft study report, Japanese Cultural Center of Hawai‘i, May 2014. Photo: NPS.

Japanese and European Americans, Japanese 

and European resident aliens, and prisoners of 

war. A few commenters suggested that national 

park designation could inspire additional 

research about the history of incarceration in 

the islands.

Others agreed with study findings that 

designation would be feasible given the 

proposed donation of land by the Monsanto 

Company to the NPS. A few highlighted the 

economic and cultural benefits that a new 

national park unit could provide to the local 

community.

A few respondents were against designation of 

Honouliuli as a unit of the national park system. 

These commenters stated concerns about 

funding and the interpretation of World War 

II incarceration history presented in the draft 

study report.

Partnerships

A large majority of comments emphasized the 

importance of maintaining partnerships with 

local organizations, particularly the Japanese 

Cultural Center of Hawaiʻi (JCCH) and the 

University of Hawaiʻi–West Oʻahu (UHWO), 

which are already engaged in research, 

stewardship, and interpretation efforts for 

Honouliuli and the associated interment sites. 

Commenters stated that these partnerships 
166 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

should continue after a NPS designation. A 

few commenters noted that the NPS draft 

study report should more strongly emphasize 

the significance of the work achieved by 

these partners. The annual Honouliuli Day 

of Remembrance, organized by JCCH, was 

cited as an important partner event that 

should continue. Some remarked that the 

presence of such active partnerships reveals 

the commitment of the local community to 

the story of Hawaiʻi’s confinement sites, while 

others stressed strong community support for 

the designation.

Many observed that partnerships could assist 

with fundraising, research, and the development 

of educational programs. A number of 

commenters proposed that the NPS collaborate 

with specific entities to share the story of 

World War II internment, notably with the 

Japanese American community and Hawaiʻi’s 

public schools. One respondent suggested the 

formation of a Friends of Honouliuli Gulch 

nonprofit organization to manage fundraising 

campaigns and coordinate volunteer activities.

Several commenters offered ideas for specific 

partnerships with various organizations and 

agencies. The JCCH, Hospice, and Project 

Dana were identified as potential collaborators 

in recording oral histories. One suggestion 

involved the creation of a center for social 

justice associated with UHWO, while another 

respondent recommended programming in 

association with the King Kamehameha V 

Judiciary History Center. The proximity of the 

Honouliuli Forest Reserve to Honouliuli Gulch 

was highlighted as an opportunity for regional 

recreation. Another commenter suggested that 

an NPS unit at Honouliuli would serve as an 

appropriate complement to the developing 

Pearl Harbor Historic Trail.

Personal Stories and Reflections

While comments in support of alternative B and 

partnerships comprised the vast majority of all 

comments received, a significant proportion 

of remaining comments offered personal 

stories and reflections on the importance of 

Hawaiʻi’s World War II internment history. 

Many respondents, particularly those 

attending the public meetings, had a personal 

connection to Honouliuli Internment Camp 

and/or the associated internment sites. Several 

commenters were the children or grandchildren 

of individuals incarcerated and expressed a 

deep investment in preserving and sharing the 

experiences of their family members. Some 

remembered visiting their parents at Honouliuli 

or other internment sites and the distress and 

fear they felt during their visits.

Other reflections addressed the impact of the 

incarceration on Hawaiʻi’s Japanese American 

community, including the loss of livelihood 

and community position endured by internees, 

and their reluctance to speak about their 

experiences. Some comments specifically 

highlighted the effect of the internment on 

families both of European and Japanese 

descent. A few shared their memories of the 

bombing of Pearl Harbor and what occurred 

during the following days. Several people 

reflected on the climate of fear and wartime 

hysteria during World War II in Hawai‘i. Some 

people also expressed how the internment of 

their family members had forever impacted 

their lives; they felt shame in being Japanese and 

that their family members had been interned 

during World War II.

Associated Sites

Many commenters expressed a strong desire 

to recognize all World War II internment sites 

throughout the Hawaiian Islands. Although 

it was understood that only the Honouliuli 

Internment Camp is proposed for inclusion 

in the national park system under alternative 

B, several individuals suggested that the other 

sites should somehow be recognized. They 

suggested that small plaques, waysides, or 

mobile applications could help with identifying 

the WWII internment sites. Some emphasized 

the need to preserve the incarceration story on 

other islands through increased research and 

interpretation. One respondent requested that 

the NPS also consider designation of another 

World War II-related site, Ewa Field.

Several comments in this category highlighted 

the significance of the U.S. Immigration 

Station and the Sand Island Detention Camp 

in Honolulu, and many stated that these 

sites should be fully interpreted in order to 

convey a comprehensive understanding of 

the incarceration history in the islands. A few 

respondents relayed their concern that the 

U.S. Immigration Station was not included 
Summary of Public Comments  Visitor Experience and Interpretation 167

as a feasible addition to the national park 

system under alternative B (due to the current 

use of the facility by the U.S. Department of 

Homeland Security and the Hawaiʻi State 

Department of Health). These respondents 

wished to ensure that the U.S. Immigration 

Station could be designated in the future if the 

facility were vacated by its current occupants. 

The significance of the U.S. Immigration 

Station to the internment history, as well as the 

high degree of exposure it receives due to its 

location, were cited as contributing factors to its 

importance.

Commenters additionally asked that Sand 

Island be commemorated in order to recognize 

its significance as Oʻahu’s first detention camp 

and that it held hundreds of internees before 

they were transported to the mainland. People 

wanted to somehow convey its harsh living 

conditions, which were more severe than those 

at Honouliuli. One respondent suggested that 

such interpretation could be provided along a 

historic trail leading from the U.S. Immigration 

Station to Sand Island and then to Honouliuli 

Internment Camp.

A few commenters recommended that technical 

assistance, grants, and partnerships be pursued 

to support interpretation at all sites. However, 

some people also expressed concerns that 

interpretation of associated sites might impinge 

on private property rights. These respondents 

asked that the NPS stress that interpretation and 

technical assistance to associated sites in private 

ownership be purely voluntary.

The U.S. Department of Homeland Security 

expressed concern about interpretive features 

or other measures that would solicit public 

visitation to the U.S. Immigration Station 

and adversely impact the operations of the 

U.S. Immigration and Customs Enforcement 

operational component at this site.

Visitor Experience and 

Interpretation

A substantial number of comments were 

submitted relating to the visitor experience and 

interpretation at Honouliuli Internment Camp, 

should the site be designated a national park 

unit.

Commenters on this topic largely emphasized 

the need to interpret Hawaiʻi’s internment 

history in its full breadth and complexity. Some 

stressed the need to describe the differences 

between incarceration in the islands and on the 

mainland. Several others expressed a strong 

desire that the story be told from multiple 

angles, including the perspectives of the many 

and diverse groups affected by the internment. 

A few respondents asked that Hawaiʻi’s 

confinement sites be interpreted within the full 

context of Hawaiian history, stretching from 

ancient history to the present. Many noted that 

the best way to convey this history is through 

the voices and stories of those who experienced 

it firsthand.

 People commenting on interpretation and 

education offered ideas for future educational 

and interpretive initiatives, citing the value 

of the site and its resources to youth and the 

American public. Advocates for educational 

programming at Honouliuli suggested providing 

scholarship and internship opportunities 

and curriculum support for teachers. Some 

stated that the internment history in Hawai‘i 

is especially relevant to civil rights abuses 

occurring today, and that a potential NPS unit 

at Honouliuli could offer significant lessons in 

citizenship for young people.

The importance of physically visiting the 

site was also identified as a tangible way 

to demonstrate the sense of isolation and 

punishing conditions suffered by internees. 

Many suggested that the camp structures 

should be recreated; however others felt that 

the history of the site could be powerfully 

conveyed through other visual means, including 

digital technology. Suggestions were offered for 

various exhibit displays, film, and other media, 

including a virtual tour and digital applications 

that could connect all of the internment sites 

across the islands.

A smaller number of people provided 

suggestions for specific site development and 

facilities at Honouliuli. Some recommended 

that new facilities on the site be targeted toward 

student use. Specific suggestions for new 

facilities included a learning center or visitor 

center with audio-visual capacity, bathrooms, 

and a monument. It was additionally noted that 

significant community discussions have already 

taken place surrounding the future development 
168 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

of Honouliuli Internment Camp, through a 

visioning charrette hosted by JCCH. The NPS 

was asked to take this existing planning work 

into account in future site planning.

Resource Protection

Several comments underscored the need to 

protect historic resources and archeological 

features at Honouliuli Internment Camp. 

Threats identified included nearby 

development, flooding and erosion in the gulch, 

wildfire, and encroachment by invasive species. 

One respondent questioned whether the site 

would be evaluated for hazardous materials.

The stories of survivors were also identified as a 

primary resource, and many commenters stated 

that the recording of oral histories should be a 

priority. The need to acquire collections items 

was cited, including personal belongings and 

objects created by prisoners; it was noted that a 

curatorial facility would ultimately be required 

to adequately protect collections.

Access and Transportation

The majority of concerns on this topic were 

related to access to the potential new unit. 

Access was identified as an urgent need for 

the site; securing an access road was described 

by several people as a crucial requirement for 

Honouliuli’s designation. Various logistical 

issues were discussed in association with 

possible roadway alignments, including 

landownership and traffic associated with 

the H-1 freeway. One commenter suggested 

that the public enter the historic site from its 

historic entry point . Universal accessibility 

was acknowledged as an important future 

consideration for site planning.

In addition, a few commenters observed 

that the site’s close proximity to a major 

metropolitan area makes it easily accessible to 

many different groups of people, in contrast to 

mainland confinement sites that are located in 

remote areas.

Management and Operations

The vast majority of comments relating to 

future management and operations addressed 

the subject of entrance fees. Many asked that 

entrance fees to Honouliuli be waived, as at 

World War II Valor in the Pacific National 

Monument, should the site become an NPS 

unit. Some respondents suggested that fees be 

waived or reduced at the very least for students 

and youth; others noted that donations could 

be accepted in lieu of fees. A few individuals 

asked about operations and what it would 

mean for the potential new unit to be overseen 

by World War II Valor in the Pacific National 

Monument. One person observed that this 

offered an opportunity to connect the NPS 

sites thematically as well as operationally. 

One comment cited a need for security at the 

potential new unit, and another respondent 

stated that Monsanto operations should not be 

allowed to continue on the site after donation 

and designation.

Funding

The availability of secure funding to support an 

NPS unit at Honouliuli was another concern 

voiced by respondents. While the draft study 

report stated that federal appropriations for 

the unit would be supplemented by public 

and private sources in the form of grants and 

partnerships, a few commenters questioned the 

likelihood of receiving the full funds necessary 

for operation. Others expressed their support 

for partner involvement in fundraising.

Land Use

Land use-related comments were submitted by 

the State of Hawaiʻi Office of Planning and the 

University of Hawaiʻi–West Oʻahu (UHWO). 

The NPS was asked to determine whether 

the proposed designation of Honouliuli 

Internment Camp would have an impact on 

coastal resources, and to submit if necessary 

a consistency determination to the Hawaiʻi 

Coastal Zone Management (CZM) Program. 

Similarly, the NPS was alerted to the potential 

need to prepare a Best Management Practices 

plan to prevent pollution to coastal waters that 

might occur through site development activities. 

The NPS was additionally asked to describe in 

the draft study report the relationship between 

the proposed designation and existing state 

and county plans. The impact of a possible 

designation on UHWO lands was questioned, 

and UHWO stated their desire to continue to 

support Honouliuli Gulch as a key partner while 

maintaining the rights to develop university 

lands to their highest and best potential.
Summary of Public Comments  Information Relevant to the Study and Technical Edits 169

Information Relevant to the 

Study and Technical Edits

Over the course of the public comment period, 

some participants shared new historical 

information about the WWII internment in 

Hawai‘i and how individuals and communities 

were affected. This information included the 

economic significance of Japanese immigration 

to Hawaiʻi, the impact of martial law on 

the internment, the cultural and religious 

effects of the internment on individuals 

and communities, and details about living 

conditions and personal experiences at the 

internment sites. Respondents in particular 

cited the unique experiences of the few women 

and children interned at Honouliuli, as well 

as prisoners of war from Korea and Okinawa. 

Some commenters suggested that the report 

could include the stories of families of Japanese 

descent who voluntarily left the islands to 

join husbands and fathers incarcerated on 

the mainland. One respondent asked that 

information be included about internees who 

returned to Japan after World War II. 

A few individuals contributed new information 

about the associated sites documented in the 

draft special resource study. This included new 

information about the history and location of 

the Maui County Jail and the Haʻikū Military 

Camp on Maui, new details about the Kalāheo 

Stockade on Kauaʻi, and the location of a 

potential new associated site near the Hilo 

Airport on the island of Hawaiʻi.

A few people commented on the level of detail 

included in the draft study report/EA. While 

most felt that a suitable level of detail was 

provided, a few requested that the NPS include 

more detailed historical information in the 

document. A few commenters also provided 

useful technical edits to the draft study report.

Planning Process

Some respondents provided feedback on 

the planning process, stating that they were 

extraordinarily pleased that the NPS had 

invited their participation and was hosting 

the series of public meetings throughout the 

Hawaiian Islands. A small number of individuals 

recommended that the planning team leverage 

social media and petitions to engage additional 

participants in the planning process, and one 

commenter suggested that the NPS reach out 

to former prisoners of war to include their 

perspective on the designation. A few people 

asked questions relating to the timeline for the 

overall designation process, were it to occur; 

the reality of funding support for the site; and 

the likelihood that the necessary land would be 

donated to the National Park Service.

Honouliuli Day of Remembrance. Photo: NPS, 2011.
170 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

RESPONSE TO SUBSTANTIVE 

COMMENTS ON THE DRAFT 

STUDY REPORT/EA

The study team reviewed all comments 

submitted on the Honouliuli Gulch and 

Associated Sites Draft Special Resource Study 

and Environmental Assessment. The following 

substantive comments were organized and 

analyzed by topic areas that correlate with 

sections of the draft study report/EA. The 

study team grouped similar comments before 

providing the National Park Service response. 

A substantive comment is defined by NPS 

Director’s Order 12 (DO-12, Section 4.6A) as 

one that does one or more of the following:

Őquestions, with reasonable basis, 

the accuracy of information in the 

environmental analysis

Őquestions, with reasonable basis, the 

adequacy of environmental analysis

Őpresents reasonable alternatives other 

than those presented in the environmental 

analysis

Őcauses changes or revisions in the proposal

Comments that contain substantive points 

regarding information in the draft study report/

EA or comments that need clarification are 

extracted below. Concern statements have 

been developed to summarize the comments. 

Corrections to the draft study report/EA 

are included in an errata document that 

is available on the study website. The final 

recommendations for the study are included 

in the Final Recommendations summary 

document and are also documented in the 

Finding of No Significant Impact (October 

2014). The draft study report/EA, errata to 

the draft study report, and the Finding of No 

Significant Impact together complete the study 

process.

Historical Background

Concern: Important historical information 

about the history of internment in Hawaiʻi 

was not included in the study, such as the 

importance of the U.S. terminating immigration 

from Japan in 1924, the legal question of 

interning U.S. citizens in Hawaiʻi, and why some 

families chose voluntary internment.

Response: The study has been updated to 

reflect this new information in chapter 2.

Concern: New information was provided about 

the individuals who were interned at Honouliuli 

Internment Camp, such as children, women, 

and individuals of Filipino heritage. 

Response: Chapter 2 of the study has 

been updated to identify the individuals 

and populations that were interned at 

Honouliuli Internment Camp.

Associated Internment Sites

Concern: Concerns were raised about private 

property rights for internment sites that are 

located on private property. There was concern 

about federal designation of privately owned 

sites, the potential for public trespass, the 

location of historical markers, and questions 

about eminent domain.

Response: The preferred alternative 

has been revised to emphasize that any 

recognition of, or assistance to, associated 

sites would be voluntary at the request of 

the landowner and/or site manager. See 

Chapter 6: Alternatives, Alternative B, 

Technical Assistance.

Concern: Under alternative B, the NPS 

authority for providing technical assistance is 

unclear. This needs more explanation in the 

study. 

Response: The NPS has authority under 

existing historic preservation laws and 

programs to provide assistance upon 

request for the preservation of historic 

resources. However, the preferred 

alternative recommends that if legislation 

were to authorize a new park unit at 

Honouliuli, such authorizing legislation 

would provide the authority for NPS to 

partner or provide assistance to related sites. 

Such assistance would only be provided 

when requested or desired by the site’s 

landowner and/or site manager. See Chapter 

6: Alternatives, Alternative B, Technical 

Assistance.
Response to Substantive Comments on the Draft Study Report/EA  Other World War II Sites 171

Concern: The other internment sites should 

receive recognition for their historical 

significance related to the World War II 

internment history in Hawaiʻi. Plaques, markers, 

and some level of interpretation and designation 

is warranted.

Response: In the preferred alternative, the 

NPS could provide technical assistance in 

interpreting and/or preserving related sites. 

Such assistance would only occur where 

it is appropriate and desired by the site 

landowner.

Concern: The U.S. Immigration Station is 

nationally significant and suitable for inclusion 

in the national park system. It should be 

considered for national park designation if it 

becomes available. 

Response: The special resource study 

states that if the U.S. Immigration Station 

facilities were no longer needed by the 

U.S. Department of Homeland Security or 

the Hawaiʻi State Department of Health, 

additional NPS analysis would be needed 

to determine the feasibility of management 

options and associated costs, particularly 

with regard to the cost of operations and 

maintenance given the size and scale of 

the facilities. Legislation or presidential 

proclamation would be required for 

inclusion in the national park system.

Concern: The U.S. Department of Homeland 

Security expressed concern about any 

interpretive efforts that might bring visitors to 

the U.S. Immigration Station. Such activities 

could potentially hamper criminal investigations 

and may have public safety repercussions.

Response: The NPS has removed language 

about opportunities to provide interpretive 

exhibits or waysides at the U.S. Immigration 

Station. The study further clarifies that any 

interpretation regarding associated sites 

would be at the discretion of site owners or 

managers. 

Concern: Sand Island played a significant 

role in the internment history. Most people 

were interned there, and it operated for over 

15 months. There should be some type of 

recognition or commemoration, such as a 

marker or monument.

Response: Recognition or commemoration 

of internment on Sand Island can occur 

without any NPS designation or action. If 

the preferred alternative were implemented 

then the NPS could provide assistance in 

interpreting or recognizing Sand Island 

where it is appropriate and desired by the 

site landowner.

Concern: New information was provided 

about associated internment sites, including the 

location of Haʻikū Camp, status of the Waiākea 

Prison Camp, a possible new internment 

location in Hilo, and resources associated with 

Kalāheo Stockade.

Response: The study has been updated to 

reflect this new information throughout the 

document.

Concern: The historical information provided 

about the internment location in the Maui 

County Jail on pages 36–38 is inaccurate. 

Internees were imprisoned in a facility that 

was demolished in 1970. The location of the 

facility was approximately at 600 Waiale Road 

in Wailuku and the current location of the Maui 

County Correctional Center. 

Response: The study has been updated to 

reflect this new information. Additional 

research is needed to determine whether 

the Maui County Courthouse and Police 

Station were used for internment.

Other World War II Sites

Concern: The federal government should also 

consider the historical significance, designation, 

and acquisition of other important World War 

II era sites on O‘ahu, namely Ewa Field. The site 

is currently at risk of development and should 

be included in the NPS unit World War II Valor 

in the Pacific National Monument because of 

its imminent loss. This should be done before 

Honouliuli is considered for designation. 
172 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Response: Ewa Field was not used for 

internment during World War II, and the 

evaluation of Ewa Field as an addition to 

World War II Valor in the Pacific National 

Monument is beyond the scope of the 

Congressionally authorized Honouliuli 

Gulch and Associated Sites Special Resource 

Study. 

Land Use

Concern: The State of Hawai‘i, Office of 

Planning stated that the study should: 1) include 

related land use maps including a map of state 

land use districts, the ‘Ewa Development Plan 

Urban Land Use Map, and maps showing 

the soil quality in the vicinity of the proposed 

project.

Response: The draft study report has been 

revised to include the maps of the state land 

use districts and the ʻEwa Development Plan

Urban Land Use Map. A map of soils was 

not included as this topic was dismissed 

from the environmental analysis. The NPS 

recognizes that soil quality would be a 

consideration in any implementation plans 

should a national park unit be designated. 

Concern: The study should also: 1) address 

the relationship of the proposed project with 

relevant state and county plans such as the 

Hawai‘i State Plan, City and County of Honolulu 

General Plan, and ‘Ewa Development Plan and 

2) indicate what permits are required for the 

proposed project. 

Response: A discussion of the relationship 

of the proposed project with relevant state 

and local plans has been added on page 95 

in Chapter 5: Feasibility, and page 138 in 

Chapter 7: Environmental Consequences. 

While the NPS does evaluate whether a 

potential national park unit would generally 

be compatible with zoning and land use, at 

the special resource study level of evaluation 

the NPS does not propose any specific 

facilities or development. Therefore the 

NPS cannot determine at this time what 

permits would be required for future use 

and development. If a National Park Service 

unit were established at the Honouliuli 

site, the NPS would conduct additional 

planning efforts to determine appropriate 

facilities. Such planning efforts would be 

conducted in compliance with the National 

Environmental Policy Act and would 

include appropriate consultation with 

federal, state, and local agencies.

Concern: The State of Hawai‘i, Office of 

Planning stated, “In accordance with 15 CFR 

§ 930.33(a), the NPS as the proposing federal 

agency must determine whether the proposed 

activity will affect any coastal use or resource of 

the Hawaii Coastal Zone Management (CZM) 

area. If the federal agency determines that 

the proposed activity will have a reasonably 

foreseeable direct or indirect effect on the state’s 

coastal uses or resources, then a consistency 

determination must be provided to the Hawaii 

CZM Program for review, pursuant to 15 

CFR § 930.34.” In addition: “Due to the close 

proximity of the Honouliuli Internment Camp 

to the waters of Pearl Harbor and Manele Bay, 

site improvements and facilities development 

may have nonpoint pollution implications 

on coastal waters. If there is any trenching 

work or ground disturbance and/or grading 

and clearing work at the site, it may result in 

erosion and sediment loss and have a negative 

environmental impact. If so, the Hawaii CZM 

program recommends that the applicant 

prepare a Best Management Practices plan.” 

Response: Designation of Honouliuli 

Internment Camp as a unit of the National 

Park System would not have a direct impact 

on coastal zone areas. If an NPS unit were 

to be established, more detailed planning 

for facilities and use of the site would be 

necessary. Consultation with state and 

local agencies would occur as part of the 

planning process. The NPS would strive to 

minimize any potential impacts to coastal 

areas and resources and would comply with 

any applicable federal and state laws.

University of Hawai‘i—West 

O‘ahu

Concern: UHWO is concerned about “the 

future impact the NPS site may have on the 

development of the University’s mauka lands. 
Response to Substantive Comments on the Draft Study Report/EA  Access and Transportation 173

It is critical that the University have the ability 

to utilize and develop the mauka lands to their 

highest and best potential for the benefit of our 

University students and our community. We 

must therefore preserve our rights to develop 

both University and non-University related uses 

on any portion of the 991-acre mauka lands 

including the 285 acres currently contemplated 

for inclusion in the NPS boundary.”

Response: The proposed national historic 

site or monument boundary has been 

reduced at the request of the University 

of Hawaiʻi. Discussions between the 

NPS and the University of Hawai‘i have 

identified approaches to public access 

that do not require inclusion of university 

lands in an NPS boundary at this time. 

The NPS appreciates the University of 

Hawaiʻi’s commitment to working with 

the NPS on granting access to the site over 

university lands should a national park 

unit be established. Future road access 

could be added to the national historic 

site or monument boundary once a more 

permanent road alignment has been 

determined. 

Concern: UHWO’s “current planning effort 

envisions that the mauka lands be considered 

for both University and non-University related 

development uses.”

Response: The study has been updated to 

reflect that University of Hawai’i planning 

efforts are also considering non-university 

related development uses for the mauka 

lands.

Concern: UHWO would like “to negotiate 

acceptable terms and conditions for road access 

rights over the university lands, recognizing that 

the future site planning will identify the road 

alignment and road easement, which may be 

different than what is included in the study.”

Response: Long-term public access 

to the site is required for an NPS unit 

at Honouliuli to be feasible. The NPS 

appreciates UHWO willingness to work 

together to find acceptable terms and 

conditions for road access over UHWO 

lands. 

Access and Transportation 

Concern: If the 7-acre parcel is developed as 

the primary staging location for visitor access 

to Honouliuli Gulch, planning should consider 

how people with mobility impairments can 

access Honouliuli Gulch. 

Response: If Honouliuli Internment 

Camp were designated as a national park 

unit, the types of programs, facilities, and 

visitor experiences at Honouliuli would 

be determined through implementation 

planning. Through implementation 

planning, the NPS would explore 

opportunities for direct access and 

experience in the gulch for all people, i.e. 

universal access. Site planning would occur 

following a designation. The NPS would 

fully consider previous site plans and work 

done by others in the site planning process.

Concern: Additional work is needed to 

ensure public access to the site in order to 

experience the site and learn about its World 

War II internment history. One idea is to 

consider using historic alignments, so that 

visitors are literally walking in the footsteps of 

the internees. Another idea is to consider the 

viability of an access route to Honouliuli from 

the proposed Makakilo Drive Extension. 

Response: If Honouliuli Internment Camp 

were designated as a national park unit, 

specific access routes would be determined 

through implementation planning in 

cooperation with nearby landowners. 

Transportation planning for access 

routes would consider visitor experience, 

feasibility and cost of specific routes, and 

other factors in identifying specific routes. 

Concern: The study should consider increased 

traffic if there is an access route to Honouliuli 

off of the H-1. 
174 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Response:The level of impact on local 

traffic would be dependent on the level of 

access provided (shuttle, onsite parking, 

etc.). If Honouliuli Internment Camp were 

designated as a national park unit, the 

types of programs, facilities, and visitor 

experiences would be determined through 

implementation planning.

Visitor Experience

Concern: The study should consider different 

types of programs, facilities, and visitor 

experiences for raising awareness about the 

World War II internment in Hawai‘i. One idea is 

a historical trail linking the internment sites on 

O‘ahu and other islands. 

Response: If Honouliuli Internment Camp 

were designated as a national park unit, 

the types of programs, facilities, and visitor 

experiences would be determined through 

implementation planning.

Funding and Operations

Concern: How can funding to properly 

preserve the site be ensured, either through 

federal appropriations and/or partner 

contributions? 

Response: NPS would be responsible 

for resource preservation and park 

operations. Federal funding levels would 

be determined by annual appropriations. 

Typically, new national parks have 

limited staff and funding during initial 

establishment. Increased staffing and 

funding would happen incrementally over 

time as implementation planning identifies 

specific objectives for park management. 

Partnership collaboration could result in 

increased capacity to preserve and interpret 

the site (i.e., funding, volunteers, in-kind 

donations). The NPS Japanese American 

Confinement Sites Grant Program would be 

a possible funding source for partners.

Concern: There would be a substantial cost and 

burden on taxpayers for road development to 

provide public access to Honouliuli.

Response: The cost of providing road 

access would be further explored 

through implementation planning when 

identification of potential routes and 

desired public access levels would be 

evaluated. There could be opportunities 

for the NPS to share development and 

maintenance costs for road access. 

Partnerships

Concern: Partners, including UHWO and 

JCCH, have done significant work in preserving, 

researching, promoting, and interpreting 

Honouliuli and the World War II internment 

history in Hawai‘i. The study should recognize 

these efforts and ensure that these important 

partners continue to have a significant role in 

the future of Honouliuli, even if designated as a 

unit of the NPS.

Response: Page 108 of the draft study 

report (Chapter 5: Feasibility, Public 

Interest and Support) describes the 

extensive work completed by partners 

to document, preserve, and interpret 

Honouliuli and other confinement sites. 

The NPS recognizes the past and current 

efforts by partners, and NPS assumes this 

would continue and would seek to maintain 

existing partnerships and build new 

partnerships. Additional acknowledgement 

of these contributions have been included 

in the alternatives considered in the the 

study. 

The NPS has also included additional 

text in the selected alternative (Chapter 6: 

Alternatives, Alternative B, Partnerships) 

to recognize the significant contributions 

of existing organizations, such as the 

Japanese Cultural Center of Hawaiʻi and the 

University of Hawaiʻi in the documentation 

and interpretation of Honouliuli Internment 

Camp and other World War II internment 

sites in Hawaiʻi. Opportunities for future 

partnerships with these organizations 

have also been referenced in the selected 

alternative.
APPENDICES
Fragment of surviving barbed wire, Honouliuli Internment Camp, 2010. Photo: Valentino Valdez.
Appendices  Appendix A: Study Legislation 175

APPENDICES 

Appendix A: Study Legislation

On Oct. 30, 2009, P.L. 111-88, Division A, Department of the Interior, Environment, and Related 

Agencies Appropriations Act, was signed into law. Title I, Section 125, “Honouliuli Special Resource 

Study,” authorizes the Secretary of the Interior to complete a special resource study of the Honouliuli 

Gulch and associated sites. The following is the text of the legislation that pertains to the Honouliuli 

Special Resource Study.

DEPARTMENT OF THE INTERIOR, ENVIRONMENT, AND RELATED AGENCIES 

APPROPRIATIONS ACT, 2010 

PUBLIC LAW 111-88—OCT. 30, 2009

111th Congress

An Act

Making appropriations for the Department of the Interior, environment, and related agencies for the 

fiscal year ending September 30, 2010, and for other purposes.

Be it enacted by the Senate and House of Representatives of the United States of America in 

Congress...

SEC. 125. Honouliuli Special Resource Study.

(a) IN GENERAL.—The Secretary of the Interior (referred to in this section as the ‘‘Secretary’’) 

shall conduct a special resource study of the national significance, suitability, and feasibility of 

including the Honouliuli Gulch and associated sites within the State of Hawaii in the National Park 

System.

(b) GUIDELINES.—In conducting the study, the Secretary shall use the criteria for the study of 

areas for potential inclusion in the National Park System described in section 8 of Public Law 91-

383 (16 U.S.C. 1a-5).

(c) CONSULTATION.—In conducting the study, the Secretary shall consult with—

1. the State of Hawaii;

2. appropriate Federal agencies;

3. Native Hawaiian and local government entities;

4. private and nonprofit organizations;

5. private land owners; and

6. other interested parties.;

(d) THEMES.—The study shall evaluate the Honouliuli Gulch, associated sites located on O‘ahu, 

and other islands located in the State of Hawaii with respect to—

1. the significance of the site as a component of World War II;

2. the significance of the site as the site related to the forcible internment of Japanese 

Americans, European Americans, and other individuals; and

3. historic resources at the site.

(e) REPORT.—Not later than 2 years after the date of enactment of this Act, the Secretary 

shall submit to the Committee on National Resources of the House of Representatives and the 

Committee on Energy and Natural Resources of the Senate a report describing the findings, 

conclusions, and recommendations of the study required under this section.

Approved Oct. 30, 2009
176 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Appendix B: 2006 NPS 

Management Policies (Sections 

1.2 and 1.3) 

1.2 THE NATIONAL PARK SYSTEM 

The number and diversity of parks within 

the national park system grew as a result of a 

government reorganization in 1933, another 

following World War II, and yet another 

during the 1960s. Today there are nearly 400 

units in the national park system. These units 

are variously designated as national parks, 

monuments, preserves, lakeshores, seashores, 

wild and scenic rivers, trails, historic sites, 

military parks, battlefields, historical parks, 

recreation areas, memorials, and parkways. 

Regardless of the many names and official 

designations of the park units that make up 

the national park system, all represent some 

nationally significant aspect of our natural or 

cultural heritage. They are the physical remnants 

of our past—great scenic and natural places that 

continue to evolve, repositories of outstanding 

recreational opportunities, classrooms of our 

heritage, and the legacy we leave to future 

generations—and they warrant the highest 

standard of protection. 

It should be noted that, in accordance with 

provisions of the Wild and Scenic Rivers Act, 

any component of the National Wild and Scenic 

Rivers System that is administered by the Park 

Service is automatically a part of the national 

park system. Although there is no analogous 

provision in the National Trails System Act, 

several national trails managed by the Service 

have been included in the national park system. 

These national rivers and trails that are part 

of the national park system are subject to the 

policies contained herein, as well as to any other 

requirements specified in the Wild and Scenic 

Rivers Act or the National Trails System Act.

1.3 CRITERIA FOR INCLUSION 

Congress declared in the National Park 

System General Authorities Act of 1970 that 

areas comprising the national park system are 

cumulative expressions of a single national 

heritage. Potential additions to the national 

park system should therefore contribute in 

their own special way to a system that fully 

represents the broad spectrum of natural and 

cultural resources that characterize our nation. 

The National Park Service is responsible for 

conducting professional studies of potential 

additions to the national park system when 

specifically authorized by an act of Congress, 

and for making recommendations to the 

Secretary of the Interior, the President, and 

Congress. Several laws outline criteria for units 

of the national park system and for additions to 

the National Wild and Scenic Rivers System and 

the National Trails System.

To receive a favorable recommendation from 

the Service, a proposed addition to the national 

park system must (1) possess nationally 

significant natural or cultural resources, (2) be a 

suitable addition to the system, (3) be a feasible 

addition to the system, and (4) require direct 

NPS management instead of protection by other 

public agencies or the private sector. These 

criteria are designed to ensure that the national 

park system includes only the most outstanding 

examples of the nation’s natural and cultural 

resources. These criteria also recognize that 

there are other management alternatives for 

preserving the nation’s outstanding resources. 

1.3.1 National Significance 

NPS professionals, in consultation with subjectmatter experts, scholars, and scientists, will 

determine whether a resource is nationally 

significant. An area will be considered nationally 

significant if it meets all of the following criteria:

It is an outstanding example of a particular type 

of resource. 

It possesses exceptional value or quality in 

illustrating or interpreting the natural or cultural 

themes of our nation’s heritage. 

It offers superlative opportunities for public 

enjoyment or for scientific study. 

It retains a high degree of integrity as a true, 

accurate, and relatively unspoiled example of a 

resource.

National significance for cultural resources will 

be evaluated by applying the National Historic 

Landmarks criteria contained in 36 CFR Part 65 

(Code of Federal Regulations). 
Appendices  Appendix B: 2006 NPS Management Policies (Sections 1.2 and 1.3) 177

1.3.2 Suitability 

An area is considered suitable for addition to the 

national park system if it represents a natural 

or cultural resource type that is not already 

adequately represented in the national park 

system, or is not comparably represented and 

protected for public enjoyment by other federal 

agencies; tribal, state, or local governments; or 

the private sector. 

Adequacy of representation is determined on a 

case-by-case basis by comparing the potential 

addition to other comparably managed areas 

representing the same resource type, while 

considering differences or similarities in the 

character, quality, quantity, or combination of 

resource values. The comparative analysis also 

addresses rarity of the resources, interpretive 

and educational potential, and similar resources 

already protected in the national park system 

or in other public or private ownership. The 

comparison results in a determination of 

whether the proposed new area would expand, 

enhance, or duplicate resource protection 

or visitor use opportunities found in other 

comparably managed areas.

1.3.3 Feasibility 

To be feasible as a new unit of the national park 

system, an area must be (1) of sufficient size and 

appropriate configuration to ensure sustainable 

resource protection and visitor enjoyment 

(taking into account current and potential 

impacts from sources beyond proposed park 

boundaries), and (2) capable of efficient 

administration by the Service at a reasonable 

cost.

In evaluating feasibility, the Service considers 

a variety of factors for a study area, such as the 

following:

Ősize

Őboundary configurations

Őcurrent and potential uses of the study area 

and surrounding lands

Őlandownership patterns

Őpublic enjoyment potential

Őcosts associated with acquisition, 

development, restoration, and operation

Őaccess

Őcurrent and potential threats to the 

resources

Őexisting degradation of resources

Őstaffing requirements

Őlocal planning and zoning

Őthe level of local and general public support 

(including landowners)

Őthe economic/socioeconomic impacts of 

designation as a unit of the national park 

system

The feasibility evaluation also considers the 

ability of the National Park Service to undertake 

new management responsibilities in light of 

current and projected availability of funding 

and personnel. 

An overall evaluation of feasibility will be made 

after taking into account all of the above factors. 

However, evaluations may sometimes identify 

concerns or conditions, rather than simply 

reach a yes or no conclusion. For example, 

some new areas may be feasible additions to 

the national park system only if landowners are 

willing to sell, or the boundary encompasses 

specific areas necessary for visitor access, 

or state or local governments will provide 

appropriate assurances that adjacent land uses 

will remain compatible with the study area’s 

resources and values. 

1.3.4 Direct NPS Management 

There are many excellent examples of the 

successful management of important natural 

and cultural resources by other public agencies, 

private conservation organizations, and 

individuals. The National Park Service applauds 

these accomplishments and actively encourages 

the expansion of conservation activities by state, 

local, and private entities and by other federal 

agencies. Unless direct NPS management of a 

studied area is identified as the clearly superior 

alternative, the Service will recommend that one 

or more of these other entities assume a lead 

management role, and that the area not receive 

national park system status. 

Studies will evaluate an appropriate range of 

management alternatives and will identify 

which alternative or combination of alternatives 

would, in the professional judgment of the 

Director, be most effective and efficient in 

protecting significant resources and providing 

opportunities for appropriate public enjoyment. 

Alternatives for NPS management will not be 
178 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

developed for study areas that fail to meet any 

one of the four criteria for inclusion listed in 

section 1.3. 

In cases where a study area’s resources meet 

criteria for national significance but do not meet 

other criteria for inclusion in the national park 

system, the Service may instead recommend an 

alternative status, such as “affiliated area.” To 

be eligible for affiliated area status, the area’s 

resources must (1) meet the same standards 

for significance and suitability that apply to 

units of the national park system; (2) require 

some special recognition or technical assistance 

beyond what is available through existing NPS 

programs; (3) be managed in accordance with 

the policies and standards that apply to units of 

the national park system; and (4) be assured of 

sustained resource protection, as documented 

in a formal agreement between the Service and 

the nonfederal management entity. Designation 

as a “heritage area” is another option that 

may be recommended. Heritage areas have a 

nationally important, distinctive assemblage of 

resources that is best managed for conservation, 

recreation, education, and continued use 

through partnerships among public and 

private entities at the local or regional level. 

Either of these two alternatives (and others as 

well) would recognize an area’s importance 

to the nation without requiring or implying 

management by the National Park Service.
Appendices  Appendix C: National Historic Landmark Criteria Sec 65.4 179

Appendix C: National Historic 

Landmark Criteria Sec 65.4

The criteria applied to evaluate properties 

for possible designation as National Historic 

Landmarks or possible determination of 

eligibility for National Historic Landmark 

designation is listed below. These criteria shall 

be used by NPS in the preparation, review and 

evaluation of National Historic Landmark 

studies. They shall be used by the Advisory 

Board in reviewing National Historic Landmark 

studies and preparing recommendations to 

the Secretary. Properties shall be designated 

National Historic Landmarks only if they are 

nationally significant. Although assessments of 

national significance should reflect both public 

perceptions and professional judgments, the 

evaluations of properties being considered 

for landmark designation are undertaken by 

professionals, including historians, architectural 

historians, archeologists and anthropologists 

familiar with the broad range of the nation’s 

resources and historical themes. The criteria 

applied by these specialists to potential 

landmarks do not define significance nor set a 

rigid standard for quality. Rather, the criteria 

establish the qualitative framework in which a 

comparative professional analysis of national 

significance can occur. The final decision 

on whether a property possesses national 

significance is made by the Secretary on the 

basis of documentation including the comments 

and recommendations of the public who 

participate in the designation process.

(a) Specific Criteria of National Significance: 

The quality of national significance is ascribed 

to districts, sites, buildings, structures and 

objects that possess exceptional value or quality 

in illustrating or interpreting the heritage 

of the United States in history, architecture, 

archeology, engineering and culture and that 

possess a high degree of integrity of location, 

design, setting, materials, workmanship, feeling 

and association, and:

1. That are associated with events that have 

made a significant contribution to, and 

are identified with, or that outstandingly 

represent, the broad national patterns 

of United States history and from which 

an understanding and appreciation of 

those patterns may be gained; or That are 

associated importantly with the lives of 

persons nationally significant in the history 

of the United States; or

2. That represent some great idea or ideal of 

the American people; or

3. That embody the distinguishing 

characteristics of an architectural type 

specimen exceptionally valuable for a study 

of a period, style or method of construction, 

or that represent a significant, distinctive 

and exceptional entity whose components 

may lack individual distinction; or 

4. That are composed of integral parts of the 

environment not sufficiently significant by 

reason of historical association or artistic 

merit to warrant individual recognition 

but collectively compose an entity of 

exceptional historical or artistic significance, 

or outstandingly commemorate or illustrate 

a way of life or culture; or

5. That have yielded or may be likely to yield 

information of major scientific importance 

by revealing new cultures, or by shedding 

light upon periods of occupation over 

large areas of the United States. Such sites 

are those which have yielded, or which 

may reasonably be expected to yield, data 

affecting theories, concepts and ideas to a 

major degree.

(b) Ordinarily, cemeteries, birthplaces, graves 

of historical figures, properties owned by 

religious institutions or used for religious 

purposes, structures that have been moved 

from their original locations, reconstructed 

historic buildings and properties that have 

achieved significance within the past 50 years 

are not eligible for designation. Such properties, 

however, will qualify if they fall within the 

following categories:

1. A religious property deriving its primary 

national significance from architectural or 

artistic distinction or historical importance; 

or

2. A building or structure removed from its 

original location but which is nationally 

significant primarily for its architectural 

merit, or for association with persons or 

events of transcendent importance in 
180 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

the nation’s history and the association 

consequential; or

3. A site of a building or structure no longer 

standing but the person or event associated 

with it is of transcendent importance in 

the nation’s history and the association 

consequential; or

4. A birthplace, grave or burial if it is of a 

historical figure of transcendent national 

significance and no other appropriate site, 

building or structure directly associated 

with the productive life of that person 

exists; or

5. A cemetery that derives its primary national 

significance from graves of persons of 

transcendent importance, or from an 

exceptionally distinctive design or from an 

exceptionally significant event; or

6. A reconstructed building or ensemble 

of buildings of extraordinary national 

significance when accurately executed in 

a suitable environment and presented in a 

dignified manner as part of a restoration 

master plan, and when no other buildings 

or structures with the same association have 

survived; or

7. A property primarily commemorative in 

intent if design, age, tradition, or symbolic 

value has invested it with its own national 

historical significance; or 

8. A property achieving national significance 

within the past 50 years if it is of 

extraordinary national importance.
Appendices  Appendix D: Japanese American Wartime Incarceration Properties 181

Appendix D: Japanese American Wartime Incarceration Properties

Name of Property Location Status of Federal/

State Designations1

Tangible Recognition: 

Markers, Monuments, 

Memorials, and Museums2

Wartime Civil Control Administration

Fresno Assembly Center Fresno County, CA No Federal designation, 

CA Historical Landmark

Marker, 1992; memorial, 2010

Marysville Assembly 

Center, aka Arboga 

Assembly Center

Yuba County, CA No Federal designation, 

CA Historical Landmark

None known

Mayer Assembly Center Yavapai County, AZ No Federal designation None known

Merced Assembly Center Merced County, CA No Federal designation, 

CA Historical Landmark

Marker, 1982; monument and 

memorial plaza, 2010

Pinedale Assembly 

Center

Fresno County, CA No Federal designation, 

CA Historical Landmark

Memorial plaza

Pomona Assembly 

Center

Los Angeles County, 

CA

No Federal designation, 

CA Historical Landmark

None known

Portland Assembly 

Center

Multnomah County, 

OR

No Federal designation Marker

Puyallup Assembly 

Center, aka Camp 

Harmony

Pierce County, WA No Federal designation Memorial courtyard with 

sculpture and markers

Sacramento Assembly 

Center, aka Walerga 

Assembly Center

Sacramento County, 

CA

No Federal designation, 

CA Historical Landmark

Marker, 1987; memorial grove 

of cherry trees

Salinas Assembly Center Monterey County, CA No Federal designation, 

CA Historical Landmark

Marker, 1984; Day of 

Remembrance Memorial 

Garden, 2010

Santa Anita Assembly 

Center

Los Angeles County, 

CA

Determined eligible for 

National Register 2006, 

CA Historical Landmark

Marker

Stockton Assembly 

Center

San Joaquin County, 

CA

No Federal designation, 

CA Historical Landmark

Marker

Tanforan Assembly 

Center

San Bruno, San Mateo 

County, CA

No Federal designation, 

CA Historical Landmark

Marker

Tulare Assembly Center Tulare County, CA No Federal designation, 

CA Historical Landmark

None known

Turlock Assembly Center Stanislaus County, CA No Federal designation, 

CA Historical Landmark

Marker, 2010

1 Federal designation includes listing in the National Register of Historic Places, designation as a National 

Historic Landmark, or some other Federal effort to honor the site for its relation to the Japanese American 

wartime experience.

2 A marker identifies the site and its relation to the World War II experience of Japanese Americans; text generally 

is mounted on a post or solid base. A monument is an artistic work that serves as a memorial to the Japanese 

American wartime experience. A memorial is a space dedicated to the Japanese American wartime experience, 

and may include landscape, architectural, sculptural, and educational elements. Museums include exhibits that 

interpret Japanese American wartime experiences.
182 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Name of Property Location Status of Federal/

State Designations

Tangible Recognition: 

Markers, Monuments, 

Memorials, and Museums

War Relocation Authority Centers

Gila River Relocation 

Center: Butte Camp and 

Canal Camp

Pinal County, AZ None Markers at both camps; 

memorial exhibit at Gila River 

Indian Reservation Cultural 

Center

Granada Relocation 

Center, aka Amache

Prowers County, CO National Register 5-18-

94; National Historic 

Landmark 2-10-06; 

National Historic Site 

1-9-07

Cemetery with monument

Heart Mountain 

Relocation Center 

Park County, WY National Register 12-

19-85; National Historic 

Landmark 9-20-06

Memorial park with markers 

and honor roll; Interpretive 

Learning Center, August 2011

Jerome Relocation Center Chicot and Drew 

Counties, AR 

None Monument

Manzanar Relocation 

Center, originally Owens 

Valley Reception Center

Inyo County, CA National Register 7-30-

76; National Historic 

Landmark 2-4-85; 

National Historic Site 

1992; CA Historical 

Landmark 1972

Memorial cemetery; markers; 

monument; interpretive 

center

Minidoka Relocation 

Center

Jerome County, ID National Register 7-10-

79; National Monument 

2001; National Historic 

Site 2008

Monument; markers; exhibit 

at Jerome County Historical 

Museum; state marker on 

State Highway 25

Poston Relocation 

Center: Poston I, II, and 

III

La Paz County, AZ None Memorial with monument 

and educational kiosk, 1992

Rohwer Relocation 

Center

Desha County, AR National Register 

7-30-74

None

Rohwer Memorial 

Cemetery

Desha County, AR National Register 7-6-

92; National Historic 

Landmark 7-6-92

Memorial cemetery with 

monuments and markers

Topaz Relocation Center, 

aka Central Utah or 

Abraham Relocation 

Center

Millard County, UT National Register 1-2-

74; National Historic 

Landmark 3-29-07

Original monument, 1976; 

replacement monument, 

2002; monument to Topaz 

soldiers, 2005

Tule Lake Relocation 

Center

Modoc County, CA National Register 

2-17-06; National 

Historic Landmark 

2-17-06; WWII Valor 

in the Pacific National 

Monument 12-5-08; CA 

Historical Landmark

Monument, 1979; marker 

and collections at BLM in 

Klamath Falls, at Modoc 

County Fairgrounds, and 

at Lava Beds National 

Monument

War Relocation Authority Internment/Detention Facilities

Leupp Isolation Camp Coconino County, AZ No Federal designation None known

Moab Isolation Center Grand County, UT National Register 5-2-

94 (Dalton Wells CCC 

Camp/Moab Relocation 

Center)

None known
Appendices  Appendix D: Japanese American Wartime Incarceration Properties 183

Name of Property Location Status of Federal/

State Designations

Tangible Recognition: 

Markers, Monuments, 

Memorials, and Museums

Camp Tulelake Tule Lake National 

Wildlife Refuge, CA

No Federal designation None known

War Relocation Authority Centers, Supplementary Sites

Antelope Springs BLM/Fillmore, Millard 

County, UT

No Federal designation None known

Cow Creek Camp Death Valley National 

Park, Inyo County, CA

Cow Creek Historic 

District, determined NR 

eligible for association 

with CCC, 1989

None known

Department of Justice Internment/Detention Facilities

Catalina Federal Honor 

Camp

Coronado National 

Forest, AZ

Named “Gordon 

Hirabayashi Recreation 

Site” by U.S. Forest 

Service, 1999

Interpretive kiosk built by 

USFS

Crystal City Internment 

Camp (INS)

Zavala County, TX No Federal designation Texas State Marker, 2007; 

monument, 1980s

Fort Lincoln Internment 

Camp (INS)

Bismarck, Burleigh 

County, ND

No Federal designation None known

Fort Missoula Internment 

Camp (INS)

Missoula County, MT National Register 

4-29-87

Monument and museum; now 

called “Historical Museum at 

Fort Missoula”

Fort Stanton Lincoln County, NM National Register 

4-13-73

Museum

Kenedy Internment 

Camp (INS)

Karnes County, TX No Federal designation Texas State Subject Marker 

at camp cemetery; marker 

in Kenedy; and materials at 

Kenedy Public Library

Kooskia Internment 

Camp

Clearwater National 

Forest, Idaho County, 

ID

No Federal designation None known

Old Raton Ranch Camp Santa Fe County, NM No Federal designation None known

Santa Fe Internment 

Camp

Santa Fe County, NM No Federal designation Marker

Seagoville Internment 

Camp (WRA camp)

Dallas County, TX No Federal designation None known

Sharp Park Detention 

Facility

Pacifica, San Mateo 

County, CA

No Federal designation None known

U.S. Federal Penitentiary, 

Leavenworth

Leavenworth County, 

KS

No Federal designation None known

U.S. Federal Penitentiary, 

McNeil Island

Steilacoom, Pierce 

County, WA

No Federal designation None known

U.S. Immigration Station, 

Ellis Island

New York Harbor, NY National Register 10-

15-66; part of Statue 

of Liberty National 

Monument

Exhibit on Japanese American 

wartime experiences opened 

in July 2010

U.S. Immigration Station, 

O‘ahu

Honolulu County, HI National Register 

8-14-73

None known
184 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Name of Property Location Status of Federal/

State Designations

Tangible Recognition: 

Markers, Monuments, 

Memorials, and Museums

U.S. Army Detention Facilities 

Angel Island, North 

Garrison of Fort 

McDowell

Marin County, CA National Register 10-

14-71; National Historic 

Landmark 12-9-97; CA 

Historical Landmark; 

now Angel Island State 

Park

Markers, monument, and 

museum

Camp Florence Florence, Pinal 

County, AZ

No Federal designation None known

Camp Forrest Tullahoma, Coffee 

County, TN

No Federal designation None known

Camp Livingston Alexandria, Rapides 

Parish, LA

No Federal designation None known

Camp Lordsburg Hidalgo County, NM No Federal designation Museum nearby

Fort Bliss El Paso County, TX National Register 5-7-98 

(included in Fort Bliss 

Main Post Historic 

District)

None known

Fort George G. Meade Anne Arundel County, 

MD 

No Federal designation None known

Fort Richardson Anchorage Borough, 

AK

No Federal designation None known

Fort Sam Houston San Antonio, TX National Register 5-15-

75; National Historic 

Landmark 5-15-75 (not 

for Japanese American 

association)

None known

Fort Sill Internment 

Camp

Comanche County, OK National Register 10-

15-66 (not for Japanese 

American association); 

National Historic 

Landmark 12-19-60

None known

Honouliuli Internment 

Camp

Honolulu County, HI National Register 

2-21-2012

None known

Kilauea Military Camp Hawai‘i County, HI No Federal designation None known

Sand Island Detention 

Camp

Honolulu County, HI No Federal designation None known

Stringtown Internment 

Camp

Stringtown, Atoka 

County, OK

No Federal designation None known

Other Internment/Detention Facilities

Haʻikū Camp Maui County, HI No Federal recognition None known

Hilo Independent 

Japanese Language 

School

Hawai‘i County, HI No Federal designation None known
Appendices  Appendix D: Japanese American Wartime Incarceration Properties 185

Name of Property Location Status of Federal/

State Designations

Tangible Recognition: 

Markers, Monuments, 

Memorials, and Museums

Honolulu Police 

Department and 

Yokohama Specie Bank

Honolulu County, HI National Register 

6-19-1973 (included 

in Merchant Street 

Historic District, not 

for Japanese American 

association)

None known

Kalāheo Stockade Kaua‘i County, HI No Federal designation None known

Kaua‘i County 

Courthouse

Kaua‘i County, HI National Register 12-

17-1981 (included in 

Līhuʻe Civic Center 

Historic District, not 

for Japanese American 

association)

None known

Lānaʻi City Jail and 

Courthouse

Maui County, HI No Federal designation None known

Līhuʻe Plantation 

Gymnasium

Kaua‘i County, HI No Federal designation None known

Maui County Courthouse 

and Police Station

Maui County, HI National Register 

8-20-1988 (included in 

Wailuku Civic Center 

Historic District, not 

for Japanese American 

association)

None known

Maui County Jail Maui County, HI No Federal designation None known

Waiākea Prison Camp Hawai‘i County, HI No Federal designation None known

Wailua County Jail Kaua‘i County, HI No Federal designation None known

Waimea County Jail Kaua‘i County, HI No Federal designation None known
186 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Appendix E: Finding of No Significant Impact

HONOULIULI GULCH AND ASSOCIATED SITES 

SPECIAL RESOURCE STUDY AND ENVIRONMENTAL ASSESSMENT

Hawaiʻi

October 2014

INTRODUCTION

The Department of the Interior, Environment, and Related Agencies Appropriations Act of 2010, 

Title 1, Section 125 (123 Stat. 2932), October 30, 2009) authorized the National Park Service (NPS) to 

“conduct a special resource study of the national significance, suitability, and feasibility of including 

the Honouliuli Gulch and associated sites within the State of Hawai‘i in the National Park System.” 

The purpose of this special resource study is to determine whether the Honouliuli Gulch and 

associated sites in Hawai‘i are eligible to be designated as a unit of the national park system. Through 

the study process, the NPS identified alternative strategies to manage, protect, or interpret the sites’ 

resources. The study conveys information to the U.S. Department of the Interior and Congress to aid 

in determining whether designation of a unit of the national park system is desirable and appropriate.

The study evaluates 17 sites associated with the history of internment in Hawai‘i. In this study, the 

NPS ascertained the public’s level of interest in nationally recognizing this part of United States 

history and evaluated whether one or more of the sites would be appropriate for designation as 

a national park system unit. The NPS identified alternative strategies to manage and protect the 

resources, and to provide or enhance public understanding, use and enjoyment of the sites. Cost 

estimates for operations, acquisition and development are also included.

Through this study, the National Park Service finds that the Honouliuli Internment Camp property, 

located in Honouliuli Gulch, is nationally significant, suitable, feasible, and appropriate for NPS 

management. This document identifies the selection of the most effective and efficient alternative 

(“the selected alternative”) and the basis for a determination that completion of the study results in no 

associated significant impacts on the human environment.

PURPOSE AND NEED

The purpose of this study is to comply with the Department of the Interior, Environment, and Related 

Agencies Appropriations Act of 2010, Title 1, Section 125 (123 Stat. 2932), October 30, 2009) which 

directed the Secretary of the Interior to conduct a special resource study of Honouliuli Gulch and 

associated sites described above. The legislation also stated, “The study shall evaluate the Honouliuli 

Gulch, associated sites located on O‘ahu, and other islands located in the State of Hawai‘i with respect 

to— 

1. the significance of the site as a component of World War II;

2. the significance of the site as the site related to the forcible internment of Japanese Americans, 

European Americans, and other individuals; and

3. historic resources at the site.”

The study follows the process established by the National Park System New Area Studies Act (P.L. 

105-391, 16 U.S.C. Sec. 1a-5). This law requires that these studies be prepared in compliance with the 

National Environmental Policy Act of 1969 (42 U.S.C. §§ 4321- 4347). This study complies with the 

National Historic Preservation Act, Section 106 and 110 requirements. Section 106 requires federal 

agencies to take into account the effects of their undertakings on historic properties. At the beginning 
Appendices  Appendix E: Finding of No Significant Impact 187

of the study process, the NPS initiated a notice of scoping that was published in the Federal Register 

on May 2, 2011 (Vol.76, No. 83, 24514–15). Through the initial public scoping process, the NPS 

identified a range of issues to address through the study, as well as impacts of concern to the public.

This study is needed to provide the Secretary of the Interior and Congress with information on 

opportunities for management of the resources found within the study area. It identifies and analyzes 

alternatives for the management, administration, and protection of those resources, and evaluates 

their appropriateness for becoming a unit of the national park system.

STUDY SITES

The study evaluates 17 sites associated with the history of internment in Hawaiʻi. The list of sites 

was developed based on information obtained through personal interviews, declassified documents 

from the Federal Bureau of Investigation and Department of Justice, military files, newspapers, 

photographs, and numerous books and essays. The University of Hawaiʻi, Japanese Cultural Center of 

Hawaiʻi, and Trans-Sierran Archaeological Research provided information about internment sites in 

Hawaiʻi. Site visits by the study team were conducted where possible to determine current conditions 

and integrity of the sites.

The sites evaluated include the Honouliuli Internment Camp, Sand Island, the U.S. Immigration 

Station, Honolulu Police Department, and Honolulu Military Police Station on O‘ahu; the Kilauea 

Military Camp, Waiākea Prison, and the Hilo Independent Japanese Language School on the island 

of Hawaiʻi; Ha‘ikū Camp and Maui County Jail on Maui; the Kaunakakai Jail on Molokaʻi; the Lāna‘i 

City Jail on Lāna‘i; and the Kalāheo Stockade, Waimea Jail, Wailua Jail, Līhu‘e Plantation Gymnasium, 

and Kaua‘i County Courthouse on Kaua‘i.

EVALUATION OF NATIONALLY SIGNIFICANT RESOURCES

The NPS has determined that the internment and incarceration of Japanese Americans and others 

during World War II on the mainland and in Hawai‘i are nationally significant events that shape our 

understanding and commitment to civil liberties and the fair treatment of all citizens, regardless of 

race. By identifying the commonalities and distinctions between mainland and Hawai‘i stories, this 

study concludes that the internment in Hawai‘i is of national significance, distinct from mainland 

incarceration. Through it, we are able to more fully understand the abrogation of civil liberties that 

occurred in the U.S. and its territories. 

The NPS has determined that two sites are nationally significant under the National Park Service New 

Area Studies Act criteria: the Honouliuli Internment Camp and the U.S. Immigration Station. 

The Honouliuli Internment Camp was located in Honouliuli Gulch, west of Waipahu, on the island 

of O‘ahu. Opened in 1943, the Honouliuli Internment Camp was the last, largest, and longest-used 

World War II confinement site in Hawai‘i. The camp was built to intern Japanese and European 

Americans, Japanese and European resident aliens, and POWs captured in military operations 

during World War II. The internment camp held 320 internees, mostly second-generation Japanese 

Americans, but also Japanese, German, and Italian nationals. It was also the largest prisoner of war 

camp in Hawai‘i, incarcerating nearly 4,000 individuals. Recent archeological surveys have resulted 

in the identification of over 130 archeological features. Honouliuli Internment Camp, protected by its 

isolated location amidst agricultural lands and nearly hidden by dense vegetation for 60 years, appears 

to offer the greatest potential to preserve resources and interpret the history of the WWII internment. 

The U.S. Immigration Station, located on Ala Moana Boulevard in Honolulu, is nationally significant 

as the location where all Hawai‘i internees were processed or temporarily incarcerated after the 

attack on Pearl Harbor on December 7, 1941. Unlike most of the other internment sites in Hawai‘i 

that only served local, short-term needs, the U.S. Immigration Station had a broad, statewide role 

over an extended period. It served as a temporary internment location, but also as a center of legal 

administration. 
188 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

EVALUATION OF SUITABILITY

This study concludes that the Honouliuli Internment Camp and the U.S. Immigration Station, as 

described in the draft study report, are suitable for inclusion in the national park system, based upon 

an evaluation of the sites resources and their relative quality, character, and rarity. The Honouliuli 

Internment Camp and the U.S. Immigration Station contain themes and resources not found in any 

national park unit or comparably managed area.

EVALUATION OF FEASIBILITY

The study concludes that Honouliuli Internment Camp is feasible as an addition to the national park 

system if public access to the site can be secured. Current land use, ownership patterns, and zoning 

associated with Honouliuli Internment Camp would not conflict with management of a national park 

unit. Primary resources associated with the camp are located on property owned by the Monsanto 

Company, which has expressed interest in donating the property to the NPS for establishment of 

a national park unit. Surrounding lands are currently in agricultural use which is compatible with 

the camp’s historic setting. However, feasibility is conditional on securing public access to the site. 

As current access is primarily over unpaved agricultural roads, improvements would be needed to 

accommodate access by the general public. An appropriate boundary configuration would include the 

historic site and would allow for access and visitor facilities.

The study concludes that the U.S. Immigration Station is not feasible as an addition to the national 

park system because of existing uses by the U.S. Department of Homeland Security and the State 

of Hawai‘i, Department of Public Health. If the facilities were no longer needed by federal or state 

agencies, additional analysis would be needed to determine the feasibility of management options and 

associated costs. 

NEED FOR NPS MANAGEMENT

The study concludes that there is a need for NPS management of the Honouliuli Internment Camp in 

partnership with others to fully protect resources and to enhance visitor appreciation of the nationally 

significant resources and important stories associated with the site. The incorporation of Honouliuli 

Internment Camp into the national park system would offer a visitor experience that allows the 

broadest understanding of the resources and stories relating to the internment of Japanese Americans 

and European Americans in Hawai‘i during World War II.

ALTERNATIVES ANALYZED

Two alternatives were analyzed in the Honouliuli Gulch and Associated Sites Draft Special Resource 

Study and Environmental Assessment. The alternatives are based on the purpose and need for the 

project and are consistent with existing laws and NPS policy.

Alternative A: Continuation of Current Management (No Action Alternative)

Sites, organizations, and programs significant to the internment history in Hawaiʻi would continue to 

be operated independently by existing landowners, agencies, or organizations without additional NPS 

management or assistance other than what is currently available through existing authorities and grant 

programs.

Alternative B: Honouliuli National Historic Site or National Monument—A New 

Unit of the National Park System

Congress would establish Honouliuli National Historic Site as a new unit of the national park system. 

Alternatively, a national monument managed by the National Park Service could be established. 

The national historic site or national monument would include the historic site of the Honouliuli 

Internment Camp and would allow for access and visitor facilities. The National Park Service would 

preserve the site and interpret the internment of Japanese Americans and European Americans 

in Hawaiʻi during World War II. The national historic site or monument would be supported by 
Appendices  Appendix E: Finding of No Significant Impact 189

operational capacity at World War II Valor in the Pacific National Monument, Pearl Harbor. The 

National Park Service could respond to requests to provide technical assistance for the preservation 

and interpretation of other sites, features, and stories related to internment in Hawaiʻi during World 

War II.

THE SELECTED ALTERNATIVE

National Historic Site or National Monument—A New Unit of the National Park 

System

The recommendations encompassed in the selected alternative are the same as those identified 

and analyzed in alternative B in the environmental assessment, with the exception of modifications 

made as a result of information and comments derived from public review of the draft study and 

environmental assessment, as follows:

ŐThe proposed national historic site or monument boundary has been reduced at the request 

of the University of Hawaiʻi—West O‘ahu. Discussions between the NPS and the University of 

Hawaiʻi have identified approaches to public access that do not require inclusion of University 

of Hawaiʻi land in an NPS boundary at this time. The University of Hawaiʻi is committed to 

working with the NPS on granting access to the site over University lands should a national 

park unit be established. Future road access could be added to the national historic site or 

monument boundary once a more permanent road alignment has been determined. 

ŐMinor modifications have also been made to address concerns regarding universal access to 

the site, potential partnerships, and technical assistance opportunities. 

The above modifications would not constitute a change in environmental impacts beyond what was 

analyzed in the environmental assessment.

CONCEPT

The selected alternative would establish Honouliuli National Historic Site as a new unit of the 

national park system. Alternatively, a national monument managed by the National Park Service could 

be established. The national historic site or national monument would include the historic site of the 

Honouliuli Internment Camp and adjacent lands that would allow for access and visitor facilities. 

In collaboration with partners, the National Park Service would preserve the site and interpret the 

internment of Japanese Americans and European Americans in Hawaiʻi during World War II. The 

national historic site or monument would be supported by operational capacity at World War II 

Valor in the Pacific National Monument, Pearl Harbor. The National Park Service could respond to 

requests to provide technical assistance for the preservation and interpretation of other sites, features, 

and stories related to internment in Hawaiʻi during World War II. 

PROPOSED AREA

The Honouliuli National Historic Site or National Monument would total approximately 155 acres 

(See Map: Alternative B (Selected Alternative), page 123.) The historic Honouliuli Internment Camp 

and the adjacent overlook parcel (totaling approximately 123 acres) would be acquired by the NPS 

through a donation by the Monsanto Company. Additional Monsanto-owned lands (31.5 acres) 

with related resources could be protected through conservation easements, land transfer, or other 

measures at Monsanto’s discretion. All private property rights would be respected. 

The University of Hawai‘i has committed to providing NPS with public access to Honouliuli, initially 

through granting the NPS a right of entry over existing roads from the west. The University of 

Hawai‘i is currently undergoing planning efforts for its lands adjacent to Honouliuli. This process, 

and subsequent planning by the NPS should a national park unit be established, may identify a 

new road alignment for public access. Once a desired road alignment for public access has been 
190 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

determined, this road alignment could be included in the national historic site or national monument 

through a boundary adjustment. This would allow the National Park Service to expend funds on the 

development and maintenance of the access road.

Three parcels owned by the City and County of Honolulu Board of Water Supply (totaling 0.6 acres) 

would be inholdings within the proposed area and would remain under current ownership and 

management. The communications facilities, non-contributing features within the historic site, would 

not be included in the proposed boundary.

MANAGEMENT

The NPS would have direct management responsibility for the Honouliuli National Historic Site 

or National Monument including: 1) interpretation and education associated with the Honouliuli 

Internment Camp and its resources, including the development of interpretive media and programs; 

2) preservation and resource management for the historic site; and 3) operational facilities and 

infrastructure such as roads, restrooms, and trails.

RESOURCE PROTECTION

NPS staff would protect and preserve resources related to Honouliuli Internment Camp. 

Management plans would guide appropriate historic preservation documentation and treatments. As 

described below, there are opportunities to partner with local institutions and organizations in the 

protection of resources.

VISITOR EXPERIENCE

Visitors would have the opportunity to learn about Honouliuli Internment Camp, World War II 

internment in Hawaiʻi, martial law, civil liberties, and peace and reconciliation through a wide variety 

of interpretive and educational programs onsite and at offsite locations. Interpretation would be 

accessible and relevant to diverse audiences and multiple generations. Virtual visitor experiences 

would be explored so that people could learn about and experience Honouliuli and related sites 

without actually visiting the sites. Programs could be provided by NPS rangers, partners, and 

volunteers. Information could be presented in multiple languages.

PARTNERSHIPS

Other entities, specifically University of Hawaiʻi—West O‘ahu and the Japanese Cultural Center 

of Hawaiʻi, have completed significant work to document, preserve, and interpret the Honouliuli 

Internment Camp and the larger history of internment in Hawai‘i during World War II. The NPS 

would seek to maintain these partnerships for future management of the Honouliuli National Historic 

Site or Monument. In addition, the NPS would explore, develop, and maintain new partnerships for 

the preservation and interpretation of Honouliuli Internment Camp and related sites, features, and 

stories in Hawaiʻi. 

There are substantial opportunities for partnerships related to Honouliuli National Historic Site 

or Monument with public agencies, educational institutions, nonprofit entities, and individuals. 

Potential partnership projects could include the development of educational programs, development 

of facilities, resource stewardship activities such as preservation of historic features and vegetation 

clearing, and research projects. Partnerships could also include shared facilities for interpretation, 

curatorial storage, operations, and maintenance. 

TECHNICAL ASSISTANCE

World War II-era internment and incarceration sites in Hawai‘i other than Honouliuli Internment 

Camp would continue to be owned and managed by their respective public and private owners. The 

associated sites illustrate the broad-reaching effects of internment on the six major islands in Hawai‘i 

and are valuable in accurately interpreting this history. 
Appendices  Appendix E: Finding of No Significant Impact 191

Upon request, the NPS could work cooperatively with associated site owners and managers to 

explore opportunities for interpretation and/or preservation of the associated sites. Any request for 

technical assistance related to the associated sites would be voluntary on the part of the landowner.

Where appropriate, the NPS could also conduct research and respond to requests for assistance to 

related sites that have yet to be identified.

OPERATIONS

Staffing

Honouliuli National Historic Site or Monument would be managed through World War II Valor in 

the Pacific National Monument at Pearl Harbor, given its close proximity and related history. Some 

staff positions at World War II Valor in the Pacific National Monument would be shared. However, 

management of the site would require additional staff as funding became available. A management 

plan would identify priorities, management emphases, and required staffing for a 15 to 20 year 

timeframe. 

Based on comparisons of staffing levels for existing national historic sites of similar scale and 

management models, the following types of staff would be recommended:

ŐSite manager

ŐCultural resource specialist 

ŐInterpretive specialist 

ŐInterpretive ranger (2)

ŐLaw enforcement ranger

ŐMaintenance (2)

ŐExotic plant management technician

Positions could be permanent, temporary, or seasonal. In addition, partner organizations could 

provide staff or volunteers, with types and numbers dependent upon the functions provided.

OPERATIONAL AND VISITOR FACILITIES

Comprehensive management planning would guide the development of facilities for Honouliuli 

National Historic Site or National Monument. Facilities would be needed to support public access, 

circulation, orientation, and learning about the history of internment in Hawaiʻi. The 7-acre overlook 

site could serve as a visitor staging area with ample space to provide for parking, visitor dropoff, interpretive features, and restrooms. The site is located just outside of the historic camp and 

offers views to Pearl Harbor, downtown Honolulu, and Diamond Head. Within the gulch, visitor 

facilities would be minimal to preserve the site’s historic integrity. Facilities might include trails, 

interpretive waysides, primitive roads, and vault toilets. Implementation planning would also explore 

opportunities for persons of all abilities to access and experience Honouliuli Internment Camp.

Currently there is no public access to Honouliuli Internment Camp. Rights of access would be 

required to provide public access to the 7-acre overlook parcel and the historic site. Existing roads 

would require considerable improvement to accommodate visitor access. As noted above, the 

University of Hawai‘i has indicated its commitment to working with the National Park Service with 

regard to providing public access on existing and future roads through its lands.

The Federal Highway Administration (FHA) estimated construction costs for public and 

administrative access using existing road alignments would range from $3 to 20 million. This dollar 

amount would also include parking and turnaround areas for buses. The higher end of the range 

would be incurred if additional reconstruction or realignment is necessary for road improvements. 

Costs would need to be reevaluated after a formal site survey and through completion of a 

comprehensive management plan. 
192 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Shuttle or bus service from either World War II Valor in the Pacific National Monument or UHWO 

was also evaluated by the FHA. Costs to operate a bus connection from World War II Valor in the 

Pacific National Monument three times per week were estimated at $25,000 to 30,000 annually. Costs 

to operate a bus or shuttle from University of Hawaiʻi—West O‘ahu twice daily were estimated at 

$91,000 to 112,000 annually.

NPS management of a national historic site at Honouliuli Gulch would be funded through federal 

appropriations as part of the annual NPS budget and through potential partners and grants. The 

national historic site or monument could share administrative, visitor, and operational facilities 

with World War II Valor in the Pacific National Monument or partner entities. Non-federal entities 

would continue to be eligible for the grants through the Japanese American Confinement Sites Grant 

Program for preservation, interpretation, and documentation projects associated with Honouliuli 

Internment Camp.

Based on the size and scope of this site, and the types of services and assistance proposed, the annual 

cost of NPS operations for the national historic site could be expected to be $400,000 to $750,000. 

The estimated operational budget would primarily fund NPS staff, programs, projects, and outreach. 

Specific costs would be reevaluated in subsequent, more detailed planning for the unit. Planning 

would consider facility and site design, detailed identification of resource protection needs, and 

changing visitor expectations. Actual costs to the NPS would vary depending on timing and 

implementation and contributions by partners and volunteers. It is assumed that the long-range 

financial needs of Honouliuli National Historic Site or Monument would not just rely upon federally 

appropriated funds. A variety of other public and private funding sources could be sought by the NPS 

to assist in implementation efforts. Other NPS units have successfully found partners to help with 

funding major projects, and some of the costs associated with actions in the alternatives may prove to 

be less expensive if donated materials, labor, and other support can be secured.

ENVIRONMENTALLY PREFERRED ALTERNATIVE

The “environmentally preferred” alternative is the course of action that would best protect, preserve 

and enhance historic, cultural and natural resources, and that would cause the least damage to the 

biological and physical environment. The environmentally preferred alternative is not the same as 

an agency’s “preferred” or “most effective and efficient” alternative. The NPS has determined that 

the selected alternative, Alternative B: Honouliuli National Historic Site or Monument—A Unit of 

the National Park System, would be the environmentally preferable alternative because it would 

protect the nationally significant cultural resources and natural resources and provide opportunities 

for visitors to learn about the history and experience of Japanese American and European American 

incarceration during World War II.

WHY THE SELECTED ALTERNATIVE WILL NOT HAVE A SIGNIFICANT EFFECT ON THE 

QUALITY OF THE HUMAN ENVIRONMENT

The NPS has determined that the selected alternative can be recommended with no significant 

adverse effects on biological resources, cultural resources, recreation resources, socioeconomics, land 

use, or water resources. This determination is based on the environmental impact analysis published 

in the draft study report which examined the effects of Alternative A: Continuation of Management 

and Alternative B: Honouliuli National Historic Site or Monument—A Unit of the National Park 

System.

As defined in 40 CFR § 1508.27, significance of impacts is determined by examining the ten criteria 

below.
Appendices  Appendix E: Finding of No Significant Impact 193

Impacts that may be both beneficial and adverse. A significant effect may exist even if the federal 

agency believes that on balance the effect will be beneficial.

The NPS evaluated the potential environmental consequences of each alternative related to the 

following topics: cultural resources; visitor use and experience; socioeconomics; land use; and water 

resources. A range of minor impacts and beneficial effects is associated with the selected alternative 

(alternative B).

Environmental effects would generally be beneficial. The impact analysis for all alternatives is 

necessarily broad to avoid speculation as to site-specific impacts, given the broad nature of the study. 

The outcome of the study is a recommendation to Congress. If Congress enacts the recommendations 

in this study, then specific actions would be developed and new environmental analyses would be 

undertaken prior to implementation.

With the establishment of a national park unit, the nationally significant cultural resources within the 

Honouliuli Gulch would be protected under federal law. The technical assistance provided by the 

National Park Service to the related sites would be a benefit to the cultural resources at those sites 

with the development of preservation planning efforts.

An access and transportation plan would be developed as part of planning for the new national park 

unit. These plans would be beneficial to the protection of the site and the visitor experience. 

Visitor opportunities would be planned and developed at the site providing a positive visitor 

experience. Effective planning of the visitor opportunities will provide protection to the cultural and 

natural resources.

There will be beneficial impacts on socioeconomics to local communities. Commercial services 

available in the developing University of Hawai‘i—West O‘ahu area could benefit from increased 

heritage-related tourism.

The selected alternative would benefit the biological resources by improving the protection of water 

quality and developing a plan for and managing nonnative vegetation. 

The degree to which the proposed action affects public health or safety.

Because this level of study does not lend itself to meaningful environmental analysis of this topic, the 

topic was dismissed from additional analysis.

Unique characteristics of the geographic area such as proximity to historic or cultural resources, 

park lands, prime farmlands, wetlands, wild and scenic rivers, or ecologically critical areas.

The study area is surrounded by ALISH (Agricultural Lands of Importance to the State of Hawaiʻi) 

and the area immediately adjacent to the Honouliuli Gulch is considered prime and unique farmland. 

If Honouliuli Gulch becomes a unit of the national park system, there will be close coordination with 

surrounding land owners and no adverse impacts to resources have been identified.

The Honouliuli Internment Camp and the U.S. Immigration Station have been evaluated and 

identified as being nationally significant by the National Historic Landmarks Program. The 

establishment of Honouliuli Internment Camp as a national park unit will provide preservation to 

these significant resources.

The degree to which effects on the quality of the human environment are likely to be highly 

controversial.

No highly controversial effects, resulting from actions proposed in the alternatives, have been 

identified during either initial public scoping, preparation of the environmental assessment, or the 

public review period. The vast majority of comments supported selection of alternative B.
194 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

The degree to which the possible effects on the quality of the human environment are highly 

uncertain or involve unique or unknown risks.

There were no highly uncertain, unique or unknown risks identified during either the preparation of 

the environmental assessment or the public review period.

The degree to which the action may establish a precedent for future actions with significant 

effects or represents a decision in principle about a future consideration.

The study does not establish a precedent for future actions or represent a decision in principle 

because it only offers findings, based on completion of a prescribed evaluation process. These findings 

may be conveyed by the Secretary as recommendations to Congress. Development of specific actions 

responsive to the recommendations would require congressional or presidential establishment of 

a national park unit and would subsequently be refined through a management planning process, 

including unit-specific environmental analysis, if established.

Whether the action is related to other actions with individually insignificant but cumulatively 

significant impacts. Significance exists if it is reasonable to anticipate a cumulatively significant 

impact on the environment. Significance cannot be avoided by terming an action temporary or 

by breaking it down into small component parts.

Other past, present, or reasonably foreseeable actions were analyzed for their potential to contribute 

to cumulative impacts in association with implementation of the selected alternative, if enacted by 

Congress. 

The effects of the selected alternative would comprise a very small component of these cumulative 

impacts, given the size and scope of the landscape within and surrounding the study area. Overall, the 

predominantly beneficial impacts of the selected alternative, combined with the negligible to major 

adverse impacts from other past, present, and reasonably foreseeable future actions, would not result 

in a significant cumulative adverse effect.

The degree to which the action may adversely affect districts, sites, highways, structures, or 

objects listed in the National Register of Historic Places or may cause loss or destruction of 

significant scientific, cultural, or historic resources.

In general, the selected alternative would result in beneficial effects to the National Register of 

Historic Places properties and other significant scientific, cultural or historical resources. The overall 

intent of establishing a National Park Service unit at this site is to protect and preserve the significant 

cultural resources that are present. There could be minor impacts to cultural resources through 

improvements at the site for the health and safety of employees and visitors, but every effort will be 

made to avoid, minimize or mitigate these impacts.

Increased education and interpretation programs will result in a broader understanding of the 

significant cultural resources at the site and will likely result in greater preservation.

The degree to which the action may adversely affect an endangered or threatened species or its 

habitat that has been determined to be critical under the Endangered Species Act of 1973.

There are no threatened or endangered species in the area, therefore, this topic was not analyzed in 

the study.

Whether the action threatens a violation of federal, state, or local law or requirements imposed 

for the protection of the environment.

The selected alternative would not violate federal, state, or local environmental protection laws.
Appendices  Appendix E: Finding of No Significant Impact 195

PUBLIC ENGAGEMENT

Public Scoping

The NPS initiated public scoping for this study in February 2011. The scoping process included 

meetings with agencies, elected officials and organizations, public meetings and workshops, 

newsletters, a web page, and written public comments. These sources were used to identify the issues, 

significant resources, ideas for alternatives, and impact topics to be considered for environmental 

analysis.

The NPS study team used a variety of methods to notify the public and stakeholders of the study 

initiation. The NPS produced and distributed newsletters to the media, individuals, organizations, 

and government officials. The purpose of the newsletter was to introduce the study, explain the 

process to community members, and solicit comments on issues the study should address. The 

newsletter was published and made available for comment on the National Park Service’s Planning, 

Environment and Public Comment (PEPC) website. Press releases announcing the beginning of the 

study process and the public meeting schedule were distributed to local media. Numerous articles 

and opinion pieces about the study have appeared in area newspapers. 

In February and March 2011, the study team held a series of public scoping meetings on the six main 

islands in Hawaiʻi. The meetings were held in Waipahu, Kailua-Kona, Hilo, Kaunakakai, Lāna‘i City, 

Kahului, Līhuʻe, and Honolulu. The meetings were attended by more than 100 people who provided 

comments on the scope of the study and information about the internment sites. Additional input 

was gathered through meetings and conversations with various individuals, agencies, organizations, 

cities, and local, state and federal elected officials. The NPS received comments via written letters and 

through e-mail. 

The comment period extended to June 1, 2011, 30 days after publication of the notice of scoping in 

the Federal Register.

Public comments predominantly expressed the desire to commemorate the internment experience 

in Hawai‘i. People felt that internment and incarceration during World War II is an important part of 

Hawaiian history and noted the differences between the experiences of Japanese Americans on the 

mainland. Most stated that there are important lessons to be learned from this history. Commenters 

expressed strong support for partnerships and preservation of Honouliuli Internment Camp and 

associated sites’ resources. They also specifically expressed strong support for NPS management and 

involvement at the sites, particularly at Honouliuli Gulch.

Draft Report

The National Park Service (NPS) released the Honouliuli Gulch and Associated Sites Draft Special 

Resource Study and Environmental Assessment (draft study report/EA) on May 8, 2014. The public 

comment period was open from May 8 to July 15, 2014.

The NPS announced the release of the draft study report, public comment period, and public 

meetings through press releases. The NPS sent study reports to agencies, organizations, government 

representatives, and stakeholders. Paper and e-newsletters were sent to approximately 800 contacts. 

The project was launched on the NPS Planning, Environment, and Public Comment (PEPC) website 

and project website (www.nps.gov/pwro/honouliuli). These websites provided downloadable versions 

of the draft study report/EA, background information about the study, and an online form to receive 

public comments. The public was invited to submit comments by mail, e-mail, fax, online, at public 

workshops, and during an online public meeting.

In May and June 2014, the study team held a series of public meetings to present the draft study report 

and receive comments. The meetings were held in Kapolei, Honolulu, Līhuʻe , Kaunakakai, Kahului, 

Lāna‘i City, and Hilo. The public meetings in the Hawaiian Islands and the online public meeting were 

attended by 256 people. 
196 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

The NPS received comments from over 3,100 individuals, agencies, elected officials, and 

organizations. Approximately 95% of the comments were submitted as a result of an organized 

campaign initiated by the National Parks Conservation Association in support of alternative B, which 

proposes the designation of Honouliuli Internment Camp as a unit of the national park system. Sixtyfour individual comments were submitted via written letters, comment forms, e-mail, and through the 

PEPC online comment system.

The vast majority of the individual public comments also supported alternative B, the designation 

of Honouliuli Internment Camp as a unit of the national park system. Commenters overwhelmingly 

cited the need to preserve the story of Hawaiʻi’s World War II internment history and ensure 

protection of the site in perpetuity. Most wanted partners to be involved in the long-term care, 

interpretation, and public outreach for Honouliuli and the internment history in Hawai‘i. There 

were also comments about ensuring resource protection, additional historical information about the 

associated sites, concern about public access to Honouliuli, and ideas for visitor use if Honouliuli 

Internment Camp is to become a unit of the NPS.

A public comment and response report summarizing comments received by the National Park Service 

during the public comment period is available on the study website at www.nps.gov/pwro/honouliuli.

Agency Consultation

The National Park Service sent letters to the following agencies, organizations and businesses, and 

elected officials in May 2014 to notify them of the study process and to seek their input:

FEDERAL AGENCIES AND ELECTED OFFICIALS

Advisory Council on Historic Preservation

Congressional Representatives

 Senator Brian Schatz

 Senator Mazie K. Hirono

 Congresswoman Tulsi Gabbard

 Congresswoman Colleen Hanabusa

U.S. Department of Homeland Security

U.S. Department of Interior, Office of Native Hawaiian Relations

U.S. Fish and Wildlife Service

STATE AND LOCAL AGENCIES AND ELECTED OFFICIALS

City and County of Honolulu Planning

Governor Neil Abercrombie

Honolulu County

Honouliuli Park Site Advisory Committee

Senator Mike Gabbard

Senator Will Espero

Representative Richard Lee Fale

Department of Business, Economic Development, and Tourism

Department of Land and Natural Resources 

 State Historic Preservation Division

 State Parks Division

Department of Hawaiian Home Lands
Appendices  Appendix E: Finding of No Significant Impact 197

BUSINESSES, INSTITUTIONS, AND ORGANIZATIONS

‘Ahahui Siwila Hawai‘i O Kapolei

Bishop Museum

Hawai‘i Historical Society

Historic Hawaiʻi Foundation

Japanese American Citizens League

Japanese American National Museum

Japanese Cultural Center of Hawaiʻi

Kapolei Community Development Corporation

Monsanto Company

National Parks Conservation Association

National Parks Foundation

National Trust for Historic Preservation

Office of Hawaiian Affairs

Pacific Historic Parks

Society of Hawaiian Archaeology

University of Hawai‘i–Mānoa

University of Hawaiʻi–West Oʻahu

Select public libraries in the Hawaiian Islands

SECTION 106

To comply with NPS responsibilities for Section 106 of the National Historic Preservation Act, 

at the time of release of the draft study in May 2014, the NPS requested consultation by the State 

Historic Preservation Division to seek concurrence on 1) recognition of the special resource 

study undertaking, 2) the area of potential effect, 3) identification of historic properties within the 

Honouliuli Gulch area, and 4) finding of No Adverse Effect to historic properties. The State Historic 

Preservation Division concurred with these findings in a letter dated September 23, 2014.
198 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

FINDINGS

The NPS has determined that completion of this special resource study and recommendation 

of the most effective and efficient alternative to the Director does not constitute an action that 

normally requires an Environmental Impact Statement (EIS). The findings of the study will not have 

a significant effect on the human environment and no major environmental impacts are foreseen. 

There are no significant adverse impacts on public health, public safety, threatened or endangered 

species, historic properties either listed in or eligible for listing in the National Register of Historic 

Places, or other unique characteristics of the region. No highly uncertain or controversial impacts, 

unique or unknown risks, significant cumulative effects, or elements of precedence were identified. 

Implementation will not violate any federal, state, or local environmental protection law. This 

determination also included due consideration of the supportive nature of the public comments and 

agency, tribal and county recommendations which were received. Based on the foregoing, it has been 

determined that an environmental impact statement is not required for this special resource study and 

thus will not be prepared.

Approved:

 Christine S. Lehnertz Date

 Pacific West Regional Director
Appendices  Appendix F: Errata 199

Appendix F: Errata

August 2015

The following errata provide factual corrections, additions, and revisions to the Honouliuli Gulch and 

Associated Sites Draft Special Resource Study and Environmental Assessment (draft study report/

EA), dated May 2014. Changes to the draft study report/EA, and references to the page number where the 

change has occurred are provided. The reader must have access to a copy of the draft study report/EA in 

order to fully understand the changes.

 These changes have been incorporated into the final study report. 

Copies of the draft and final study reports can be downloaded from the internet at www.nps.gov/pwro/

honouliuli. 

INTRODUCTION

The following document includes errata, organized by chapter, that correct and add factual 

information to the May 2014 Honouliuli Gulch and Associated Sites Draft Special Resource Study and 

Environmental Assessment (draft study report/EA). Attach this document to the draft study report/

EA to comprise a full and complete record of the environmental impact analysis. The NPS did not 

identify any changes that would result in the determination of significant impacts. A Finding of No 

Significant Impact was completed for the study in October 2014.

Underlined text is new information added to the draft report, while text struck out is deleted. 

Hawaiian diacritical marks were updated throughout the report to conform to the Hawai‘i Board on 

Geographic Names database.

FRONT MATTER

Abstract, 1st paragraph, 1st sentence, revised as follows:

The National Park Service (NPS) prepared the Honouliuli Gulch and Associated Sites Draft Special 

Resource Study and Environmental Assessment to determine whether the Honouliuli Internment 

Camp and associated World War II internment sites in Hawai‘i are nationally significant, suitable, and 

feasible for inclusion in the national park system. 

Abstract, 7th paragraph, 1st sentence, revised as follows:

The NPS evaluated two alternatives in the draft study.

Abstract, Alternative B paragraph, 3rd sentence, revised as follows:

The national historic site or national monument would include the historic site of the Honouliuli 

Internment Camp and adjacent lands that provide road access and opportunities for visitor facilities. 

EXECUTIVE SUMMARY

Page xii, right column, 2nd paragraph, 1st sentence, revised as follows:

On the mainland West Coast, all individuals of Japanese ancestry living in California, southern 

Arizona, the western halves of Washington and Oregon, and the territory of Alaska—two-thirds of 

them American-born citizens—were forced from their homes by military exclusion orders following 

under Executive Order 9066, issued on February 19, 1942. They were rounded up and sent to 

temporary detention centers and then to before being sent to live out the remainder of the war at

isolated large-scale camps located throughout the western states and Arkansas, where most would 

spend the duration of the war years. The mass incarceration of 120,000 persons of Japanese ancestry 

was the largest forced removal of people in the history of the United States.
200 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Page xii, right column, 3rd paragraph, 2nd sentence, revised as follows:

The camp held approximately 400 320 internees and became the largest prisoner-of-war camp in 

Hawai‘i with nearly 4,000 individuals from Korea, Okinawa, Taiwan, Japan, and Italy. 

Page xiv, left column, last paragraph, 1st sentence, revised as follows:

The internment camp held approximately 400 320 internees, mostly second-generation Japanese 

Americans, but also Japanese, German, and Italian nationals. 

Page xvii, left column, 1st paragraph, last sentence, revised as follows:

An appropriate boundary configuration would include the historic site and lands sufficient to provide 

site access and public staging visitor facilities such as parking areas.

Page xvii, left column, 5th paragraph, 1st sentence, revised as follows:

The NPS finds that the U.S. Immigration Station is not feasible as an addition to the national park 

system because of existing uses by the U.S. Department of Homeland Security and the Hawai‘i State 

Department of Health State of Hawai‘i, Department of Public Health.

Page xviii, left column, 1st paragraph, revised as follows:

Given the U.S. Immigration Station’s prominent location in downtown Honolulu, interpretive 

features located near the sidewalk and bus stop on Ala Moana Boulevard could provide information 

about this site’s historical significance. Given the size and scale of the facilities, costs for maintenance 

and preservation of the historic structures would be a primary consideration.

Page xviii, right column, 3rd paragraph, 1st sentence, revised as follows:

The study team developed two alternatives for the draft study report/environmental assessment 

(EA), based on information gathered from public and stakeholder input, internal NPS discussions, 

evaluation of special resource study criteria, historical research, and NPS management models.

Page xviii, right column, additional text to follow 4th paragraph:

The Selected Alternative

NATIONAL HISTORIC SITE OR NATIONAL MONUMENT—A NEW UNIT OF THE NATIONAL PARK SYSTEM

The recommendations encompassed in the selected alternative are the same as those identified and 

analyzed in alternative B in the draft study report/EA, with the exception of modifications made as 

a result of information and comments derived from public review of the draft study report/EA, as 

follows:

ŐThe proposed national historic site or monument boundary has been reduced at the request 

of the University of Hawaiʻi. Discussions between the NPS and the University of Hawaiʻi have 

identified approaches to public access that do not require inclusion of University of Hawaiʻi lands 

in an NPS boundary at this time. The University of Hawaiʻi is committed to working with the 

NPS on granting access to the site over university lands should a national park unit be established. 

Future road access could be added to the national historic site or monument boundary once a 

more permanent road alignment has been determined. 

ŐMinor modifications have also been made to address public concerns regarding universal access 

to the site, potential partnerships, and technical assistance opportunities.

The above modifications would not constitute a change in environmental impacts beyond what was 

analyzed in the environmental assessment.
Appendices  Appendix F: Errata 201

Page xix, left column, before 2nd paragraph, insert additional paragraph:

Local organizations and institutions have been active in documentation, preservation, and 

interpretation efforts for Honouliuli Internment Camp. The Japanese Cultural Center of Hawaiʻi 

(JCCH) has conducted extensive research and uncovered the location of Honouliuli Internment 

Camp and other related sites. The JCCH maintains the largest repository of archives and collection 

items related to Honouliuli and the internment history in Hawai‘i. University of Hawai‘i—West 

O‘ahu faculty and students have also played a significant role in researching the history of Honouliuli 

and conducting archeological surveys. In 2012, the Hawaiʻi State legislature commissioned an 

advisory group, called the Honouliuli Park Site Advisory Committee, to support preservation of the 

Honouliuli site. The advisory group was directed to: 1) provide state support toward preservation of 

the Honouliuli site; 2) establish a mechanism to leverage county, state, federal, and private funding for 

an educational resource center at the site; and 3) memorialize the struggle for civil rights by Hawaiʻi’s 

people.

Page xxi, left column, 3rd paragraph, 1st sentence, revised as follows:

Honouliuli Internment Camp and other associated sites would continue to be eligible for grants 

through the Japanese American Confinement Sites ((JACS) Grants Program.

Page xxi, left column, 3rd paragraph, 2nd sentence, revised as follows:

Public Law a109-441 (16 USC 461) established the JACS Grant Program for the preservation and 

interpretation of U.S. confinement sites where Japanese Americans were incarcerated during World 

War II.

Page xxi, left column, 4th paragraph, last sentence, revised as follows:

Since its establishment in 2006, Tthe JACS Grant Program has awarded more than $15 approximately 

$12.4 million dollars in grants as of fiscal year 2014 2013. 

Page xxi, left column, 5th paragraph, before last sentence, insert: 

California-based CyArk received a grant of $39,020 to digitally document Honouliuli.

Page xxi, left column, 5th paragraph, last sentence, revised as follows:

Under the no action alternative, organizations would continue to obtain assistance from the JACS 

JACs Grant Program.

Page xxii, Table 1: Existing Management of Sites Evaluated in the Study, Nationally Significant Sites, 3rd

column, 2nd row, revised as follows:

Hawai‘i State Department of Public Health 

Page xxii, Table 1: Existing Management of Sites Evaluated in the Study, Sites Listed or Potentially Eligible 

for Listing in the National Register of Historic Places, 4th row, revised as follows:

Maui County Jail, 

Courthouse, and Police 

Station

Primary, Maui Public, Maui County None

 

Page xxii, Table 1: Existing Management of Sites Evaluated in the Study, Sites Listed or Potentially Eligible 

for Listing in the National Register of Historic Places, 1st row, revised as follows:

Honolulu Police 

Department

Secondary, O‘ahu Public, City and County 

of Honolulu

None
202 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Page xxii, Table 1: Existing Management of Sites Evaluated in the Study, Potentially Significant SitesAdditional Research Needed, 1st row, revised as follows:

Waiākea Prison Camp Secondary, Island of 

Hawai’i

Private Exact Location 

Unknown

None

Page xxii, Table 1: Existing Management of Sites Evaluated in the Study, Potentially Significant SitesAdditional Research Needed, last row, revised as follows:

Maui County 

Courthouse and Police 

Station

Secondary, Maui Public, Maui County None

Page xxii, Table 1: Existing Management of Sites Evaluated in the Study, Other Related Sites- No Integrity 

Remaining, revised as follows:

Sand Island Detention 

Camp

Primary, O’ahu Public, State of Hawai’i None/Non-Extant

Wailua Jail Primary, Kaua’i Public None/Non-Extant

Waimea Jail Primary, Kaua’i Public None/Non-Extant

Kaunakakai Jail and 

Courthouse

Secondary, Moloka’i Public None/Non-Extant

Maui County Jail Primary, Maui Public, Maui County None/Non-Extant

Page xxiii, left column, heading, revised as follows:

Alternative B (Selected Alternative): Honouliuli National Historic Site or National Monument—A 

New Unit of the National Park System

Page xxiii, left column, 1st paragraph, 3rd sentence, revised as follows:

The national historic site or national monument would include the historic site of the Honouliuli 

Internment Camp and adjacent lands that provide road would allow for access and opportunities for 

visitor facilities. 

Page xxiii, left column, 1st paragraph, 4th sentence, revised as follows:

In collaboration with partners, the National Park Service would preserve the site and interpret the 

internment of Japanese Americans and European Americans in Hawaiʻi during World War II. 

Page xxiii, left column, 1st paragraph, 6th sentence, revised as follows:

The National Park Service could respond to requests to provide technical assistance for the 

preservation and interpretation of other sites, features, and stories related to internment in Hawaiʻi 

during World War II.

Page xxiii, right column, Proposed Area, revised as follows:

The Honouliuli National Historic Site or National Monument would total approximately 440 

155 acres. The historic Honouliuli Internment Camp and the adjacent overlook parcel (totaling 

approximately 123 acres) would be acquired by the NPS through a donation by the Monsanto 

Company. Additional Monsanto-owned lands (31.5 acres) with related resources would could be 

protected through conservation easements or land acquisition, land transfer, or other measures, at 

Monsanto’s discretion. Adjacent parcels (285 acres) owned by the University of Hawaiʻi would also 

be included in the boundary of the historic site to provide flexibility inestablishing public access to 

the site (NPS can only expend funds on roads within an authorized boundary unless Congressional 
Appendices  Appendix F: Errata 203

legislation authorizes the use of funding for road maintenance on non-federally owned lands). 

Options for the University of Hawaiʻi parcels could include the University of Hawaiʻi maintaining 

ownership of the property, granting an easement to the NPS, or transferring ownership to the NPS 

by donation, exchange, or sale. Conservation easements could also be obtained for parcels directly 

adjacent to Honouliuli Internment Camp. Future development of road Easement 6134 could also 

provide opportunities for site access. All private property rights would be respected. 

The University of Hawaiʻi has committed to providing NPS with public access to Honouliuli, initially 

through granting the NPS a right of entry over existing roads from the west. The University of 

Hawaiʻi is currently undergoing planning efforts for its lands adjacent to Honouliuli. This process 

and subsequent planning by the NPS should a national park unit be established may identify a 

new road alignment for public access. Once a desired road alignment for public access has been 

determined, this road alignment could be included in the national historic site or national monument 

through a boundary adjustment. This would allow the National Park Service to expend funds on the 

development and maintenance of the access road.

Several Three parcels owned by the City and County of Honolulu Board of Water Supply (totaling 0.6 

acres) would be inholdings within the proposed area and would remain under current ownership and 

management. The communications site facilities, non-contributing features within the historic site, 

would not be included in the proposed boundary.

Page xxiv, left column, 3rd paragraph, 1st sentence, revised as follows:

The NPS would have direct management responsibility for the Honouliuli National Historic Site 

or National Monument including: 1) interpretation and education associated with the Honouliuli 

Internment Camp and its resources, including the development of interpretive media and programs; 

2) preservation and resource management for the historic site; and 3) operational facilities and 

infrastructure such as roads, restrooms, and trails.

Page xxiv, left column, 4th paragraph, revised as follows:

NPS staff would protect and preserve the resources and setting of related to Honouliuli Internment 

Camp. Management plans would guide appropriate historic preservation documentation and 

treatments. As described below, there are opportunities to partner with local institutions and 

organizations in the protection of resources. The NPS would seek out partnership opportunities with 

existing organizations that have conducted research and documentation of the site. These include the 

Japanese Cultural Center of Hawaiʻi, which maintains the largest repository of archives and collection 

items related to Honouliuli and the internment in Hawai‘i, and the University of Hawaiʻi—West 

O‘ahu, whose faculty and students have been actively involved in researching the history of the site 

and conducting archeological field schools at Honouliuli.

Page xxiv, right column, 2nd paragraph, before 1st sentence, additional text as follows:

Other entities, specifically the University of Hawaiʻi—West O’ahu and the Japanese Cultural Center of 

Hawaiʻi, have done significant work to document, preserve, and interpret the Honouliuli Internment 

Camp and the larger history of internment in Hawai‘i during World War II. The NPS would seek 

to maintain these partnerships for future management of the Honouliuli National Historic Site or 

Monument. In addition, the NPS would explore, develop, and maintain new partnerships for the 

preservation and interpretation of Honouliuli Internment Camp and related sites, features, and stories 

in Hawaiʻi. 

Page xxiv, right column, 3rd paragraph, last sentence, revised as follows:

Possible partners include but are not limited to the University of Hawai‘i- West O‘ahu and the 

Japanese Cultural Center of Hawai‘i. 
204 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Page xxiv, right column, 4th paragraph, 1st sentence, revised as follows:

World War II-era internment and incarceration sites in Hawai‘i other than Honouliuli Internment 

Camp would continue to be owned and managed by their respective public and private owners.

Page xxiv, right column, 4th paragraph, 2nd sentence, revised as follows:

The associated sites illustrate the broad-reaching effects of internment on the six major islands in 

Hawai‘i and are essential valuable in accurately interpreting this history.

Page xxiv, right column, 5th paragraph, after 3rd sentence, revised as follows:

The NPS could contribute to further evaluation of the U.S. Immigration Station as a national historic 

landmark and explore opportunities to interpret its significance through waysides and exhibits in 

cooperation with site owners and managers.

Page xxiv, right column, 5th paragraph, 1st sentence, revised as follows:

Upon request, the NPS could work cooperatively with associated site owners and managers to 

explore opportunities for interpretation and/ or preservation of the associated sites.

Page xxiv, right column, 5th paragraph, 2nd sentence, revised as follows:

For example, the U.S. Immigration Station played a central role in the internment process. Almost 

every person interned passed through the U.S. Immigration Station either for initial detention, 

processing for transfer to internment camps on O‘ahu and the mainland, or for hearings and trials. 

The NPS could contribute to further evaluation of the U.S. Immigration Station as a national historic 

landmark and explore opportunities to interpret its significance through waysides and exhibits.

Page xxiv, right column, 5th paragraph, after 3rd sentence, additional text as follows:

Any request for technical assistance related to the associated sites would be voluntary on the part of 

the landowner.

Page xxv, left column, 1st paragraph, 1st sentence, revised as follows:

Where appropriate, the NPS could also conduct research and respond to requests provide for 

assistance to related sites that have yet to be identified.

Page xxv, left column, 2nd paragraph, 1st sentence, revised as follows:

Management of Honouliuli National Historic Site or Monument would be managed through World 

War II Valor in the Pacific National Monument at Pearl Harbor, given its close proximity and related 

history.

Page xxv, right column, 2nd paragraph, 3rd sentence, revised as follows:

The 7-acre overlook site could serve as an excellent location for a visitor staging area with ample space 

to provide for parking, visitor drop-off, interpretive features, and restrooms.

Page xxvi, left column, 1st paragraph, insert after last sentence:

Implementation planning would also explore opportunities for persons of all abilities to access and 

experience Honouliuli Internment Camp.

Page xxvi, left column, 2nd paragraph, revised as follows:

Currently there is no public access to Honouliuli Internment Camp does not currently exist because 

it is located on private property. Rights of access would be required to provide public access to the 

7-acre overlook parcel and the historic site. Existing roads would require considerable improvement 
Appendices  Appendix F: Errata 205

to accommodate visitor access. As noted above, the University of Hawaiʻi has committed to working 

with the National Park Service with regard to providing public access on existing and future roads 

through its lands.

Page xxvi, right column, 2nd paragraph, revised as follows:

Specific costs would be reevaluated in subsequent, more detailed planning for the unit. Planning 

would consider facility and site design, detailed identification of resource protection needs, and 

changing visitor expectations. Actual costs to the NPS would vary depending on timing and 

implementation and contributions by partners and volunteers. It is assumed that meeting the longrange financial needs of Honouliuli National Historic Site or Monument would not just rely upon 

federally appropriated funds. A variety of other public and private funding sources could be sought 

by the NPS to assist in implementation efforts. Other NPS units have successfully found partners to 

help with funding major projects, and some of the costs associated with actions in the alternatives 

may prove to be less expensive when if donated materials, labor, and other support can be secured are 

forthcoming.

Page xxvii, left column, 4th paragraph, last sentence, revised to include numbers instead of bullet points:

The CEQ (46 FR 18026 – 46 FR 18038) provides direction that the “environmentally preferable 

alternative is the alternative that would promote the national environmental policy as expressed in 

NEPA’s Section 101,” including: 

1 Fulfill the responsibilities of each generation as trustee of the environment for succeeding 

 generations;

 2 Assure for all Americans safe, healthful, productive, and aesthetically 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 which will 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 (NEPA Section 101(b)).

CHAPTER 1: INTRODUCTION

Page 3, left column, 3rd paragraph, additional text to follow:

THE SELECTED ALTERNATIVE

The National Park Service special resource study process requires that the study identify the 

alternative or combination of alternatives that in the professional judgment of the NPS Director is 

most effective and efficient in protecting significant resources and providing for visitor enjoyment. 

Based on public and stakeholder input and professional judgment, the NPS selected alternative B, the 

action alternative, which would provide for the establishment of a national historic site or national 

monument. The National Park Service has determined this to be the most effective and efficient 

alternative in protecting significant resources and providing for visitor enjoyment.
206 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Page 3, left column, 4th paragraph, revised as follows:

Chapter 8: Consultation and Coordination describes the public involvement and agency consultation 

that took place during the special resource study process.The public comment period for Publication 

of the Draft Honouliuli Gulch and Associated Sites Draft Special Resource Study and Environmental 

Assessment will be followed by a 60-day public comment period was open from May 8 to July 15, 2014. 

Comments received have been incorporated into this final study report. The NPS study team will 

then complete a A Finding of No Significant Impact (Appendix E) and errata to the draft study report 

(Appendix F) were completed by the NPS study team, which will which could include corrections to 

the study and environmental assessment, and transmit it them with the report to the Secretary of the 

Interior. The Secretary will transmit submit the report final special resource study to Congress, along 

with the Secretary’s recommendations for the area.

CHAPTER 2: HISTORICAL OVERVIEW AND RESOURCES

Page 5, right column, 3rd paragraph, last sentence, revised as follows:

With the passage of the Immigration Act of 1924, immigration from Japan (and other countries 

and territories in the Asia Pacific) was terminated. The ban remained with few alterations until the 

Immigration and Nationality Act of 1965.

Page 6, left column, 1st paragraph, 3rd sentence, revised as follows:

In Europe, the U.S. allied with Britain against the Axis nations and readied itself for possible war in the 

Pacific.

Page 8, left column, 4th paragraph, 1st sentence, revised as follows:

On Hawai‘i Island, internees were held temporarily at Kilauea Military Camp, Waiākea Prison Camp 

near at the Hilo Airport, and the Hilo Independent Japanese Language School. 

Page 8, right column, 3rd paragraph, after 3rd sentence, revised as follows:

In 1942, family members of interned men were given the option to join them on the mainland. Many 

family members chose this voluntary incarceration because they didn’t have any financial support 

without their head of household .

Page 9, left column, 2nd paragraph, revised as follows:

Honouliuli Internment Camp held approximately 400 internees. Of these, tThree hundred sixty-four 

twenty were Nikkei are known to have been interned at Honouliuli,including six women (JCCH, 

pers. comm. 2014 and (Soga 2007, Appendix 4). Most of the Nikkei interned were American citizens 

of Japanese ancestry who had been educated in Japan, some of whom held dual citizenship (JCCH, 

pers. comm. 2014). In addition, 33 of the 36 remaining internees—described as being of “German” or 

“Italian” heritage—were American citizens, including seven women (Rosenfeld 2014).

Page 9, right column, 2nd paragraph, revised as follows:

The best estimate for the number of people of Japanese ancestry incarcerated from Hawai‘i is 

approximately 2,456 2,392 (Kashima 2003, 86). This number included 875 predominantly Issei 

males arrested and transferred to Department of Justice internment camps on the mainland; 1,217 

individuals of Japanese ancestry in Hawaiʻi sent to War Relocation Authority camps on the mainland; 

and approximately 364 300 Nikkei imprisoned in Hawai‘i (JCCH 2014 and Kashima 2003, 86). 

Page 10, left column, 1st paragraph, revised as follows:

In addition, there were 139 Caucasian internees from Hawai’i (Rosenfeld 2014). One hundred twentyfive of them were listed in an FBI memo at lists 125 people of European ancestry incarcerated by the 

end of March 1942, including which cited 67 German aliens, 40 U.S. citizens of German ancestry, 
Appendices  Appendix F: Errata 207

15 Italian aliens, two U.S. citizens of Italian ancestry, and one Norwegian alien (Shivers 1942). 

New research indicates that some internees reported to be “German” and “Italian” were of other 

nationalities or cultural affiliations. In summary, individuals who were interned in Hawai’i included 

people of Filipino, Okinawan, Japanese, German, Italian, Danish, Finnish, Irish, Lithuanian, Korean, 

Norwegian, and Swedish descent, as well as European Jews who had escaped persecution by the 

Nazis (Rosenfeld 2014).

Page 17, right column, 3rd paragraph, 1st sentence, revised as follows:

The U.S. Immigration Station building is currently used for offices of the Department of Homeland 

Security and the Hawaiian Hawai‘i State Department of Health.

Page 20, left column, 1st paragraph, 1st sentence, revised as follows:

All of the buildings at the site were present during World War II: the administration building; a twostory detention building now used by the Hawai‘i State Department of Public Health; a long, onestory annex; and the garage/waiting shed.

Page 23, right column, 2nd paragraph, 1st sentence, revised as follows:

Honouliuli is a longstanding place name, translated as “dark bay,” that marks the areas between ‘Ewa 

villages and Waipahu. 

Page 24, right column, 2nd paragraph, 1st sentence, revised as follows:

Honouliuli was the largest prisoner of war camp in Hawai‘i and held nearly 4,000 individuals during 

its operation, including 2,700 Korean POWs. The POW population was composed of soldiers and 

labor conscripts from Korea, Okinawa, Taiwan, Japan, and Italy. Honouliuli also held women and 10 

children who were Japanese civilians displaced from the Pacific, including Saipan and Rota, as well as 

four men from the Philippines (Adler 2014 and Falgout 2014).

Page 28, left column, 2nd paragraph, 1st sentence, revised as follows:

On the island of Hawai‘i, those arrested were sent to the Kilauea Military Camp (KMC), a military 

installation located within Hawai‘i Volcanoes National Park, Waikakea Waiākea Prison Camp, and the 

Hilo Independent Japanese Language School. 

Page 28, left column, 2nd paragraph, last sentence, revised as follows:

It is not known how many were temporarily detained and released. A few internees were held at the 

Waiākea Prison Camp, located near at the Hilo Airport. 

Page 28, left column, 2nd paragraph, added after last sentence:

Participants at the Hilo public meeting on June 4, 2014 indicated that a place near the U.S. Post Office 

at the Hilo Airport was used by the Army National Guard and FBI for interrogation and detaining 

internees. It was suggested that it could have been a location where internees were first taken before 

being transferred to other internment locations. Additional research is needed to verify the location 

and confirm that it was used for internment during World War II, 

Page 32, left column, 2nd paragraph, revised as follows:

Waiākea Prison Camp is no longer intact, though a former mess hall slab may still exist. The Waiākea 

Prison Camp was located in the vicinity of 1498 Kalanianaole Avenue and is currently owned by 

Kamehameha Schools and leased to the Edith Kanakaole Foundation for their use (Mossman, 

pers. comm. 2013). A complex of new structures exists at the site today. The precise location of 

the Waiakea Prison Camp has not been determined. If a specific place or existing feature can be 

associated with the imprisonment of civilian internees, the site could be of local significance.
208 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Page 35, right column, 3rd paragraph, revised as follows:

The location of Kalāheo Stockade has not yet been fully determined beyond anecdotal agreement 

about its location at the current Medeiros Chicken Farm. Six possible locations were investigated 

during the 2006 archeological reconnaissance, and additional reconnaissance was attempted in 2014. 

No conclusive evidence of the stockade was found, but many members of the public believe it to be at 

or near the most likely sites were determined to be the Medeiros Chicken Farm. A 1943 military map 

places the stockade in the Medeiros Chicken Farm vicinity, but to the east. Additional research would 

be needed to confirm the precise location of the Kalāheo Stockade and condition of any remaining 

resources., a site along the Alexander Reservoir Road, and Kalaheo School. The Medeiros Chicken 

Farm was identified as the correct location by attendees at the Kaua’i public scoping sessions, and 

there are reports that a map of hte camp exists (Schlang, pers. comm. 2011).

Page 36, right column, 2nd paragraph, 1st sentence, revised as follows:

The two known internment sites on Maui are the Maui County Jail—called the “Detention Camp” in 

Wailuku, which was located at the site of the current Maui County Correction Center,in the center 

of the island’s main government and office district,-—and the Ha‘ikū Military Camp in the town of 

Ha‘ikū.

Page 37, revised as follows:

Photos (clockwise from top left): 1. The Old Police Station in Wailuku may have been used to detain 

internees temporarily stood adjacent to the Maui County Jail (since demolished), where internees 

were temporarily detained. Photo by Rick Regan: provided as part of National Register nomination 

form, 1981. 2. The Old Wailuku Courthouse, (seen here in 2006) stood adjacent to the Maui County 

Jail. Photo: Burton and Farrell 2007. The significance of the Police Station and the Courthouse to 

WWII internment requires further investigation. 3. Historic cannery building, Ha‘ikū. Photo: Burton 

and Farrell 2007. 4. Roots School Horizons Academy, possible United Service Organizations (USO) 

site of Ha‘ikū Camp during WWII. Photo: NPS, 2011.

Page 38, left column, 2nd and 3rd paragraphs, revised as follows:

Maui County Jail

Records indicate that the Maui County Jail, also called the Wailuku County Jail, was used to detain 

individuals of Japanese descent. A letter from an internee, dated June 3, 1942, identified the return 

address as “Detention Camp, Wailuku.” The original jail building was constructed in 1941 as the 

county’s jail facility, and then was used during World War II as a location to detain internees. It was 

located at the site of the current Maui County Correctional Center at 600 Waiale Road in Wailuku. 

This building has been demolished, however two buildings adjacent to the Maui County Jail may also 

have held internees. Additional research is necessary to determine if and how these two buildings—

the Old Wailuku Courthouse and the Old Police Station, now called the Kalana Pakui Building, or Old 

Police Station—were used during internment.

PHYSICAL REMAINS

The Maui County Jail structure was demolished in 1970. The Old Police Station (built in 1928) and 

the Old Wailuku Courthouse (built in 1907) are part of the Wailuku Civic Center Historic District. 

The district was listed in the National Register of HIstoric Places in 1986., which also includes a noncontributing modern structure built on the site of the former jail. 

Page 38, right column, 2nd paragraph, revised as follows:

Lindsay went to visit the Haʻikū Camp during World War II. His personal recollection is that the 

existing Roots School Horizons Academy building located at 740 Ha‘ikū Road may have been part 

of the old Ha‘ikū Pineapple Company and later used for the internment camp (Lindsay, pers. comm. 

2010). 
Appendices  Appendix F: Errata 209

Additional research completed by David Fukuda of the Nisei Veterans Memorial Center confirms 

the location of the Ha‘ikū Camp in the area north and east of the existing Ha‘ikū Post Office. 

Fukuda interviewed Ty Kakihara, born in 1927, who remembered the area during World War II. He 

remembered the former dorm for cannery workers was enclosed with a wire fence and guard towers.

CHAPTER 3: RESOURCE SIGNIFICANCE

Page 41, left column, 2nd paragraph, 1st sentence, revised as follows:

According to 36 CFR 65.4 – National Historic Landmark (See Appendix D C), the quality of national 

significance is ascribed to districts, sites, buildings, structures and objects that possess exceptional 

value or quality in illustrating or interpreting the heritage of the United States in history, architecture, 

archeology, engineering and culture and that possess a high degree of integrity of location, design, 

setting, materials, workmanship, feeling and association, and: 

Page 42, caption, revised as follows:

Barracks and tents at Honouliuli, with the women’s internee compound in the background. A portion 

of the rock wall visible in the background behind still stands on the site today. Photo by R. H. Lodge, 

c. 1945, courtesy Hawai‘i’s Plantation Village.

Page 51, right column, 3rd paragraph, 1st sentence, revised as follows:

Creating social institutions and movements: The NPS notes that “Americans generate temporary 

movements and create enduring institutions in order to define, sustain, or reform their values” (NPS 

1996, 8) and this theme is illustrated by the internment sites.

Page 52, right column, 4th paragraph, 1st sentence, after 3rd sentence revised as follows:

The U.S. Immigration Station’s recent change in administration illustrates the changing role 

of the United States in the world community: the 70-year-old United States Immigration and 

Naturalization Service was dismantled by the Homeland Security Act of 2002 and separated into 

the U.S. Immigration and Customs Enforcement, U.S. Customs and Border Protection, and the U.S. 

Citizenship and Immigration Services, all within the Department of Homeland Security. became part 

of the Department of Homeland Security in 2003.

Page 54, left column, 5th paragraph, last sentence, revised as follows:

Exhibits along the sidewalk and other outside areas could provide the public with information about 

the story of the internment, as well as the history of immigration in Hawai‘i and the architecture of the 

buildings.

Page 62, left column, last paragraph, 1st sentence, revised as follows:

The Honolulu Police Department, Yokohama Specie Bank, and Kauaʻi County Courthouse, and Maui 

County Courthouse and Police Station are three five sites associated with internment that are already 

listed in the National Register of Historic Places and retain high integrity. 

Page 62, right column, 1st paragraph, last sentence revised as follows:

Together, these seven five sites possess opportunities to tell multiple aspects of the story of the forcible 

internment of civilians during World War II. 

Page 62, right column, 2nd paragraph, revised as follows: 

Five of the sites (Waiakea Prison Camp and the Hilo Independent Japanese Language School on 

the Big Island, Lihue Plantation Gymnasium and Kalaheo Stockade on Kaua‘i, and Haiku Military 

Camp on Maui) associated with the World War II internment of civilians need additional research to 

determine whether they retain sufficient integrity of location, setting, materials, workmanship, design, 

feeling, and association to be of national or state significance.
210 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Page 62, right column, 3rd paragraph, revised as follows:

Association with internment enhances the significance of three five buildings already listed in the 

National Register of Historic Places: Honolulu Police Department, Yokohama Specie Bank, and 

Kauaʻi County Courthouse, and Maui County Courthouse and Police Station. 

Page 63, left column, 3rd paragraph, 1st sentence, revised as follows:

In six five cases, additional research is necessary to establish clear association with internment, or 

to determine whether the property retains sufficient integrity to convey its significance: Waiākea 

Prison Camp and the Hilo Independent Japanese Language School on the island of Hawai‘i, Līhu'e 

Plantation Gymnasium and Kalāheo Stockade on Kaua‘i, and Ha‘ikū Military Camp and Maui 

County Courthouse and Police Station on Maui. 

Page 63, left column, 4th paragraph, 1st sentence, revised as follows:

SixFour of the sites associated with the World War II internment of civilians appear to lack sufficient 

integrity for National Register consideration: Sand Island Detention Camp on O‘ahu, Wailua Jail and 

Waimea Jail on Kaua‘i, Maui County Jail on Maui, Waiākea Prison Camp on the island of Hawai‘i, and 

Kaunakakai Jail and Courthouse on Moloka‘i. Structures related to World War II internment have 

been removed from the Sand Island, Wailua, and Waimea, Waiākea,sites and Maui County Jail sites, 

and because of modern disturbance there is little potential for significant archeological deposits at 

those sites. 

Page 65, Sites Listed in the National Register of Historic Places, where Internment History Enhances or 

May Enhance Their Significance, bottom row, revised as follows:

Maui County Jail, 

Courthouse, and 

Police Station

150 and 200 

South High 

Street, Wailuku, 

Maui

Jail has been 

demolished but 

Courthouse and 

Police Station have 

high integrity.

Internees were held at the Maui County 

Jail, which has since been demolished. 

However, the Courthouse and Police 

Station may be associated with the World 

War II internment. The courthouse and 

the police station were listed as part of the 

Wailuku Civic Center Historic District in 

the National Register of Historic Places 

in 1986 for architecture and for their 

association with the early development of 

Maui County. Their potential relationship 

to World War II internment could enhance 

the significance of both structures.

Page 66, Sites Needing Additional Research, top row, revised as follows:

Waiākea Prison 

Camp

Hilo, Island of 

Hawai’i

Unknown As a hard-labor prison camp where 

internees considered “troublemakers” 

were sent, this site could have a high level 

of significance for its ability to convey the 

reach of martial law. However, its location 

and integrity needs to be determined.
Appendices  Appendix F: Errata 211

Page 66, Sites Needing Additional Research, bottom row, revised as follows:

Maui County 

Courthouse and 

Police Station

150 and 200 

South High 

Street, Wailuku, 

Maui

High Further investigation is required to 

determine whether the Courthouse and 

Police Station were associated with the 

World War II internment. The Courthouse 

and the Police Station were listed as part of 

the Wailuku Civic Center Historic District 

in the National Register of Historic Places 

in 1986 for architecture and for their 

association with the early development of 

Maui County.

Page 67, Other Sites, bottom row, revised as follows:

Maui County Jail 600 Waiale 

Road, Wailuku, 

Maui

Lacks Integrity/

Demolished

The Maui County Jail, also called the 

Wailuku County Jail, was used to detain 

individuals of Japanese descent. It was 

called the “Detention Camp, Wailuku.” 

The jail was demolished in 1970.

CHAPTER 4: SUITABILITY

Page 69, right column, 2nd paragraph, 2nd sentence, revised as follows:

In Chapter 3: Resource Significance, the section Significance of the Events: Incarceration of Civilians 

in the United States during World War II provides a complete description of the differences between 

the incarceration of civilians in Hawai‘i and on the U.S. mainland.

Page 76, left column, 3rd paragraph, 1st sentence, revised as follows:

Appendix C D: Japanese American Wartime Incarceration Properties provides the names of 

properties, their locations, and status of federal and state designations of all known incarceration 

sites.

Page 81, left column, 1st paragraph, last sentence, revised as follows:

Despite these limitations, the U.S. Immigration Station’s history could be interpreted for the public 

through a variety of offsite media and outreach and limited onsite exhibits and waysides.

Page 81, right column, 1st paragraph, 2nd sentence, revised as follows:

ŐCreating Social Institutions and Movements

Page 89, left column, 2nd paragraph, 1st sentence, revised as follows:

National Historic Landmarks and National Register Districts that reflect the theme of the Changing 

Role of the United States in the World Community:

National Historic Landmarks and National Register Districts that reflect the theme of the Changing Role 

of the United States in the World Community:

CHAPTER 5: FEASIBILITY AND THE NEED FOR NPS MANAGEMENT

Page 91, right column, 4th paragraph, 1st sentence, revised as follows:

Honouliuli Internment Camp is located approximately 20 15 miles west of downtown Honolulu, east 

west of Kunia Road and north of Interstate H-1.
212 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Page 91, right column, 4th paragraph, 2nd and 3rd sentences, revised as follows:

The historic site, defined by the boundary established by the National Register of Historic Places 

(122.5 acres), is located on portions of three separate parcels owned by the Monsanto Company, 

identified as Honolulu County tax map keys (TMKs) (1) 9-2-001-001 (Monsanto Parcels 1 and 1a 

Lots 16851-A and 16851-B) and(1) 9-2-004-009 (Monsanto Parcel 2 Lot 12007). Parcel 1 (1) 9-2-001-

001 is approximately 1,830 acres. The Monsanto Company has recently subdivided 116 acres of this 

parcel (Parcel 1A Lot 16851-B), which contains most of the historic camp features. Parcel 2 Lot 12007 

is 437 acres, nine of which include historic camp features.

Page 93, left column, 3rd paragraph, 4th sentence, revised as follows:

Parcels include TMK (1) 92001008 9-2-001-008 (0.4 acres), TMK (1) 92001009 9-2-001-009 (0.1 

acres), and TMK (1) 920010010 9-2-001-0010 (0.1 acres).

Page 93, left column, 3rd paragraph, 7th sentence, revised as follows:

BWS holds access easements over Monsanto Parcel 1 parcel TMK (1) 9-2-001-001.

Page 93, right column, 2nd paragraph, revised as follows:

Large satellite dishes owned by the KITV television station are located within a fenced enclosure 

in the southeastern area of the gulch on Monsanto Parcel 1 parcel TMK (1) 9-2-001-009 (Integral 

Consulting, Inc. 2013).

Page 93, right column, 3rd paragraph, last sentence, revised as follows:

Currently zoned for agricultural uses, UHWO has identified these parcels for either future campus 

expansion

Page 95, left column, 1st paragraph, 1st and 2nd sentences, revised as follows:

or university or non-university related development, which could include educational, scientific, 

and research activities. UHWO will be conducting master planning for its campus lands west of 

Honouliuli to identify more specific future uses for the properties. The University of Hawai‘i is 

currently working on a strategic land use plan that will determine the future use of its parcels adjacent 

to Honouliuli Internment Camp. 

Page 95, left column, 4th paragraph, revised as follows:

In light of the interest in a potential unit of the national park system, the Monsanto Company has 

subdivided Parcel 1 TMK (1) 9-2-001-001 and TMK (1) 9-2-001-009 Parcel 2 to create three separate 

conservation easements that it could potentially transfer to the NPS. The Monsanto Company is also 

creating created a new standalone fee parcel (Lot 15861-B Parcel 1A, 116 acres) over the historic site 

to transfer for conservation purposes. (See Map: Honouliuli Internment Camp–Historic Resources 

and Conservation Easements Land Ownership - Honouliuli Internment Camp). The Monsanto 

Company has also expressed a desire to transfer title to the 7-acre overlook site (Parcel 3 Lot 12011) 

to the National Park Service.

Page 95, left column, Last paragraph, before 1st sentence, additional text as follows:

Establishment of a national park unit that would include Honouliuli Internment Camp is consistent 

with state and local land use policies and guidance including, the Hawai‘i State Plan, the City and 

County of Honolulu General Plan and Revised Ordinances of 1990, and the ‘Ewa Development Plan

(Hawai‘i Department of Planning and Economic Development 1986, City and County of Honolulu 

2002 and 2013).
Appendices  Appendix F: Errata 213

Page 95, right column, 1st paragraph, after 1st sentence, additional text as follows:

Chapter 205 of Hawai‘i Revised Statutes (§205-4.5 (a)(6)(8)). City and County of Honolulu local 

zoning allows for public uses and structures in zone AG-1 (Revised Ordinances of Honolulu 1990). 

The recently adopted ‘Ewa Development Plan, the City and County of Honolulu’s long-range land 

use and infrastructure plan for the ‘Ewa region, identifies Honouliuli Internment Camp as one of 

‘Ewa’s significant historic features and landmarks and calls for its protection and preservation (See 

Maps: Honouliuli Internment Camp-Zoning Zoning - Honouliuli Internment Camp, State Land Use 

Districts, and ‘Ewa Development Plan, Urban Land Use Map).

Page 95, right column, 2nd paragraph, 2nd sentence, revised as follows:

As described in Chapter 3: Resource Significance, the U.S. Immigration Station was listed in the 

National Register of Historic Places in 1978.

Page 95, right column, 2nd paragraph, 3rd sentence, revised as follows:

The U.S. Immigration Station Complex site is 4.5 acres located on two separate parcels.

Page 95, right column, 2nd paragraph, 4th sentence, revised as follows:

The larger parcel (TMK 2-1-015-018) contains all but one of the four buildings associated with the 

complex and is currently occupied by the U.S. Department of Homeland Security’s Immigration and 

Naturalization Service, Immigration and Customs Enforcement.

Page 95, right column, 3rd paragraph, last sentence, revised as follows:

This two-story building is currently occupied by the Hawai‘i State Department of Public Health.

Page 96, map Historic Resources and Conservation Easements – Honouliuli Internment Camp, deleted 

from document. Pertinent information is included on map Land Ownership - Honouliuli Internment 

Camp. 

Pages 97 and 100, additional maps provided, State Land Use Districts, and ‘Ewa Development Plan, 

Urban Land Use Map.

Page 99, Map: Zoning—U.S. Immigration, revised as follows:

Street data has been updated to reflect current road and circulation patterns.

Page 100, left column, 2nd paragraph, 3rd sentence, revised as follows:

Monsanto has expressed its interest in donating portions of the property to the NPS for establishment 

of a national park unit (Parcels 1A and 3 Lot 16851-B and Lot 12011).

Page 100, left column, 3rd paragraph, revised as follows:

Existing use of the U.S. Immigration Station by the U.S. Department of Homeland Security and 

Hawai‘i State Department of Public Health would not be compatible with use as a national park unit. 

However, if the U.S. Immigration Station facilities were no longer needed by the U.S. Department 

of Homeland Security or the Hawai‘i State Department of Health, additional NPS analysis would 

be needed to determine the feasibility of management options and associated costs. Given the size 

and scale of the facilities, costs for maintenance and preservation of the historic structures would 

be a primary consideration. However, if at any time in the future the U.S. Department of Homeland 

Security no longer needed the facilities, zoning and ownership would not conflict with management 

of a national park unit. The U.S. Immigration Station complex would not be feasible for direct NPS 

management and ownership as part of a national park unit at this time.
214 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Page 104, Map: Access and Circulation Data—U.S. Immigration, revised as follows:

Street data has been updated to reflect current road and circulation patterns.

Page 105, left column, 1st paragraph, 2nd sentence, revised as follows:

Honolulu’s Department of Transportation Services buses (lines 8 and 20) stop directly in front of the 

complex.

Page 105, left column, 1st paragraph, 3rd sentence, revised as follows:

However, current use of the building by the U.S. Department of Homeland Security and the State of 

Hawai‘i State Department of Public Health does not allow for general public access (See Map: Access 

and Circulation–U.S. Immigration Station).

Page 105, left column, 2nd paragraph, 2nd sentence, revised as follows:

To provide for limited public information about the U.S. Immigration Station’s history, waysides or 

other information materials could be provided along the sidewalk in front of the complex or at the 

bus stop located directly in front of the buildings on Ala Moana Boulevard.

Page 105, right column, 2nd paragraph, 2nd sentence, revised as follows:

However, given the building’s prominent location in downtown Honolulu, interpretive features 

located in near the sidewalk and bus stop on Ala Moana Boulevard could provide information about 

this site’s historical significance.

Page 106, left column, last paragraph, revised as follows:

In addition to the lands within the national register boundary, a suitable boundary would include 

parcels owned by UHWO and the Monsanto Company that provide current road access and 

opportunities for visitor facilities such as parking, restrooms, and interpretive features. This includes

the 7-acre overlook site to the west, currently owned by Monsanto, and UHWO parcels to the 

north (38 acres) and south (12 acres) of the overlook site 22.5 acres of land owned by Monsanto 

surrounding the drainage to the south of the national register boundary. These lands may contain 

archeological artifacts related to the internment camp.

Portions of the large UHWO parcel (285 acres) west of the overlook site wcould also be included 

to provide for public access. These parcels are agricultural lands either actively farmed or fallow. 

The University of Hawaiʻi is currently completing a land use plan for its lands west of Honouliuli 

Internment Camp. If the university were to identify new road alignments as part of that planning 

process, which could be used to access Honouliuli Internment Camp, then a small boundary 

adjustment for this alignment could be considered to allow NPS to expend funds on road 

maintenance. Although the primary purpose of including UHWO lands to the west would be for 

public access, the NPS could also seek to work with the UHWO to pursue conservation easements 

on some portion of these lands. The NPS would not need to directly own or manage UHWO lands to 

achieve these purposes.

Page 106, right column, last paragraph, 3rd sentence, revised as follows:

For Honouliuli Internment Camp, there is sufficient land available for appropriate use and 

development of the site on parcels that lie to the west.

Page 113, right column, 1st paragraph, 2nd sentence, revised as follows:

An appropriate boundary configuration would include the historic camp area and lands sufficient to 

provide site would allow for access and public staging visitor facilities such as parking.
Appendices  Appendix F: Errata 215

Page 113, right column, 2nd paragraph, 1st sentence, revised as follows:

The U.S. Immigration Station complex is not feasible as a national park unit because of existing 

uses by the U.S. Department of Homeland Security and the State of Hawai‘i State Department of 

Public Health.However, if the U.S. Immigration Station facilities were no longer needed by the 

U.S. Department of Homeland Security or the Hawai‘i State Department of Health, additional 

NPS analysis would be needed to determine the feasibility of management options and associated 

costs. Given the size and scale of the facilities, costs for maintenance and preservation of the 

historic structures would be a primary consideration.However, if at any time in the future the U.S. 

Department of Homeland Security no longer needed the facilities, zoning and ownership would not 

conflict with management of a national park unit. The public enjoyment potential of the facilities 

is high given its accessible and prominent location in downtown Honolulu. If the facilities were no 

longer needed by federal or state agencies, additional analysis would be needed to determine the 

feasibility of management options and associated costs. 

Page 114, right column, 1st row, 1st paragraph, 2nd sentence, revised as follows:

Existing use of the U.S. Immigration Station complex by the U.S. Department of Homeland Security 

and State of Hawai‘i State Department of Public Health make it incompatible with NPS management 

as part of a national park unit.If the U.S. Immigration Station buildings were no longer used by the 

U.S. Department of Homeland Security or the Hawai‘i State Department of Health, additional NPS 

analysis would be needed to determine the feasibility of management options and associated costs. 

Given the size and scale of the facilities, costs for maintenance and preservation of the historic 

structures would be a primary consideration., and were to become available to the NPS, management 

as a national park unit would be compatible with current zoning and ownership patterns.

Page 114, right column, 2nd row, 1st paragraph, 4th sentence, revised as follows:

However, given the site’s prominent location in downtown Honolulu, interpretive features located in 

publicly accessible areas could provide information about its historical significance.

CHAPTER 6: ALTERNATIVES

Page 117, left column, 2nd paragraph, 1st sentence, revised as follows:

The study team developed two alternatives for the draft study report/environmental assessment 

(EA), based on information gathered from public and stakeholder input, internal NPS discussions, 

evaluation of special resource study criteria, historical research, and NPS management models.

Page 117, left column, additional text to follow 3rd paragraph:

The Selected Alternative

NATIONAL HISTORIC SITE OR NATIONAL MONUMENT—A NEW UNIT OF THE NATIONAL PARK SYSTEM

The recommendations encompassed in the selected alternative are the same as those identified and 

analyzed in alternative B in the draft study report/EA, with the exception of modifications made as 

a result of information and comments derived from public review of the draft study report/EA, as 

follows:

ŐThe proposed national historic site or monument boundary has been reduced at the request 

of the University of Hawaiʻi. Discussions between the NPS and the University of Hawaiʻi have 

identified approaches to public access that do not require inclusion of University of Hawaiʻi land 

in an NPS boundary at this time. The University of Hawaiʻi is committed to working with the 

NPS on granting access to the site over university lands should a national park unit be established. 

Future road access could be added to the national historic site or monument boundary once a 

more permanent road alignment has been determined. 
216 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

ŐMinor modifications have also been made to address concerns regarding universal access to the 

site, potential partnerships, and technical assistance opportunities.

The above modifications would not constitute a change in environmental impacts beyond what was 

analyzed in the environmental assessment.

Page 118, left column, before 3rd paragraph, insert additional paragraph: 

Local organizations and institutions have been active in documentation, preservation, and 

interpretation efforts for Honouliuli Internment Camp. The Japanese Cultural Center of Hawaiʻi 

(JCCH) has conducted extensive research and uncovered the location of Honouliuli Internment 

Camp and other related sites. The JCCH maintains the largest repository of archives and collection 

items related to Honouliuli and the internment history in Hawai‘i. University of Hawai‘i—West 

O‘ahu faculty and students have also played a significant role in researching the history of Honouliuli 

and conducting archeological surveys. In 2012, the Hawaiʻi State Legislature commissioned an 

advisory group, called the Honouliuli Park Site Advisory Committee, to support preservation of the 

Honouliuli site. The advisory group was directed to: 1) provide state support toward preservation of 

the Honouliuli site; 2) establish a mechanism to leverage county, state, federal, and private funding for 

an educational resource center at the site; and 3) memorialize the struggle for civil rights by Hawaiʻi’s 

people.

Page 120, left column, 4th paragraph, 2nd sentence, revised as follows:

Public Law a109-441 (16 USC 461) established the JACS Grant Program for the preservation and 

interpretation of U.S. confinement sites where Japanese Americans were incarcerated during World 

War II.

Page 120, right column, 1st paragraph, last sentence, revised as follows:

Since its establishment in 2006, Tthe JACS Grant Program has awarded more than $15 approximately 

$12.4 million dollars in grants as of fiscal year 20142013. 

Page 120, right column, 2nd paragraph, before last sentence, insert: 

California-based CyArk received a grant of $39,020 to digitally document Honouliuli.

Page 120, right column, 2nd paragraph, last sentence, revised as follows: 

Under the no action alternative, organizations would continue to apply for JACS JACs grants for the 

life of the program.

Page 121, Table 6-1: Existing Management of Sites Evaluated in the Study, Nationally Significant Sites, 3rd

column, 2nd row, revised as follows:

Hawai‘i State Department of Public Health 

Page 121, Table 6-1: Existing Management of Sites Evaluated in the Study, Sites Listed or Potentially 

Eligible for Listing in the National Register of Historic Places, insert before first row:

Honolulu Police 

Department

Secondary, O‘ahu Public, City and County 

of Honolulu

None
Appendices  Appendix F: Errata 217

Page 121, Table 6-1: Existing Management of Sites Evaluated in the Study, Sites Listed or Potentially 

Eligible for Listing in the National Register of Historic Places, 3rd row, revised as follows:

Maui County Jail, 

Courthouse, and Police 

Station

Primary, Maui Public, Maui County None

Page 121, Table 6-1: Existing Management of Sites Evaluated in the Study, Potentially Significant Sites—

Additional Research Needed, 1st row, revised as follows:

Waiākea Prison Camp Secondary, Island of 

Hawai’i

Private Exact Location 

Unknown

None

Page 121, Table 6-1: Existing Management of Sites Evaluated in the Study, Potentially Significant Sites—

Additional Research Needed, insert row:

Maui County 

Courthouse and Police 

Station

Secondary, Maui Public, Maui County None

Page 121, Table 6-1: Existing Management of Sites Evaluated in the Study, Other Related Sites—No 

Integrity Remaining, revised as follows:

Sand Island Detention 

Camp

Primary, O’ahu Public, State of Hawai’i None/Non-Extant

Wailua Jail Primary, Kaua’i Public None/Non-Extant

Waimea Jail Primary, Kaua’i Public None/Non-Extant

Kaunakakai Jail and 

Courthouse

Secondary, Molokaʻi Public None/Non-Extant

Maui County Jail Primary, Maui Public, Maui County None/Non-Extant

Page 122, left column, heading, revised as follows:

Alternative B (Selected Alternative): Honouliuli National Historic Site or National Monument—A 

New Unit of the National Park System

Page 122, left column, 1st paragraph, 3rd sentence, revised as follows:

The national historic site or national monument would include the historic site of the Honouliuli 

Internment Camp and adjacent lands that provide road would allow for access and opportunities for 

visitor facilities. 

Page 122, left column, 1st paragraph, 4th sentence, revised as follows:

In collaboration with partners, the National Park Service would preserve the site and interpret the 

internment of Japanese Americans and European Americans in Hawaiʻi during World War II.

Page 122, left column, 1st paragraph, 5th sentence, revised as follows:

The National Park Service could respond to requests to provide technical assistance for the 

preservation and interpretation of other sites, features, and stories related to internment in Hawaiʻi 

during World War II.
218 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Page 122, right column, Proposed Area, revised as follows:

The Honouliuli National Historic Site or National Monument would total approximately 440 

155 acres. The historic Honouliuli Internment Camp and the adjacent overlook parcel (totaling 

approximately 123 acres) would be acquired by the NPS through a donation by the Monsanto 

Company. Additional Monsanto-owned lands (31.5 acres) with related resources would could be 

protected through conservation easements or land acquisition, land transfer, or other measures, at 

Monsanto’s discretion. Adjacent parcels (285 acres) owned by the University of Hawaiʻi would also 

be included in the boundary of the historic site to provide flexibility inestablishing public access to 

the site (NPS can only expend funds on roads within an authorized boundary unless Congressional 

legislation authorizes the use of funding for road maintenance on non-federally owned lands). 

Options for the University of Hawaiʻi parcels could include the University of Hawaiʻi maintaining 

ownership of the property, granting an easement to the NPS, or transferring ownership to the NPS 

by donation, exchange, or sale. Conservation easements could also be obtained for parcels directly 

adjacent to Honouliuli Internment Camp. Future development of road Easement 6134 could also 

provide opportunities for site access. All private property rights would be respected. 

The University of Hawaiʻi has committed to providing the NPS with public access to Honouliuli, 

initially through granting the NPS a right of entry over existing roads from the west. The University 

of Hawaiʻi is currently undergoing planning efforts for its lands adjacent to Honouliuli. This process 

and subsequent planning by the NPS should a national park unit be established may identify a 

new road alignment for public access. Once a desired road alignment for public access has been 

determined, this road alignment could be included in the national historic site or national monument 

through a boundary adjustment. This would allow the National Park Service to expend funds on the 

development maintenance of the access road.

Three Several parcels owned by the City and County of Honolulu Board of Water Supply (totaling 0.6 

acres) would be inholdings within the proposed area and would remain under current ownership and 

management. The communications site facilities, non-contributing features within the historic site, 

would not be included in the proposed boundary.

Page 122, right column, 3rd paragraph, 1st sentence, revised as follows:

The NPS would have direct management responsibility for the Honouliuli National Historic Site 

or National Monument including: 1) interpretation and education associated with the Honouliuli 

Internment Camp and its resources, including the development of interpretive media and programs; 

2) preservation and resource management for the historic site; and 3) operational facilities and 

infrastructure such as roads, restrooms, and trails.

Page 123, Map: Alternative B: Proposed Boundary, Honouliuli National Historic Site or Monument, 

Table: Parcels Included in Proposed Boundary, after column 1, additional column added to reference lot 

numbers.

Page 123, Map: Alternative B: Proposed Boundary, Honouliuli National Historic Site or Monument, 

Table: Parcels Included in Proposed Boundary, Row 2, Column 3, revised as follows:

922.5

Page 123, Map: Alternative B: Proposed Boundary, Honouliuli National Historic Site or Monument, 

Table: Parcels Included in Proposed Boundary, Row 7, Column 3, revised as follows:

229
Appendices  Appendix F: Errata 219

Page 123, Map: Alternative B: Proposed Boundary, Honouliuli National Historic Site or Monument, 

Table: Parcels Included in Proposed Boundary, after row 2, additional rows provided as follows:

92001008 5616-B CCH Board of Water Supply 

(Inholding)

0.401

92001009 9211 CCH Board of Water Supply 

(Inholding)

0.1

92001010 9212 CCH Board of Water Supply 

(Inholding)

0.1

Page 123, Map: Alternative B: Proposed Boundary, Honouliuli National Historic Site or Monument, 

callout text for parcel 92004009 within the proposed NPS boundary, revised as follows:

Conservation Easement Monsanto - 229 acres

Page 123, Map: Alternative B: Proposed Boundary, Honouliuli National Historic Site or Monument, 

callout text for parcel 92004001 within the proposed NPS boundary, revised as follows:

Conservation Easement Monsanto - 922.5 acres

Page 123, Map: Alternative B: Proposed Boundary, Honouliuli National Historic Site or Monument, 

callout text for Board of Water Supply Inholdings: 

(0.6 acres)

Page 124, left column, 1st paragraph, revised as follows:

NPS staff would protect and preserve the resources and setting of related to Honouliuli Internment 

Camp. Management plans would guide appropriate historic preservation documentation and 

treatments. As described below, there are opportunities to partner with local institutions and 

organizations in the protection of resources. The NPS would seek out partnership opportunities with 

existing organizations that have conducted research and documentation of the site. These include the 

Japanese Cultural Center of Hawaiʻi, which maintains the largest repository of archives and collection 

items related to Honouliuli and the internment in Hawai‘i, and the University of Hawaiʻi—West 

O‘ahu, whose faculty and students have been actively involved in researching the history of the site 

and conducting archeological field schools at Honouliuli.

Page 124, left column, 3rd paragraph, before 1st sentence, additional text as follows:

Other entities, specifically the University of Hawaiʻi—West O‘ahu and the Japanese Cultural Center of 

Hawaiʻi, have done significant work to document, preserve, and interpret the Honouliuli Internment 

Camp and the larger history of internment in Hawai‘i during World War II. The NPS would seek 

to maintain these partnerships for future management of the Honouliuli National Historic Site or 

Monument. In addition, tThe NPS would explore, develop, and maintain new partnerships for the 

preservation and interpretation of Honouliuli Internment Camp and related sites, features, and stories 

in Hawaiʻi. 

Page 124, right column, 1st paragraph, last sentence, revised as follows:

Possible partners include but are not limited to the University of Hawai‘i- West O‘ahu and the 

Japanese Cultural Center of Hawai‘i. 

Page 124, right column, 2nd paragraph, 1st sentence, revised as follows:

World War II-era internment and incarceration sites in Hawai‘i other than Honouliuli Internment 

Camp would continue to be owned and managed by their respective public and private owners.
220 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Page 124, right column, 2nd paragraph, 2nd sentence, revised as follows:

The associated sites illustrate the broad-reaching effects of internment on the six major islands in 

Hawai‘i and are essential valuable in accurately interpreting this history.

Page 124, right column, 3rd paragraph, 1st sentence, revised as follows:

Upon request, the NPS could work cooperatively with associated site owners and managers to 

explore opportunities for interpretation and/ or preservation of the associated sites.

Page 124, right column, 3rd paragraph, 2nd sentence, revised as follows:

For example, the U.S. Immigration Station played a central role in the internment process. Almost 

every person interned passed through the U.S. Immigration Station either for initial detention, 

processing for transfer to internment camps on O‘ahu and the mainland, or for hearings and trials. 

The NPS could contribute to further evaluation of the U.S. Immigration Station as a national historic 

landmark and explore opportunities to interpret its significance through waysides and exhibits.

Page 124, right column, 3rd paragraph, after 3rd sentence, additional text as follows:

Any request for technical assistance related to the associated sites would be voluntary on the part of 

the landowner.

Page 124, right column, 4th paragraph, 1st sentence, revised as follows:

Where appropriate, the NPS could also conduct research and respond to requests provide for 

assistance to related sites that have yet to be identified.

Page 124, right column, 5th paragraph, 1st sentence, revised as follows:

Management of Honouliuli National Historic Site or Monument would be managed through World 

War II Valor in the Pacific National Monument at Pearl Harbor, given its close proximity and related 

history.

Page 125, right column, 1st paragraph, 1st complete sentence, revised as follows:

The 7-acre overlook site could serve as an excellent location for a visitor staging area with ample space 

to provide for parking, visitor drop-off, interpretive features, and restrooms.

Page 125, right column, 1st paragraph, insert after last sentence:

Implementation planning would also explore opportunities for persons of all abilities to access and 

experience Honouliuli Internment Camp.

Page 125, right column, 2nd paragraph, revised as follows:

Currently there is no public access to Honouliuli Internment Camp does not currently exist because 

it is located on private property. Rights of access would be required to provide public access to the 

7-acre overlook parcel and the historic site. Existing roads would require considerable improvement 

to accommodate visitor access. As noted above, the University of Hawaiʻi has committed to working 

with the National Park Service with regard to providing public access on existing and future roads 

through its lands.

Page 126, right column, 1st paragraph, revised as follows:

Specific costs would be reevaluated in subsequent, more detailed planning for the unit. Planning 

would consider facility and site design, detailed identification of resource protection needs, and 

changing visitor expectations. Actual costs to the NPS would vary depending on timing and 

implementation and contributions by partners and volunteers. It is assumed that meeting the longrange financial needs of Honouliuli National Historic Site or Monument would not just rely upon 
Appendices  Appendix F: Errata 221

federally appropriated funds. A variety of other public and private funding sources could be sought 

by the NPS to assist in implementation efforts. Other NPS units have successfully found partners to 

help with funding major projects, and some of the costs associated with actions in the alternatives 

may prove to be less expensive when if donated materials, labor, and other support can be secured are 

forthcoming.

CHAPTER 7: ENVIRONMENTAL CONSEQUENCES

Page 130, Table 7-1: Impact Topics Analyzed, 1st row, revised as follows:

Land Use 

(including Prime 

and Unique 

Farmland)

Management Policies (NPS 2006) states: “...the Service will cooperate with federal 

agencies; tribal, state, and local governments; nonprofit organizations; and property 

owners to provide appropriate protection measures. Cooperation with these entities will 

also be pursued, and other available land protection tools will be employed when threats 

to resources originate outside boundaries.” Because the alternatives may affect land use, 

including ownership, occupancy and activities,land use has been retained as an impact 

topic.

The Farmland Protection Policy Act of 1981, as amended, requires federal agencies 

to consider adverse effects to prime and unique farmland that would result in the 

conversion of these lands to non-agricultural uses. Prime or unique farmland is classified 

by the USDA, Natural Resources Conservation Service and is defined as soil that 

particularly produces general crops such as common foods, forage, fiber, and oil seed; 

unique farmland produces specialty crops such as fruits, vegetables, and nuts. Prime 

farmland is one of several kinds of important farmland defined by the USDA. It is of 

major importance in meeting the nation’s short- and long-range needs for food and 

fiber. Because the supply of high-quality farmland is limited, the USDA recognizes that 

responsible levels of government, as well as individuals, should encourage and facilitate 

the wise use of our nation’s prime farmland.

ALISH (Agricultural Lands of Importance to the State of Hawaiʻi) is a Hawaiʻi state 

classification system that identifies agriculturally important lands and is intended to 

provide decision makers with a tool for use in agricultural preservation, planning, and 

development.The criteria for classification of prime agricultural land are identical to 

the criteria established by Soil Conservation Service, U.S.Department of Agriculture 

for national application. The criteria for unique agricultural and other important 

agricultural lands were established cooperatively by the Soil Conservation Service in 

Hawaiʻi, the College of Tropical Agriculture, and the State Department of Agriculture. 

Based on planning maps available through the State of Hawaiʻi Office of Planning 

website, areas immediately adjacent to Honouliuli Gulch are considered prime and 

Unique farmlands.

The potential for an introduction of visitors to an area surrounded by ALISH lands may 

present an impact to agricultural operations, therefore this topic has been retained.
222 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Page 130, Table 7-1: Impact Topics Analyzed, 3rd row, revised as follows:

Prime and Unique 

Farmlands 

(Agricultural Lands 

of Importance to 

the State of Hawaiʻi 

[ALISH]) 

Prime and Unique Farmlands (Agricultural Lands of Importance to the State of Hawaiʻi 

[ALISH]) The Farmland Protection Policy Act of 1981, as amended, requires federal 

agencies to consider adverse effects to prime and unique farmlands that would result 

in the conversion of these lands to non-agricultural uses. Prime or unique farmland is 

classified by the USDA, Natural Resources Conservation Service and is defined as soil 

that particularly produces general crops such as common foods, forage, fiber, and oil 

seed; unique farmland produces specialty crops such as fruits, vegetables, and nuts. 

Prime farmland is one of several kinds of important farmland defined by the USDA. It is 

of major importance in meeting the nation’s short- and long-range needs for food and 

fiber. Because the supply of high-quality farmland is limited, the USDA recognizes that 

responsible levels of government, as well as individuals, should encourage and facilitate 

the wise use of our nation’s prime farmland.

ALISH (Agricultural Lands of Importance to the State of Hawaiʻi) is a Hawaiʻi state 

classification system that identifies agriculturally important lands and is intended to 

provide decision makers with a tool for use in agricultural preservation, planning and 

development. Based on planning maps available through the state of Hawaiʻi Office of 

Planning website, the area immediately adjacent Honouliuli Gulch is considered Prime 

and Unique Farmlands. 

The potential for an introduction of visitors to an area surrounded by ALISH lands may 

present an impact to agricultural operations, therefore this topic has been retained. 

Page 131, Table 7-1: Impact Topics Analyzed, Discussion and Rationale column, 2nd paragraph, 1st 

sentence, revised as follows:

Compliance with the ARPA Archeological Resources Protection Act in protecting known or 

undiscovered archeological resources is necessary.

Page 138, left column, insert after 3rd paragraph:

PRIME AND UNIQUE FARMLAND

Based on the ALISH (Agricultural Lands of Importance to the State of Hawaiʻi) classification system, 

most areas within the historic internment camp, as defined by the National Register of Historic 

Places, are not considered prime or unique farmland. Only two small areas, one in the far north of 

the historic site, and one in the far east near the current entry road, are classified as prime farmland. 

No lands are classified as unique farmland. These two areas are owned by the Monsanto Company, 

but are currently fallow. Areas to the west of the historic site owned by the University of Hawaiʻi, 

and the 7-acre overlook parcel owned by the Monsanto Company, are classified as prime farmland. 

The 7-acre site is currently fallow. However, most of the UHWO lands are under cultivation (see 

Map: Prime and Unique Farmland). The University of Hawai‘i is currently working on a strategic 

land use plan that will determine the future use of these agricultural lands which could include either 

university or non-university related land uses. 

Page 138, right column, 1st paragraph, last sentence, additional text to follow:

Direct effects to prime farmland adjacent to Honouliuli Internment Camp would be dependent on 

future use of the land as determined by the University of Hawai‘i in its strategic land planning process. 

Occasional use of Honouliuli Gulch for interpretive tours and research as permitted by the current 

landowner would have no direct effects on prime farmland.

Page 138, right column, 2nd paragraph, last sentence, revised as follows:

Pending continued protection of sites designated or eligible as NHLs or listed in the National Register 

of Historic Places (NRHP), effects would remain moderate.
Appendices  Appendix F: Errata 223

Page 138, right column, 3rd paragraph, 3rd sentence, revised as follows:

Possible changes to zoning could occur through Ccity and Ccounty of Honolulu (and adjacent 

landowner) land use plans to reflect the historic preservation of Honouliuli Gulch and visitor uses.

Page 139, left column, 2nd paragraph, last sentence, additional text to follow:

Direct effects to prime farmland could result from road improvements required for visitor access. The 

extent of such effects would need to be reassessed should the University of Hawai‘i’s strategic land 

planning process identify future activities and uses other than agriculture for these parcels.

Page 139, left column, 3rd paragraph, 2nd sentence, revised as follows:

Likely support for visitor facilities would be in the vicinity of the UHWO University of Hawai‘i – 

West O‘ahu campus to take advantage of existing development plans and more easily manage access 

methods (i.e., shuttle buses).

Page 139, left column, 5th paragraph, 1st sentence, revised as follows:

Under alternatives A and B, there could be cumulative impacts on land use resulting from the campus 

development on the UHWO University of Hawai‘i – West O‘ahu lands to the west of Honouliuli 

Gulch and construction of the Honolulu rail line.

Page 139, right column, 3rd paragraph, 1st sentence, revised as follows:

Alternative A would have no direct effects on land use, but lack of a specific preservation direction for 

Honouliuli Gulch could result in incremental changes to use of the agricultural lands surrounding the 

gulch, resulting in long-term moderate to major adverse impacts to the Honouliuli Gulch Internment 

Camp.

Page 139, right column, 4th paragraph, 2nd sentence, revised as follows:

With a reliance on ‘offsite’ visitor contact infrastructure (in the vicinity of the UHWO University 

of Hawai‘i – West O‘ahu), and utilization of existing roads, visitor impacts to existing agricultural 

operations surrounding Honouliuli Gulch would be limited.

Page 139, right column, 4th paragraph, 3rd sentence, revised as follows:

Impacts to the UHWO’s University of Hawai‘i – West O‘ahu’s parcels in the immediate vicinity of 

Honouliuli Gulch area would need to be reassessed should the university’s planning process identify 

an activity other than agriculture for these parcels.

Page 140, left column, 1st paragraph, 5th sentence, revised as follows:

At the northern end of the gulch, the U.S. Geological Survey (USGS) maintains a stream flow gauge 

gage (station number 16212480 Honouliuli Stream Tributary).

Page 140, left column, 4th paragraph, 1st sentence, revised as follows:

Although modifications could be made to accommodate visitor parking and walking trails through 

the gulch, the known water resources located at this site (i.e. ground water pumping station used to 

support existing Bureau of Water Supply operations, the ephemeral stream, the USGS Water Gauge 

Gage) would not be adversely impacted.

Page 140, right column, 4th paragraph, 2nd sentence, revised as follows:

Limited data from the USGS water gauge gage shows that water flow in the ephemeral stream occurs 

in the form of flash floods with fast draw down periods.
224 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Page 142, left column, 5th paragraph, 1st sentence, revised as follows:

Much of the Honouliuli Gulch area is overgrown with vegetation, most notably invasive species such 

as guinea Guinea grass (Panicum maximum) and haole koa (Leucaena sp.) with Chinese banyan trees 

(Ficus microcarpa) near the creek drainage that runs north to south through roughly the center of the 

gulch.

Page 142, right column, 1st paragraph, 1st sentence, revised as follows:

After discussion with the U.S. Fish and Wildlife Service, a determination was made that there were 

no listed species present in the vicinity of the Honouliuli Gulch, so the NPS decided to dismiss 

threatened and endangered T&E species from further consideration.

Page 144, right column, 2nd paragraph, last sentence, revised as follows:

Other sites that were found to be nationally significant and retain a high degree of integrity include 

the U.S. Immigration Station, currently listed in the National Register of Historic Places and Kilauea 

Military Camp, eligible to be listed in the National Register of Historic Places.

Page 147, right column, 2nd paragraph, 2nd sentence, revised as follows:

It is not clear whether other associated sites (Maui County Jail and Courthouse, Lihue Courthouse, 

Honolulu Downtown Jail) would continue to be preserved. 

Page 148, left column, 3rd paragraph, 2nd sentence, revised as follows:

However, a range of documents, oral histories, art, and other objects is available to researchers at the 

Japanese Cultural Center of Hawai’i research center in Honolulu.

Page 152, left column, 1st paragraph, 2nd sentence, revised as follows:

West O‘ahu is where the ‘second city’ “second city” of Kapolei is being promoted as an alternative 

governmental agency center away from the high-density Kakaako district near downtown Honolulu.

CHAPTER 8: CONSULTATION AND COORDINATION

Page 158, left column, 1st paragraph, 1st sentence, revised as follows:

Public comments were universal predominantly expressed in the desire to commemorate the 

internment experience in Hawai‘i.

Page 159, left column, 2nd paragraph, last sentence, revised as follows:

To comply with NPS responsibilities for Section 106, at the time of release of the this draft study 

in May 2014, the NPS requested consultation by will consult with the State Historic Preservation 

Division to seek concurrence on 1) recognition of the special resource study undertaking, 2) the 

area of potential effect, 3) identification of historic properties within the Honouliuli Gulch area, 

and 4) finding of No Adverse Effect to historic properties. The State Historic Preservation Division 

concurred with these findings in a letter dated September 23, 2014.

Page 159, left column, 3rd paragraph, last sentence, revised as follows:

The U.S. Fish and Wildlife Service is was invited to comment on the draft study.

Page 159, right column, 4th row from the bottom, revised as follows:

Department of Lands and Natural Resources

Page 159, right column, last row, revised as follows:

Department of Hawaiian Home Lands Homelands 
Appendices  Appendix F: Errata 225

Page 160, new section to follow: “Public Review of Draft Study Report”

APPENDICES

Page 167, 1st row, revised as follows:

Appendix D: Japanese American Wartime Incarceration Properties, Summary of Known Recognition, 

July 2011

Page 170–171, last section of table (“Other Internment/Detention Facilities”) reorganized to conform to 

alphabetical order. No changes in content made.

Page 171, 4th row, revised as follows:

Maui County Jail, 

Courthouse, and Police 

Station

Maui County, HI National Register 

8-20-1988 (included in 

Wailuku Civic Center 

Historic District, not 

for Japanese American 

association)

None known

Maui County Jail Maui County, HI No Federal designation None known

REFERENCES 

Page 174, image reference for photo on page 42:

Barracks and tents at Honouliuli, with the women’s internee compound in the background. A portion 

of the rock wall visible in the background behind still stands on the site today. Photo by R. H. Lodge, 

c. 1945, courtesy Hawai‘i’s Plantation Village.

Page 175, last paragraph, move “Selected Bibliography” to precede bibliography.

Page 176, before Allen, Gwenfread citation, revised as follows:

Adler, Susan Matoba

2014 “The Effect of Internment on Children and Families: Honouliuli and Manzanar.” In 

 Breaking the Silence: Lessons of Democracy and Social Justice from the World War II 

 Honouliuli Internment and POW Camp in Hawai‘i, edited by Suzanne Falgout 

 and Linda Nishigaya, 217–236. Social Process in Hawai‘i, Vol. 45. Honolulu, HI: 

 University of Hawai‘i Press.

Page 176, before Daws, Gavan citation, revised as follows:

City and County of Honolulu 

2002 City and County of Honolulu General Plan (as amended 2002). Available on the 

 internet at: http://honoluludpp.org/Planning/GeneralPlan.aspx

2013 ‘Ewa Development Plan. Department of Planning and Permitting. Available on the 

 internet at: http://www.honoluludpp.org/Planning/ 

 DevelopmentSustainableCommunitiesPlans/EwaPlan.aspx
226 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

Page 176, before Faye, Christine, Michael Faye, and Roy Miyake citation, revised as follows:

Falgout, Suzanne

2014 “Honouliuli’s POWs: Making Connections, Generating Changes.” In Breaking the 

 Silence: Lessons of Democracy and Social Justice from the World War II Honouliuli 

 Internment and POW Camp in Hawaiʻi, edited by Suzanne Falgout and Linda 

 Nishigaya, 109–147. Social Process in Hawai‘i, Vol. 45. Honolulu, HI: University of 

 Hawaiʻi Press.

Falgout, Suzanne and Linda Nishigaya, eds.

2014 Breaking the Silence: Lessons of Democracy and Social Justice from the World War II 

 Honouliuli Internment and POW Camp in Hawaiʻi. Social Process in Hawai‘i, Vol. 45. 

 Honolulu, HI: University of Hawai‘i Press.

Page 177, before Helber Hastert and Fee Planners, Inc., revised as follows:

Hawai‘i Department of Planning and Economic Development

1986 The Hawaiʻi State Plan, Revised. Prepared by Hawaiʻi State Plan Policy Council, 

 Department of Planning and Economic Development. Honolulu, HI.

Page 177, before Kashima, Tetsuden, revised as follows:

Japanese Cultural Center of Hawai’i (JCCH) 

2014 Personal communication, September 1, 2014.

Page 179, before Saiki, Patsy Sumie Saiki, revised as follows:

Alan Rosenfeld

2014 “Neither Aliens nor Enemies: The Hearings of ‘German’ and ‘Italian’ Internees in 

 Wartime Hawai’i.” In Breaking the Silence: Lessons of Democracy and Social Justice 

 from the World War II Honouliuli Internment and POW Camp in Hawaiʻi, edited by 

 Suzanne Falgout and Linda Nishigaya, 80-108. Social Process in Hawai‘i, Vol. 45. 

 Honolulu, HI: University of Hawai‘i Press.

Page 179, Saiki, Patsy Sumie Saiki, revised as follows:

Saiki, Patsy Sumie Saiki

Page 182, right column, 7th paragraph, revised as follows:

Jeff Burton

Cultural Resources Program Manager, Manzanar National Historic Site Trans-Sierran Archaeology
 References 227

REFERENCES

LIST OF HISTORICAL IMAGES

Page number Caption and Source

Cover Photo of the Honouliuli Internment Camp, c. 1945, by R. H. Lodge. Courtesy 

 of Hawai‘i’s Plantation Village, Waipahu, HI. 

xiv Images of the Sand Island Internment Camp during World War II. National 

 Park Service, World War II Valor in the Pacific National Monument archives, 

 Honolulu, HI.

Chapter 2 Coast Guard Station at Sand Island, O‘ahu, November 1946. Courtesy of the 

divider Japanese Cultural Center of Hawai‘i, Honolulu, HI.

5 Japanese store, Honolulu, c. 1895–1910. Library of Congress, Prints & 

 Photographs Division, Washington, DC: LC-DIG-det-4a20736.

6 Japanese emigrants on sisal plantation, Hawai‘i, c. 1910–1915. Library of 

 Congress, George Grantham Bain Collection, Prints & Photographs Division, 

 Washington, DC: LC-DIG-ggbain-13386.

7 Pearl Harbor Naval Base and the U.S.S. Shaw ablaze following the Japanese 

 attack, December 7, 1941. Library of Congress, Prints & Photographs 

 Division, Washington, DC: LC-USZ62-16555.

9 Drawing of the women’s internee compound at Honouliuli by Dan Toru 

 Nishikawa, 1943. Courtesy of the Japanese Cultural Center of Hawai‘i, 

 Honolulu, HI.

10 Civilian Exclusion Order demanding the removal of all persons of Japanese 

 ancestry, San Francisco. Photograph by Dorothea Lange, April 11, 1942. 

 Courtesy of the Bancroft Library, University of California, Berkeley.

10 In response to Civilian Exclusion Order No. 20, San Francisco residents of 

 Japanese ancestry wait to register with the Civil Control Station. Photograph 

 by Dorothea Lange, April 25, 1942. Courtesy of the Bancroft Library, 

 University of California, Berkeley.

12 Families board a bus in Centerville, CA that will take them to a temporary 

 detention camp known as an “assembly center.” Photograph by Dorothea 

 Lange, May 9, 1942. Courtesy of the Bancroft Library, University of 

 California, Berkeley.

12 A grandfather and grandchildren await transportation, Hayward, CA. 

 Photograph by Dorothea Lange, May 8, 1942. Courtesy of the Bancroft 

 Library, University of California, Berkeley.

12 Families arrive at the WRA center at Heart Mountain, WY, September 1943. 

 Photograph by Bud Aoyama. Courtesy of the Bancroft Library, University of 

 California, Berkeley.

12 Arrivals at the Salinas Assembly Center, California. Photograph by Clem 
228 Honouliuli Gulch & Associated Sites Final Special Resource Study and Environmental Assessment 

 Albers, March 31, 1942. Courtesy of the Bancroft Library, University of 

 California, Berkeley.

20 Gate at Sand Island Internment Camp. Photographer unknown, c. 1942. U.S. 

 Army Museum of Hawai‘i, Honolulu, HI.

20 Detainees at Sand Island Internment Camp lived in tents for six months 

 until barracks were constructed. Photographer unknown, c. 1942. U.S. 

 Army Museum of Hawai‘i, Honolulu, HI.

22 Portraits of internees by George Hoshida. Courtesy of the George Hoshida 

 Collection. Gift of June Hoshida Honma, Sandra Hoshida, and Carole 

 Hoshida Kanada. Japanese American National Museum, Los Angeles, CA.

25 View of tents in Compound # 4 for POWs at Honouliuli Internment Camp, c. 

 1945, by R. H. Lodge. Courtesy of Hawai‘i’s Plantation Village, Waipahu, HI.

31 Kilauea Military Detention Camp. Drawing by George Hoshida, 1942. 

 Courtesy of the George Hoshida Collection. Gift of June Hoshida Honma, 

 Sandra Hoshida, and Carole Hoshida Kanada. Japanese American National 

 Museum, Los Angeles, CA.

32 1932 aerial photograph of the landing field at Hilo Airport, near the Waiākea 

 Prison Camp. Courtesy Hawai‘i Department of Transportation, Honolulu, HI.

35 Wailua County Jail, Kaua‘i, possibly with internee housing in the background. 

 Photo taken by Lt. James Daniels during WWII. Courtesy of the 

 Kaua‘i Museum Archives, Līhuʻe, HI.

Chapter 3 A view into daily life at Honouliuli Internment Camp, c. 1945, by R. H. Lodge. 

divider Courtesy of Hawai‘i’s Plantation Village, Waipahu, HI. 

42 Barracks and tents at Honouliuli, with the women’s internee compound in the 

 background. A portion of the rock wall visible behind still stands on the site 

 today. Photo by R. H. Lodge, c. 1945, courtesy of Hawai‘i’s Plantation Village, 

 Waipahu, HI. 

44 Sketch of internees working on crafts at Honouliuli by Dan T. Nishikawa, 

 April 29, 1943. Courtesy of the Japanese Cultural Center of Hawai‘i, Dan Toru 

 Nishikawa Family Collection, Honolulu, HI.

49 The U.S. Immigration Station, Honolulu, as it appeared in 1938. Photo on 

 display at the U.S. Immigration Station, Honolulu.

70 Japanese American heads of family and persons living alone wait outside the 

 Civil Control Station, San Francisco, in response to Civilian Exclusion Order 

 Number 20. Photograph by Dorothea Lange, April 25, 1942. National 

 Archives and Records Administration, College Park, MD.

72 This photograph of Manzanar, taken by Ansel Adams in 1943, illustrates the 

 exposed, remote conditions of the majority of mainland incarceration 

 sites. Manzanar War Relocation Center Photographs, Library 
 References 229

 of Congress, Prints & Photographs Division, Washington, 

 DC: LC-DIG-ppprs-00284.

73 Tule Lake: internees contribute to a large-scale agricultural operation typical 

 of mainland sites, c. 1942–43. Farm Security Administration/Office of 

 War Information Collection, Library of Congress Prints & Photographs 

 Division,Washington, DC: LC-DIG-fsac-1a35013.

73 Women pose outside a barber shop at Tule Lake, c. 1942–43. Farm Security 

 Administration/Office of War Information Collection, Library of Congress 

 Prints & Photographs Division, Washington, DC: LC-DIG-fsac-1a35014.

77 A 1940 photograph of Camp Tulelake, looking northeast, when the camp was 

 being used by the Civilian Conservation Corps. National Archives and 

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84 The church in the Aleutian village Kashega in 1938, photographed by Alan G. 

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 Consortium Library, University of Alaska Anchorage.

84 Unangan children forcibly removed from their homes and relocated to 

 Southeast Alaska. Photo: George Dale, 1942. Courtesy Alaska State Library, 

 Evelyn Butler and George Dale Collection, ASL-P306-1056.

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STUDY TEAM AND 

PREPARERS

NPS Study Team

The NPS study team is based in the National 

Park Service’s Pacific West Region. Study 

team members were responsible for public 

involvement and outreach, technical reviews, 

research, writing and analysis, development of 

the alternatives, environmental compliance, and 

production of the study report.

Betsy Anderson

Landscape Architect, Park Planning and 

Environmental Compliance 

Suzanne Bott

Former Outdoor Recreation Planner, Project 

Manager, Park Planning and Environmental 

Compliance 

Barbara Butler Baunsgard

Landscape Architect, Project Manager, Park 

Planning and Environmental Compliance 

Suzanne Boyce Carlson

Assistant Field Solicitor, Department of the 

Interior

Martha Crusius

Chief of Park Planning and Environmental 

Compliance

Paul DePrey

Former Superintendent, World War II Valor in 

the Pacific National Monument

Natascha Fraser

Realty Specialist, Land Resources Program 

Center

Greg Gress

Chief, Pacific Land Resources Program Center

Frank Hays

Former Manager, Pacific Islands 

Office—Honolulu

Cari Kreshak

Former Pacific Islands Cultural Resources 

Program Manager & PWR Section 106 

Coordinator

Melia Lane-Kamehele

Manager, Pacific Islands Office—Honolulu

Anna Tamura

Landscape Architect, Project Manager, Park 

Planning and Environmental Compliance

Consultants

Mary M. Farrell

Trans-Sierran Archaeology 

Acknowledgements 

The NPS study team asked for and received 

tremendous help from many people and 

organizations. They hosted public meetings, 

publicized the study and meetings, provided 

historic photos and other documentation, 

organized site visits and tours, and provided 

many ideas. We extend a warm mahalo nui loa

to: 

Neil Abercrombie

Former Governor, State of Hawai‘i

Jeff Burton

Cultural Resources Program Manager, 

Manzanar National Historic Site

Ty Cullen

Hawai‘i State Representative

Will Espero

Hawai‘i State Senator

Suzanne Falgout, Ph.D.

Professor, University of Hawai‘i, West O‘ahu

Yarrow Flower

Real Estate Associate, Monsanto Company, 

Hawai‘i
 Study Team and Preparers 237

Carol Fukunaga

Honolulu City Council

Honorable Tulsi Gabbard

United States Representative, Hawai‘i

Honorable Colleen Hanabusa 

Former United States Representative, 

Hawai‘i

Carole Hayashino

President & Executive Director, Japanese 

Cultural Center of Hawai‘i 

Honorable Mazie Hirono

United States Senator, Hawai‘i

Tetsuden Kashima, Ph.D.

Professor of American Ethnic Studies, 

University of Washington

Marcia Kemble

Resource Center Manager, Japanese Cultural 

Center of Hawai‘i

Jane Kurahara

Staff Associate, Japanese Cultural Center of 

Hawai‘i

Brian Niiya

Formerly of the Japanese Cultural Center of 

Hawai‘i

Fred Perlak

Vice President of Research and Business 

Operations, Monsanto Company, Hawai‘i

Alan Rosenfeld, Ph.D.

Assistant Professor of History, University of 

Hawai‘i, West O‘ahu

Honorable Brian Schatz

United States Senator, Hawai‘i

Alan Takemoto

Community Affairs Director, Monsanto 

Company, Hawai‘i

Betsy Young

Staff Associate, Hawai‘i Confinement Sites 

Education, Japanese Cultural Center of Hawai‘i

Honouliuli Park Site Advisory Committee

Pua Aiu, Ronald Chung, Suzanne Falgout, 

Kiersten Faulkner, Carole Hayashino, Jacce 

Mikulanec, Duk Hee Murabayashi, Alan 

Takemoto, Angie Westfall

The National Park Service cares for the special places saved by the American people 

so that all may experience our heritage.

Experience Your America

As the nation’s principal conservation agency, the Department of the Interior has 

responsibility for most of our nationally owned public lands and natural resources. 

This includes fostering sound use of our land and water resources; protecting our 

fish, wildlife, and biological diversity; preserving the environmental and cultural 

values of our national parks and historical places; and providing for the enjoyment 

of life through outdoor recreation. The department assesses our energy and mineral 

resources and works to ensure that their development is in the best interests of all 

our people by encouraging stewardship and citizen participation in their care. 

The department also has a major responsibility for American Indian reservation 

communities and for people who live in island territories under U.S. administration.

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