National Park Service 

U.S. Department of the Interior 

Hawai‘i Volcanoes National Park 

SPRING 2016

HAWAI‘I VOLCANOES NATIONAL PARK 

Abbreviated Final General Management Plan, Wilderness Study, and Environmental Impact Statement 
Hōlei Sea Arch. Photo by Peter Anderson. 
ABSTRACT
 

HAWAI‘I VOLCANOES NATIONAL PARK ABBREVIATED FINAL GENERAL MANAGEMENT PLAN /
 

WILDERNESS STUDY / ENVIRONMENTAL IMPACT STATEMENT
 

The Hawai‘i Volcanoes National Park Draft General Management Plan / Wilderness Study / Environmental Impact Statement 

(Draft GMP/WS/EIS) examines three possible management strategies or “alternatives,” including the impacts of 

implementing these alternatives in the park. These alternatives, described below, address visitor use and the preservation of 

natural and cultural resources to protect and interpret the significance of the park. They comply with National Park Service 

(NPS) planning requirements and respond to issues identified during the public scoping process. This draft plan was available 

for public and agency review from May 1, 2015 through June 30, 2015. 

Alternative 1 (no action) would assume that existing programming, facilities, staffing, and funding would generally continue 

at current levels to protect the values of Hawai‘i Volcanoes National Park. There would be no major changes in current 

management or visitor use, and implementation of currently approved plans would continue as funding allows. 

Alternative 2 (preferred) would strengthen and broaden opportunities to connect people with the volcanic world 

treasure, Hawai‘i Volcanoes National Park, and provide a wide range of high-quality visitor experiences based on different 

geographic areas. This alternative emphasizes the park’s role as a refuge and haven for native biota, people, and cultures 

in a world constantly adapting to volcanic activity and island-building processes and emphasizes Native Hawaiian values 

such as mālama ʻāina (nourishing or taking care of the land) and kuleana (responsibility) as important concepts in park 

stewardship of resources. 

Alternative 3 emphasizes building new connections with the park, primarily through expanded education and handson stewardship opportunities. As in the preferred alternative, this alternative emphasizes the park’s role as a refuge 

and haven for native biota, people, and cultures in a world constantly adapting to volcanic activity and island-building 

processes and emphasizes Native Hawaiian values such as mālama ʻāina and kuleana as important concepts in park 

stewardship of resources. 

All alternatives also recommend modifying the boundary of Hawai‘i Volcanoes National Park to include 31,784 acres 

of previously identified high priority lands. In addition, the plan includes a Wilderness Study through which the NPS 

recommends wilderness designation of the lands found eligible in Kahuku (121,015 acres), which was acquired by the NPS 

in 2003. This designation of wilderness in Kahuku would create connectivity for park wilderness that would span from the 

summit of Mauna Loa Volcano down its massive Southwest Rift. Consistent with NPS policy, the park would continue to 

manage these proposed eligible lands for their wilderness qualities prior to formal designation. 

Environmental impacts resulting from implementation of the alternatives are addressed in the Draft GMP/WS/EIS. Impact 

topics include: weather and climate; air quality; volcanoes and volcanic processes and features; soils; vegetation; native 

wildlife and wildlife habitat; special status species; water resources; night skies; climate change; wilderness; soundscapes and 

the acoustic environment; historic resources; archeological resources; cultural landscapes; ethnographic resources; museum 

collections; visitation; visitor opportunities and experiences; interpretation, education, and outreach; commercial visitor 

services; visitor and employee health and safety; transportation and access; socioeconomics; partnerships and agreements; 

adjacent land management; and park operations. 

This document is the Hawai‘i Volcanoes National Park Abbreviated Final General Management Plan / Wilderness Study / 

Environmental Impact Statement (Final GMP/WS/EIS). It responds to and incorporates the public and agency comments 

received on the Draft GMP/WS/EIS. An abbreviated final GMP/WS/EIS is used because the comments received require 

only minor changes involving only factual corrections or explanations of why comments do not warrant further response. 

No substantial changes have been made to the alternatives or to the impact analyses presented in the Draft GMP/WS/EIS 

as a result of public comments. Therefore, Alternative 2 remains the NPS preferred alternative. Following the public release 

of this Abbreviated Final GMP/WS/EIS, there will be a 30-day no action period, after which the NPS will prepare a record 

of decision documenting the selected alternative and setting forth any stipulations for implementation of the GMP. This 

Abbreviated Final GMP/WS/EIS and Draft GMP/WS/EIS will constitute the complete and final documentation upon which 

the record of decision will be based. 

HAWAI‘I VOLCANOES NATIONAL PARK, PO BOX 52, HAWAI‘I NATIONAL PARK, HI 96718 | 808.985.6303 

PREPARED BY THE UNITED STATES DEPARTMENT OF THE INTERIOR: NATIONAL PARK SERVICE i 
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ii FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS 
HAWAI‘I VOLCANOES NATIONAL PARK
 

Abbreviated Final General Management Plan, Wilderness Study, and Environmental Impact Statement 

Hawai‘i Volcanoes National Park 

PO Box 52 

Hawai‘i National Park, HI 96718 

Attn: Danielle Foster 

808.985.6303 

Prepared by: 

National Park Service 

Pacific West Region – Seattle Office 

Park Planning and Environmental Compliance 

909 1st Avenue 

Seattle, WA 98104 

FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS iii 
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iv FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS 
LETTER FROM THE SUPERINTENDENT
 

Aloha Friends, 

We are pleased to share with you the Hawai‘i Volcanoes National Park Abbreviated Final General 

Management Plan/Wilderness Study/Environmental Impact Statement (Final GMP/WS/EIS). The 

document includes an analysis of comments received on the Draft GMP/WS/EIS with NPS responses, 

errata sheets detailing editorial corrections to the Draft GMP/WS/EIS, and copies of letters received 

from agencies and organizations. 

The plan will guide long-term decisions about the preservation and use of Hawai‘i Volcanoes 

National Park. Over the past few years, the public has participated in the planning process through 

public meetings, formal and informal consultation, newsletters, and materials posted on websites and 

through social media. In May 2015, the Draft GMP/WS/EIS was available for public review for over 

60 days. Approximately 800 interested individuals, agencies, and organizations were sent a newsletter 

summarizing the alternatives in the plan. These newsletters, as well as copies of the draft plan were 

also available for review at the park’s visitor centers, at local libraries, and on the NPS Planning, 

Environment, and Public Comment (PEPC) website (http://parkplanning.nps.gov/HAVO). 

The National Park Service (NPS) hosted a public meeting/talk story session and wilderness 

hearing on June 10, 2015. Press releases, email notifications, social media posts, and messages on 

the park’s nps.gov homepage announced the availability of the document, as well as the talk story 

session date and time. 

The NPS received 32 pieces of correspondence on the draft plan. This commentary was thoughtful, 

helpful, and sincere. We would like to thank the people who commented for sharing their insights. 

We also would like to express our appreciation to the many people – partners, advisors, and members 

of the public – who provided input throughout the planning process. Your input has confirmed our 

belief that alternative 2 is the preferred alternative and that the management actions it proposes will 

best guide long-term stewardship of Hawai‘i Volcanoes National Park. 

The enclosed document is in an abbreviated form because comments received during the public 

review period required only minor responses and editorial changes to the Draft GMP/WS/EIS. 

There are no substantial changes to the alternatives or the impact analyses presented in the Draft 

GMP/WS/EIS. Alternative 2 remains the NPS preferred alternative. The abbreviated format has 

allowed us to produce a simple, brief document and to avoid the costly reprinting of the entire 500­

plus page document. 

The public release of the Abbreviated Final GMP/WS/EIS will be followed by a 30-day no-action 

period, after which the NPS will prepare a record of decision to document the selected alternative. 

The Abbreviated Final GMP/WS/EIS and the Draft GMP/WS/EIS constitute the documentation upon 

which the record of decision will be based. 

Mahalo nui loa, 

Cindy Orlando 

Superintendent 

You can access information about the Hawai‘i Volcanoes National Park GMP/WS/EIS at 

http://www.nps.gov/havo/parkmgmt/plan.htm. 

FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS v 
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vi FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS 
HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS

TABLE OF CONTENTS
 

ABSTRACT .................................................................................................................. i
 

LETTER FROM THE SUPERINTENDENT......................................................................... v
 

PUBLIC REVIEW AND COMMENTS ON DRAFT GMP/WS/EIS........................................ 1
 

INTRODUCTION .................................................................................................................1
 

SUMMARY OF THE PUBLIC REVIEW PROCESS FOR THE DRAFT GMP/WS/EIS............................1
 

COMMENTS AND RESPONSES SUMMARY ............................................................................3
 

ERRATA: CHANGES AND CLARIFICATIONS TO THE DRAFT GMP/WS/EIS ................... 19
 

APPENDIX A: AGENCY AND ORGANIZATION COMMENTS ........................................ 21
 

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viii HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS 
PUBLIC REVIEW AND COMMENTS ON DRAFT GMP/WS/EIS
 

INTRODUCTION 

This document is the Hawai‘i Volcanoes National 

Park Abbreviated Final General Management Plan/ 

Wilderness Study/Environmental Impact Statement 

(Final GMPS/WS/EIS). The material included 

here is to be combined with the Hawai‘i Volcanoes 

National Park Draft General Management Plan / 

Wilderness Study / Environmental Impact Statement 

(Draft GMP/WS/EIS) that was distributed for public 

review in May 2015. The 60-day public review 

period was held from May 1, 2015 through June 30, 

2015. This document is composed of a summary of 

the public review process for the Draft GMP/WS/ 

EIS, the National Park Service (NPS) responses 

to public comments, errata detailing editorial 

changes to the Draft GMP/WS/EIS, and copies of 

comment letters from agencies, business, and other 

organizations (Appendix A). 

An abbreviated final GMP/WS/EIS is used because 

the comments received on the draft document 

require only “minor changes involving only factual 

corrections or explanations of why comments do 

not warrant further response” (Director’s Order 12 

Handbook 2015). No substantial changes have been 

made to the alternatives or to the impact analyses 

presented in the Draft GMP/WS/EIS as a result 

of public comments. Rather than updating and 

republishing the Draft GMP/WS/EIS as a full-length 

500-plus page document, this abbreviated final 

incorporates the Draft GMP/WS/EIS by reference 

and responds to comments and text changes within 

an errata that is included within this document. 

Use of this format is in compliance with the 1969 

National Environmental Policy Act (NEPA) 

regulations (40 Code of Federal Regulations or 

CFR 1503.4 (c)) and Director’s Order #12 (2011) 

and associated NEPA Handbook (2015). The draft 

and abbreviated final documents together present 

the full Hawai‘i Volcanoes National Park General 

Management Plan / Wilderness Study / Environmental 

Impact Statement, including the alternatives, 

associated environmental impacts, comments 

that were received and evaluated, and responses 

to the comments. 

Following the public release of this Abbreviated 

Final GMP/WS/EIS, there will be a 30-day no action 

period, after which the NPS will prepare a record of 

decision documenting the selected alternative and 

setting forth any stipulations for implementation of 

the GMP. This Abbreviated Final GMP/WS/EIS and 

Draft GMP/WS/EIS will constitute the complete 

and final documentation upon which the record of 

decision will be based. 

SUMMARY OF THE PUBLIC 

REVIEW PROCESS FOR THE 

DRAFT GMP/WS/EIS 

The official public review process for Hawai‘i 

Volcanoes National Park Draft General Management 

Plan / Wilderness Study / Environmental Impact 

Statement began on May 1, 2015 and ended July 30, 

2015. The NPS announced the public release of the 

Draft GMP/WS/EIS and invited public comment 

through a notice in the Federal Register, press 

releases, websites, mailings, social media, and a 

public talk story session (open house style meeting) 

and formal wilderness hearing. 

The NPS formally announced the public review 

process through a Notice of Availability published 

by the Environmental Protection Agency (EPA) in 

the Federal Register on May 1 (v80, n84, pp 24915). 

The NPS published the Notice of Availability again 

on May 6, 2015 (v80, n87, pp 26086). A press release 

announcing the availability of the Draft GMP/ 

WS/EIS was distributed to local and regional news 

media on April 30, 2015, and the draft plan and 

information about how to provide public comments 

were made available on the NPS and Planning, 

Environment, and Public Comment (PEPC) websites 

(www.nps.gov/havo and http://parkplanning.nps. 

gov/havogmp) on May 1, 2015. The project site 

on the PEPC website (http://parkplanning.nps. 

gov/havogmp) also included a venue to accept 

public comments. In late April 2015, the NPS 

distributed approximately 107 paper and digital 

copies of the complete Draft GMP/WS/EIS to state 

congressional offices, Native Hawaiians individuals 

and organizations, governmental agencies, and 

FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS PUBLIC REVIEW AND COMMENTS | 1 
other interested organizations and individuals. The 

NPS also produced and mailed the Draft GMP/WS/ 

EIS Executive Summary Newsletter #4 to over 800 

contacts on the park’s mailing list. The newsletter 

fully outlined the three alternatives in the plan 

and encouraged the public to participate in the 

planning process. 

The NPS held a talk story session and formal 

wilderness hearing on June 10, 2015 at the Kīlauea 

Visitor Center to share information, answer 

questions, and take public comment. Approximately 

20 people participated in these meetings and 

provided oral comments. The talk story session 

was structured as an open house, with information 

available on posters and via shared documents, 

and NPS staff were onsite to write down comments 

directly from attendees. A NPS facilitator and 

independent court reporter led the wilderness 

hearing in the auditorium of the visitor center during 

the talk story session where they answered questions 

about wilderness protection and management and 

took formal comments regarding the Wilderness 

Study within the Draft GMP/WS/EIS. This talk story 

session and wilderness hearing was announced via 

the newsletter, the project website, social media, and 

a separate press release that was distributed to media 

on June 5, 2015. 

Throughout the public review period, the public 

had opportunities to provide comments through 

attending the talk story session and wilderness 

hearing, submitting comments on the project website 

in PEPC, writing a letter or e-mail, or providing 

comments on the postage paid comment form 

enclosed in the newsletter. Contact information for 

the public to either request more planning materials 

and/or comment on the draft plan was printed in the 

newsletter and available on the web. 

Range of Public Comments 

During the public review period, the NPS received 

32 responses in the form of letters, comment cards, 

phone calls, and comments submitted on the NPS 

Planning, Environment, and Public Comment 

(PEPC) website. Of the comments received, two 

were from businesses, two were from non-profit 

conservation organizations, and one was from 

another federal agency. The EPA also provided 

comments on the Draft EIS, rating the proposed 

project as Lack of Objections (LO), and requested 

that additional information be included in the Final 

EIS. No form letters were submitted. 

The comments on the Draft GMP/WS/EIS covered a 

broad range of topics, issues, and recommendations 

for Hawai‘i Volcanoes National Park. The comments 

were entered into the NPS Planning Environment 

and Public Comment database and analyzed. 

The public provided comments on the following 

topics which are further elaborated on in the next 

section, “Comments and Responses Summary”: 

• Alternatives 

• Kahuku 

• ‘Āinahou 

• Facilities and Access 

• Trails 

• Bikes 

• Equestrian Use 

• Visitor Experience 

• Cultural Resources 

• Natural Resources 

• Climate Change 

• Wilderness 

• Boundaries 

• Partners 

• Commercial Services 

• Air Tours 

• Planning Process 

List of Commenters 

The following is a list of agencies, businesses, and 

interest groups and organizations that provided 

comments on the draft plan. These comment 

letters are included in this document in Appendix 

A. Copies of all letters are available in electronic 

format upon request, with individual names and 

addresses removed. 

• Kīlauea EcoGuides 

• Digital Tours – Hawaii, LLC 

• Ka Ahahui O Ka Nahelehele 

• Sierra Club 

• Ala Kahakai National Historic Trail 

Again, the EPA provided comments on the Draft 

EIS, rating the proposed project as LO, and 

requested that additional information be included in 

the Final EIS (letter dated July 2, 2015). This letter is 

also included in Appendix A. 

2 | PUBLIC REVIEW AND COMMENTS FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS 
COMMENTS AND 

RESPONSES SUMMARY 

Public comments allow the planning team, NPS 

decision-makers, and other interested parties to 

review and assess the views of other agencies, 

organizations, and individuals related to the 

preferred alternative, the other alternatives, and 

potential impacts. 

All written comments were considered during 

the preparation of this Abbreviated Final GMP/ 

WS/EIS in accordance with the requirements of 

Council on Environmental Quality’s regulations for 

implementing the National Environmental Policy 

Act (40 CFR 1503). 

It is important to stress that the identification of the 

preferred alternative and revisions to the alternative 

are not based on how many people supported a 

particular alternative. 

Analysis of Substantive Comments 

on the Draft Plan 

Consistent with the requirements of 40 CFR 1503, 

the NPS staff has provided written responses to 

those pieces of correspondence that have either 

substantive comments or comments that the NPS 

planning team determined required a written 

response for clarification. 

Substantive comments are defined by Director’s 

Order 12, “Conservation Planning, Environmental 

Impact Analysis and Decision-Making” (NPS, 2001) 

as those comments that: 

• Question, with reasonable basis, the accuracy
 

of information in the environmental
 

impact statement.
 

• Question, with reasonable basis, the adequacy of 

the environmental analysis. 

• Present reasonable alternatives other than those 

presented in the environmental impact statement. 

• Cause changes or revisions in the proposal. 

Substantive comments raise, debate, or question 

a point of fact or policy. Comments in favor of or 

against the preferred alternative or alternatives, or 

those that only agree or disagree with NPS policy are 

not considered substantive. Comments that contain 

substantive points regarding information in the Draft 

GMP/WS/EIS or comments that need clarification 

are extracted below. 

NPS Responses to All Commenters 

A concern statement has been developed to 

summarize the comments recieved on the Draft 

GMP/WS/EIS below, but representative quotes are 

also included from original letters, edited only for 

style consistency and spelling. All comment letters 

from agencies, organizations, and businesses have 

been scanned and are included in Appendix A. 

Where appropriate, text in the Draft GMP/WS/EIS 

has been revised to address comments and changes 

(as indicated in the following responses) in an errata 

included within this document. Unless otherwise 

noted, all page number citations refer to the Hawai‘i 

Volcanoes National Park Draft General Management 

Plan / Wilderness Study / Environmental Impact 

Statement (May 2015). 

ALTERNATIVES (25 COMMENTS) 

Concern 1: 

The alternatives are not significantly different. 

NPS Response: 

See page 171 in the GMP for an explanation of how 

alternatives were combined and revised in response 

to comments on the preliminary alternatives 

(under “Alternatives B and C”). Based on these 

public comments, the two action alternatives have 

similar guidance for managing natural and cultural 

resources in the park, but they differ significantly 

on proposed developments within the park for 

managing visitor use and enhancing the visitor 

experience. For example, Alternative 3 would 

maintain the closure along Crater Rim Drive and use 

shuttles as the primary methods for transportation 

and managing congestion whereas Alternative 2 

would reopen Crater Rim Drive to two way traffic 

assuming eruptive activity ceases or changes in 

Halema‘uma‘u Crater and the park determines 

through active monitoring that air quality and 

other hazards are at a level that is consistent with 

general visitor use. Recreational opportunities in 

Kahuku would also be more primitive and limited 

than in Alternative 2. In addition, Alternative 

3 would prohibit commercial use in Kahuku 

whereas Alternative 2 would allow for this use. 

Alternative 3 also focuses more on guided-only 

access in key areas. 

FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS PUBLIC REVIEW AND COMMENTS | 3 
Concern 2: 

The preferred alternative needs to include more 

science, learning opportunities, restoration and 

public involvement. 

Representative Comment: 

• “In general, the improvements listed in Alt 2
 

sound fine. The final plan needs to incorporate 


more of the science, learning opportunities, 


restoration and public involvement listed in Alt 


3. This is important to help engage the public 

with the park, and to meet the park’s mandate to 

maintain and restore the natural environment.” 

NPS Response: 

We agree that public involvement in science, 

restoration, and other stewardship activities within 

the park are “important to help engage the public 

with the park, and to meet the park’s mandate to 

maintain and restore the natural environment”. 

That is why the preferred alternative states that, 

“Stewardship and hands-on activities would be a 

key element in these programs engaging visitors 

in research, learning, science, restoration, and 

educational programs and facilities. In addition, 

park staff would engage visitors in research and 

citizen science (page 143)”. While these activities are 

the primary focus of any new visitor opportunities 

within Alternative 3, these important elements are 

still incorporated within the preferred alternative. 

Concern 3: 

The preferred alternative needs to include reference 

to the Ala Kahakai National Historic Trail in 

compliance with Public Law 106-509. 

Representative Comment: 

• “[I]nclusion of [Ala Kahakai NHT] in the
 

Preferred Alternative is actually mandated by
 

Public Law 106-509 which established the
 

ALKA corridor within all NPS units on Hawai‘i
 

Island. As such it needs to be included in
 

all Alternatives.”
 

NPS Response: 

While Alternative 1 is the only alternative that 

specifically references Ala Kahakai National 

Historic Trail (page 113), the referenced language 

in Alternative 1 is actually a duplicate of language 

that is incorporated within Actions Common to All 

Alternatives in the GMP (page 98), which states: 

“The park would continue to work with Ala Kahakai 

National Historic Trail staff to sign and interpret 

those trail segments through the park.” Therefore 

this action is already incorporated within all 

alternatives in the GMP, including the preferred. 

KAHUKU (17 COMMENTS) 

Concern 4: 

Develop an orientation/interpretive strategy for 

Kahuku to define and site various media to interpret 

Mauna Loa history, native species and forest 

conservation, history of cattle ranching, and Native 

Hawaiian presence in this area. 

Representative Comment: 

• “Ensure the interpretive programs at Kahuku 

continue and are expanded, and incorporate third 

bullet point [references a specific poster at the 

talk story session] under Kahuku in alternative 1.” 

NPS Response: 

On page 143 of the GMP, the preferred alternative 

states that the park “would develop a comprehensive 

interpretive plan that would expand interpretive 

opportunities to introduce visitors to all of the 

park’s interpretive themes through the use of 

interpretive standards and methods. Kahuku would 

also be integrated into the park’s comprehensive 

interpretive plan, and key stories...would be 

featured in this unit.” 

As of December 2015, the park is finalizing the 

Comprehensive Interpretive Plan that is called for 

within the GMP (page 142). This plan will inform the 

interpretive themes and programs in all areas of the 

park, including Kahuku. 

Concern 5: 

Consider fire prevention and hazardous fuels 

management at Kahuku. 

Representative Comment: 

• “With the increased public use in Lower Kahuku, 

increased fire suppression capability was 

identified. However, prevention and hazardous 

fuels management (e.g. fuel break) in the interface 

area is critical to reducing the likelihood of these 

fires entering the newly designated wilderness 

area with human-caused fires.” 

4 | PUBLIC REVIEW AND COMMENTS FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS 
NPS Response: 

The park has already identified specific pasture 

roads to be maintained as fuel breaks in the lower 

Kahuku area, as well as along boundary between 

upper and lower Kahuku. The park will continue 

to maintain fuel breaks and consider other fuel 

management reduction projects to protect key 

resources. Under the park’s Fire Management Plan 

(see page 36), the current strategy in the Kahuku 

Unit is to suppress all fires. Because this guidance 

already exists and is incorporated within the GMP 

by reference to the Fire Management Plan, no 

additional changes are needed in the GMP to ensure 

this protection occurs. 

Concern 6: 

Please specify restoration goals and objectives 

for Kahuku and propose specific uses for the 

lower pastures. 

Representative Comment: 

•	 “[I would] like to see specific goals, objectives for 

restoration of Kahuku pastures and propose uses 

of lower, historic pastures.” 

NPS Response: 

The park has been developing a Kahuku Restoration 

Plan and Environmental Assessment (see pages 38­

39). This plan will include specifics on restoration 

strategies for the former pastures at the Kahuku 

Unit. The Site Plan for lower Kahuku, which is called 

out as a needed next step in the GMP, will provide 

the specific types of visitor-related development 

and uses. Both of these future documents will guide 

restoration and use of the lower Kahuku Unit. 

Concern 7: 

Consider implementing improvements for the 

entrance to Kahuku, camping in lower Kahuku, 

road access, and backcountry facilities (trails, 

water catchment, and shelters) in upper Kahuku. 

Also consider allowing commercial guided use 

in lower Kahuku. 

Representative Comments: 

•	 “Campgrounds in lower Kahuku are in demand.” 

•	 “Consider adding shelters and catchment 


in Upper Kahuku away from road to 


support hikers.”
 

•	 “It would be nice to develop some wilderness 

trails in upper Kahuku that would access some of 

the ancient Hawaiian trails there.” 

NPS Response: 

These suggestions are already incorporated within 

the preferred alternative in the Draft GMP/WS/ 

EIS as either direct actions or actions that could be 

considered during future implementation of the 

preferred alternative (see pages 130-135). 

Concern 8: 

Protect the cabins in upper Kahuku and prohibit 

camping near these cabins for a number of 

resource concerns. 

Representative Comment: 

•	 “Any development of camping in NE Kahuku 

needs to be kept miles away from the Nēnē Cabin. 

Nēnē frequent this area all year and if our goal is 

to keep Nēnē from being habituated to humans, 

we need to limit the interactions in this area.” 

NPS Response: 

We agree with your concerns about impacts to nēnē 

and other resources by allowing camping too close 

to the cabins in upper Kahuku. That is why, on page 

135, the preferred alternative includes consideration 

for “developing a small campground in the proximity 

of the existing cabins and out of nēnē habitat outside 

of wilderness for walk-in users”. This language is 

intended to identify the general vicinity of camping 

within upper Kahuku, but ensures camping would 

not be too close to the cabins in order to avoid 

potential impacts to resources near the cabins. 

Concern 9: 

Extend 4-wheel drive access to Upper Kahuku. 

Representative Comment: 

•	 “I would like to see access to the cabins at 


Kahuku available by 4-wheel drive.”
 

NPS Response: 

Vehicular access has been intentionally limited in 

upper Kahuku due to potential impacts from the 

spread of invasive species and out of consideration 

for potential wilderness designation in the future. 

Several invasive species are not found in upper 

Kahuku and limiting method of access keeps the 

risk of introductions low. Similarly, as part of 

completing the Wilderness Eligibility assessment, 

the NPS determined that once restoration has 

been completed, the areas of the upper Kahuku 

Unit that are currently excluded from wilderness 

eligibility could be considered again. If the NPS were 

FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS PUBLIC REVIEW AND COMMENTS | 5 
to allow public vehicle use of the roads, it would 

make consideration for wilderness eligibility more 

challenging in the future. 

‘ĀINAHOU (10 COMMENTS) 

Concern 10: 

Restricting access to the grounds adversely effects 

the visitor experience and is inconsistent with 

management in other areas of the park. Please keep 

public access open to ‘Āinahou. 

Representative Comment: 

•	 “I request a MODIFIED VERSION of Alternative 

2...‘Āinahou ranch road and grounds should 

remain open to public access. Restricting access 

to the grounds is impairing the enjoyment for 

future generations....It is understandable to close 

the grounds periodically due to maintenance 

or Nene nesting, however to restrict public 

access entirely when generations of families have 

enjoyed this area is altogether unacceptable. 

Modify the statement to continue to allow public 

access to ‘Āinahou ranch and gardens.” 

NPS Response: 

The ‘Āinahou Ranch was acquired under the 

authority of the Endangered Species Conservation 

Act of 1969 (see page 128) specifically for the 

purpose of protecting, restoring, and propagating 

endangered bird species. The ‘Āinahou Ranch 

and Grounds are not open to the public due to 

safety and resource protection concerns (as per 

Superintendent’s Compendium 2015). This closure 

has been in effect for at least the past ten years. 

Currently, access to the area is limited to actions 

that support park objectives of cultural and natural 

resource protection. The ‘Āinahou Road itself is 

open most of the year, but is closed intermittently 

due to fire risk or resource protection. This is not 

changing within the Preferred Alternative. 

Nēnē are found in many locations in the park 

and the park implements temporary closures as 

necessary to protect breeding birds. Other areas 

where the birds are found may not experience 

closures if it is not warranted. 

Concern 11: 

Please consider alternatives to closing general public 

access to ‘Āinahou. 

Representative Comments: 

•	 “There are better ways to manage this area 


than 100% closure.”
 

•	 “[R]equire people to register with the 

backcountry office on the day of travel and check 

out again at the office same day. Take a copy of 

the boot print for added security as Sequoia and 

Kings Canyon National Park does with their 

backcountry hikers.” 

NPS Response: 

The preferred alternative does not propose 

100% closure of ‘Āinahou. Rather, tours, that 

were started on a pilot basis in 2014 but cut short 

due to hazardous trees and two tropical storms, 

may be conducted in future years following 

specific guidance developed by the park for 

natural and cultural resource protection. Other 

methods to monitor or control access may be 

considered in the future. 

Concern 12: 

Use ‘Āinahou for propagating native, midelevation plants. 

NPS Response: 

The use of ‘Āinahou for propagation of native plants 

is an operational issue and is too detailed for the 

Draft GMP/WS/EIS. If the park determines that 

propagation at this location is operationally feasible, 

it will be done utilizing the existing disturbed area 

and following Standard Operating Procedures 

to prevent the introduction of invasive plants, 

animals, fungus, etc. 

FACILITIES AND TRANSPORTATION (36
 

COMMENTS)
 

Concern 13:
 

Expand the visitor center, but do not move the 

bathroom near Kīlauea Visitor Center as proposed 

in the preferred alternative due to cost, potential 

impacts to resources, and accessibility. 

Representative Comments: 

•	 “The Visitor Center has outgrown itself and 


needs to be expanded.” 


•	 “Instead of new bathroom, expand visitor 

services (interpretation, exhibit areas, etc.) to 

area between Kīlauea Visitor Center and Volcano 

Art Center to reduce impact (plumbing is more 

disturbance and expensive).” 

6 | PUBLIC REVIEW AND COMMENTS FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS 
•	 “The plan to move the restroom in order to make 

more room for interpretation makes no sense. 

The current restroom location is best for all 

especially for anyone who can only walk a short 

distance or needs a restroom right away.” 

NPS Response: 

During the planning process for the GMP, the 

park identified the need to improve/increase 

interpretative space at Kīlauea Visitor Center. In 

identifying and reviewing alternatives for improving 

this facility, the park dismissed the alternative to 

expand the building itself due to associated costs 

and impacts to the cultural integrity of the structure 

(see page 174 in the GMP for further discussion) 

and instead has recommended the expansion of 

the exterior interpretive space on the lanai. While 

the draft GMP states that the park would do so 

by relocating the restrooms and freeing up more 

interpretive space on the lanai, these comments 

raise concerns about the cost and impacts of this 

alternative. While valid concerns, the park believes 

more analysis is needed to assess how these costs 

and impacts would compare to the benefits of 

relocating the restrooms (ex: decreased noise 

in the lanai area) and how they would compare 

with the alternative to expand the lanai around 

the restrooms. In other words, the NPS remains 

committed to increasing the exterior interpretive 

space at Kīlauea Visitor Center and is not ready 

to dismiss this alternative from further analysis. 

Rather, the park would complete this additional 

analysis through the completion of a site plan for 

the complex of buildings on the summit of Kīlauea, 

as called for in the GMP. The language in the GMP 

has been updated through the errata to clarify that 

the park would improve exterior interpretive space 

at the visitor center through the completion of the 

recommended site plan. This site plan would assess 

the benefits and impacts of the various alternatives 

for doing so, including the potential relocation of the 

restrooms. See the “Errata,” “Page 121” for the final 

wording on this action within the GMP. 

Concern 14: 

Bathrooms need to be improved or expanded and 

more sitting areas and picnic tables are needed at a 

number of locations within the park. 

Representative Comments: 

•	 “Add a restroom at Kīlauea Iki.” 

•	 “More restrooms at Mauna Loa parking lot.” 

•	 “More picnic tables are needed throughout the 

park. With over a million visitors a year, many 

want to picnic but the lack of tables is not helping 

any, especially near the Visitor Center area. The 

current designated Kīlauea [Overlook] Picnic 

area has only 2 or 3 tables, set way back from the 

view of the caldera, that’s it.” 

NPS Response: 

Additional or new restroom facilities and picnic 

areas is an operational issue and is too detailed of 

information for the Draft GMP/WS/EIS. The park 

will consider these comments during future site 

specific planning (see pages 124-126, 128). 

Concern 15: 

Parking is a major issue in the park. Parking 

lots need to be expanded and a shuttle system 

must be adopted. 

Representative Comments: 

•	 “The current Jaggar parking lot has outgrown 

itself, especially with the current lava fountaining 

activity. Vehicles waiting in long lines to get a 

parking stall are constantly polluting the air 

with exhausts fumes. The dirt area opposite 

the parking lot (Mauna Loa side of the parking 

area) should be made into a parking lot to 

accommodate more vehicles.” 

•	 “Parking is the most critical problem. You must 


adopt a shuttle system.”
 

NPS Response: 

The planning team identified these issues and 

concerns early in the planning process. As a result, 

the GMP includes recommendations to improve 

transportation, parking, and access within the 

park, particularly at Nahuku. For example, through 

implementing the preferred alternative in the 

GMP, the park would 1) continue to evaluate the 

effectiveness of reducing congestion through a 

pilot hydrogen shuttle project that would run along 

Crater Rim Drive (page 123); 2) implement a suite 

of tools to address congestion around Thurston 

Lava tube (such as improved visitor information, 

increased ranger presence, and potential vehicle 

size limitations for parking, time of day restrictions, 

and/or reservations for commercial vehicles only); 

and 3) reconfigure parking lots near Thurston with 

enhanced trail access between lots (page 125). 

FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS PUBLIC REVIEW AND COMMENTS | 7 
Concern 16: 

Large commercial buses are a safety hazard on the 

roads. The size of these buses needs to be limited. 

Representative Comment: 

•	 “Need to seriously limit the size of the tour buses 

that use the roads. I visit 2 times a month from 

Oahu and every time I almost always have close 

calls with the buses because the road is narrow 

and they use the whole road around the curves. I 

always cringe every time I take a blind corner.” 

NPS Response: 

The preferred alternative in the GMP calls for 

implementing a pilot program that would limit 

large commercial buses or vehicles over 98 inches 

in width and/or over 38 feet in length to one-way 

traffic between Jaggar Museum and Chain of Craters 

Road junction along the southwest portion of 

Crater Rim Drive (page 123), if the closed portion of 

Crater Rim Drive is reopened. This would preserve 

the historic character and alignment of the road 

while addressing some of the safety concerns with 

having large vehicles go around tight bends on 

this narrow road. 

Tour buses are an important mode of travel for many 

of the park’s visitors and can reduce vehicular and 

parking congestion within the park. Approximately 

20% of the park’s visitors arrive on a bus or similar 

tour (see page 269). The park currently conducts 

Commercial Use Authorization (CUA) Operator 

training that all CUAs are required to attend. This 

training includes safety as well as information on 

the park’s natural and cultural resources. The park 

will continue to outreach to the CUAs utilizing the 

training and other methods to ensure safe driving 

practices are adhered to within the park. 

Concern 17: 

Infrastructure improvements are badly needed at 

Hawai‘i Volcanoes National Park. 

Representative Comment: 

•	 “What should be included in the GMP are badly 

needed infrastructure improvements.” 

NPS Response: 

The NPS approved an increase in the park’s 

entrance fee (incremental increase from 2015­

2017) which will provide some additional funds 

for improving visitor-related infrastructure. In 

addition, the park continues to submit requests 

for project funds to address deferred maintenance 

throughout the park. The park recognizes the 

need for infrastructure improvements and with the 

actions proposed in the GMP, the park’s deferred 

maintenance will be reduced by $22 million. Recent 

projects have addressed some of the deferred 

maintenance in the park, such as the rehabilitation 

of Crater Rim Drive, resurfacing Chain of Craters 

Road and Mauna Loa Road, construction of the 

Visitor and Emergency Operations Center, and 

rehabilitation of Volcano House, just to name a few. 

Concern 18: 

Accessibility improvements are badly needed at the 

Petroglyphs and Thurston Lava Tube, some of the 

most popular destinations in the park. 

Representative Comment: 

•	 “Two of the many ‘must sees’ in the park are the 

petroglyphs and the very popular Thurston Lava 

Tube. Like the petroglyphs, the lava tube is not at 

all wheelchair friendly either. Two main features 

that limited mobility folks are missing out on.” 

NPS Response: 

The park currently has plans to improve accessibility 

at several sites in the park and continues to evaluate 

other locations that may need accessibility upgrades. 

However, due to natural and cultural resource 

concerns, not all sites within the park can be made 

accessible. The impacts that would be required to 

make some sites accessible would significantly affect 

cultural, viewshed, and natural resources, the very 

reasons the sites are important. In order to meet the 

intent of the law, where locations cannot be made 

physically accessible, alternative experiences, such 

as off-site interpretation, will be provided for visitors 

that cannot personally visit the site. 

TRAILS (27 COMMENTS) 

Concern 19: 

The park should consider restoring and/or 

constructing several historic trails to connect with 

surrounding lands. 

Representative Comments: 

•	 “NPS participates in preserving and providing 


connecting old and newer trails all over the US, 


and it is a big disappointment in this draft plan 


that no mention is made of these old trails and 


preserving them for public use.”
 

8 | PUBLIC REVIEW AND COMMENTS FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS 
• “Loss of access to historic and prehistoric trail
 

routes that cross HAVO land. When HAVO was
 

established, these trails were in use”
 

• “It would be nice to develop a trail which links 

Kakuku to MLO Strip Road (potentially in 

coordination with DLNR land)....I would love to 

see a few backcountry campgrounds and possibly 

a trail that would allow an avid backpacker to 

hike and camp from Kahuku to MLO striproad, 

to Ka‘ū, to Puna Coast.” 

NPS Response: 

The GMP identifies the need for completing a 

trail management plan for the entire park (see 

page 142) and articulates that development of new 

trail alignments would primarily be along historic 

alignments and traditional routes, in addition to 

along existing roads (such as at the Kahuku Unit). 

The trail management plan could consider some 

of the suggestions made through the comments 

received that relate to this topic. 

Concern 20: 

Trails need to be well maintained and some 

improvements made to address visitor safety. 

Representative Comments: 

• “Trails with tall grass are safety and fire hazards.” 

• “HAVO should increase maintenance of cabins 

in the park and of trail markings overall where 

they have become ambiguous. This can be a safety 

issue in several areas.” 

• “Improve signage at Nahuku and Kīlauea Iki.
 

There is no signage for the trail to Nahuku from
 

Kīlauea Iki. Many people think walking on the
 

roadway is the only way to get there and that is
 

very hazardous.”
 

NPS Response: 

The park recognizes there is a concern with 

pedestrians walking along the road and is currently 

developing improved signage in the Kīlauea Iki 

to Thurston Lava Tube area. Improvements to 

provide better visitor experience along Mauna 

Loa Road are recommended in the GMP (see 

pages 128-129), including considering additional 

turnouts and signage. 

Trail maintenance is an operational issue and is too 

detailed of information for the Draft GMP/WS/ 

EIS. The NPS approved an increase in the park’s 

entrance fee (incremental increase from 2015­

2017) which will provide some additional funds 

for improving visitor-related facilities, including 

trails. The park has a large amount of deferred 

maintenance (approximately $22 million of which 

would be addressed by actions proposed in the 

GMP, see page 148) due to lack of adequate funding 

over many years. The park continues to submit 

requests for project funds to address deferred 

maintenance throughout the park. The park will 

consider these comments as deferred maintenance 

projects are planned and implemented. 

Concern 21: 

The emergency road at the end of Chain of Craters 

Road should be used as a trail. 

Representative Comment: 

• “Emergency road will make a great trail someday.” 

NPS Response: 

All action alternatives in the GMP include the 

possibility of using the emergency access route at 

the end of Chain of Craters Road as a trail. Due 

to commitments made by the NPS during the 

construction of this road (County of Hawai‘i funded 

the construction of this route with the anticipation 

of being reimbursed by FEMA; FEMA includes 

specific mandates in their funding), the NPS is 

responsible for ensuring that the route is protected 

and maintained as an emergency access route 

regardless of temporary uses like trail access. This 

language has been clarified in the GMP in a number 

of locations through the errata included within 

this document. 

BICYCLES (9 COMMENTS) 

Concern 22: 

More bike routes need to be built within the park 

to enhance public recreation, reduce congestion on 

roads, and reduce our carbon footprint. 

Representative Comments: 

• “There needs to be more focus on bicycle
 

trail development as an alternative form of
 

transportation and public recreation.”
 

• “At Kahuku a lot of bicycle trail development can 

be done. Bicycle access to the forested pit crater 

would be just a start. There are miles of ranch 

roads in the Paddocks that would be great for 

bicycle access rather than having to hike.” 

FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS PUBLIC REVIEW AND COMMENTS | 9 
NPS Response: 

The preferred alternative in the GMP calls for 

additional bike access both along Chain of Craters 

Road and within Kahuku. Specifically, on page 123, 

the preferred alternative calls for improving signage 

along the road corridor, providing adjacent bicycle 

trails when feasible, and considering vehicular traffic 

closures during specific times of day or days of the 

week to encourage bicycle use on some park roads. 

On page 132, the plan also calls for the development 

of a “trail network in lower Kahuku that would 

accommodate different visitor abilities across a 

series of loop trails and trail connections in an 

effort to promote hiking, bicycling, and equestrian 

use.” In addition to these specific improvements, 

the GMP identifies the need for completing a 

trail management plan for the entire park that 

could include recommendations for some of the 

suggestions made through the above comments. 

Concern 23: 

Please add a single track mountain bike 

trail in the park. 

Representative Comment: 

•	 “I would absolutely love to see single track Mt 

biking in specific areas of HVNP...specifically 

in and around the Bird Park area between Tree 

Molds and the Day use area and out behind the 

camp ground. Here in on the Big Island we have 

ONLY ONE worthy single track trail system to 

ride on.... [W]e are responsible and we take care 

of the area in which we ride. You have no idea 

how much I love HVNP and this would truly 

enhance my park experience!!!” 

NPS Response: 

The park considered adding a single track mountain 

bike trail in Kahuku but dismissed this from 

further consideration due to the miles of existing 

unimproved roads, impacts to resources, costs, and 

the challenges of managing this use. Please see page 

176 in the GMP for further discussion. 

The GMP recommends development of a park-wide 

trail management plan. This planning process will 

include an evaluation of locations in the park where 

new trails or trail uses may be warranted (pages 

142). Comments received, such as those above, 

can be considered during the development of the 

trail management plan, as well as public comments 

received during the planning process. 

EQUESTRIAN USE (2 COMMENTS) 

Concern 24: 

Allow equestrian use in Upper Kahuku. 

Representative Comments: 

•	 “[T]he fact that you are not necessarily restricting 

horseback riding in the upper areas is important, 

I think. Because it was a ranch, the history of 

it certainly included horses, and some sort of 

equestrian something is, I think, in keeping with 

the whole spirit of what’s happened at Kahuku.” 

•	 “[W]e would really like to see that [horseback 


riding is] available in the wilderness area as well 


as the lower elevations.”
 

NPS Response: 

Under the preferred alternative, “the park would 

implement a small pilot program for equestrian use 

in lower Kahuku pastures” but dismissed providing 

full, unrestricted equestrian access to Kahuku due 

to anticipated impacts to natural resources in this 

unit (page 134). Please see page 176 in the GMP 

for further discussion on equestrian use in upper 

Kahuku and unrestricted equestrian use in this 

area of the park. 

VISITOR EXPERIENCE (11 COMMENTS) 

Concern 25: 

Technology can be used more effectively to 

provide visitors with park information and inspire 

them to become more connected to the park 

and its resources. 

Representative Comments: 

•	 “The current wired display listening devices 

located at each display are outdated, dirty from 

hand and ear contact, rarely used and are just 

playthings for children. Do away with these 

devices and in its place, a cellphone app that will 

connect visitors with recordings of each display.” 

•	 “I propose that HVNP consider the pairing 

of mobile technology with an audio narrated 

experience to be the way in which we can elevate 

and enhance the overall experience of visitors to 

the park, especially as they drive.” 

NPS Response: 

The NPS recently developed a strategy and action 

plan for achieving relevancy through interpretation, 

education, and volunteers as the agency moves 

into its second century. This strategy and plan call 

for the use of emerging technologies to encourage 

10 | PUBLIC REVIEW AND COMMENTS FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS 
self-directed learning and reach new audiences, 

which the GMP further reinforced. The preferred 

alternative in the GMP call for utilizing “new 

media and tools to provide inquiry-based learning 

through frontcountry self-guided interpretive 

and educational opportunities in order to meet 

the diverse needs of an increasingly international 

audience” (page 143). 

CULTURAL RESOURCES (8 COMMENTS) 

Concern 26: 

Hawai‘i Volcanoes National Park belongs not to the 

federal government but to Native Hawaiians and the 

continued management of this land by the National 

Park Service is illegal. 

Representative Comments: 

•	 “‘Be it ordained and enacted by the Legislature 


of Hawai‘i: That the government de jure of
 

the Hawaiian Kingdom possess the authority
 

to reclaim any and all land within its 


territorial boundaries.’”
 

•	 “[This land was] ‘illegally conveyed to the 

United States from the government de facto 

of the insurrectionists...’ Law 103-150, Sta. 

1510, acknowledging and confessing to illegally 

overthrowing the Kingdom of Hawai‘i, violating 

international law, and unlawfully accepting 

those national lands which are owned by the 

inherent sovereignty of Hawai‘i...[is] still in 

effect in America.” 

NPS Response: 

This assertion is at odds with the federal laws, 

policies, and guidelines under which the National 

Park Service and Hawai‘i Volcanoes National Park 

operate, including the Organic Act of 1916 and the 

Hawaii National Park Act of August 1, 1916 -- which 

together give authority to the National Park Service 

to manage the lands designated as Hawai‘i Volcanoes 

National Park. This comment is therefore outside the 

scope of a GMP to address. 

NATURAL RESOURCES (12 COMMENTS) 

Concern 27: 

The GMP should consider impacts to pollinators 

from the proposed actions. Therefore, please include 

a list of herbicides that would be used in the park 

and specify best management practices for the 

application of these herbicides. 

Representative Comments: 

•	 “On June 20, 2014, President Obama issued a 

memorandum directing Federal departments 

and agencies to evaluate and use their resources, 

facilities, and land management responsibilities 

to expand knowledge of pollinator health 

and to increase habitat quality and availability. 

While the DEIS acknowledges the importance 

of native pollinators to specific plant species, it 

is unclear what potential adverse impacts may 

occur to pollinators from proposed herbicide/ 

pesticide use associated with the initial action.... 

We recommend the NPS include, where 

appropriate in the FEIS,...best management 

practices to support pollinator health and 

affected ecosystems.” 

•	 “The project proposes to treat invasive plants 

with herbicide (page: 169). We recommend that 

the FEIS clearly identify which herbicide or 

pesticide products, if any, would be approved for 

use and in which areas. We recommend that the 

NPS include a commitment in the FEIS to adhere 

to pesticide label directions for any pesticide 

or herbicide application. We also recommend 

that the FEIS specify appropriate buffer zones 

to protect water quality from any pesticide/ 

herbicide applications. We recommend that the 

FEIS describe how pesticide mixing and storage 

areas would be sited and managed to further 

protect water sources and other sensitive areas, 

such as food source and/or herb gathering areas.” 

NPS Response: 

The General Management Plan is a long-term 

planning document for the park and does 

not, as such, include the detailed analysis and 

information requested. 

The park is committed to ecosystem restoration 

and protection, which benefits insect and bird 

pollinators and their habitats. Specific projects 

undergo project-level compliance to ensure 

mitigation measures are included to protect natural 

and cultural resources. The park also works with 

outside researchers to identify risks to pollinators. 

Invasive species are a top threat to native ecosystems 

(including pollinators) worldwide, and particularly 

in Hawai‘i. Within the park, invasive species are 

treated with pesticide, where appropriate, using 

trained applicators. The park is committed to 

FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS PUBLIC REVIEW AND COMMENTS | 11 
consistent adherence with label and worker safety 

requirements. No restricted use herbicides are used 

to control invasive vegetation. The invasive plant 

control program does not treat invasive aquatic 

vegetation, and never applies herbicides near 

streams, standing water, or any location below the 

high tide mark. All herbicides and pesticides are 

stored in a secure facility in a developed sector of the 

park, away from visitors, and the majority of mixing 

occurs at this site. Any mixing in the field occurs in 

bins to guard against a spill. Detailed information on 

specific herbicides and pesticides and application of 

such is addressed by project-specific compliance. 

Concern 28: 

The GMP needs to explain the rationale for 

identifying specific indicators and standards for 

monitoring the acoustic environment at Hawai‘i 

Volcanoes National Park (reference to User Capacity 

(pages 162-164 and Appendix G)). 

Representative Comments: 

•	 “The NPS should state if it believes ANY air tours 

are appropriate use (including constructive use of 

soundscape, i.e., impact on natural quiet) in the 

wild/primitive zone.” 

•	 “The NPS should usefully offer further rationale 

as to WHY it set said standard at 1.0 dBA 

difference between natural and ambient dBA.... 

The rational might state if for any reason the 1.0 

dBA standard is Park-specific? Or would it be a 

reasonable standard appropriate to apply in other 

Parks with Wild/Primitive Zoning?” 

•	 “The NPS should explain whether/how current 

acoustical measurement technology is available to 

capture this 1.0 dBA difference accurately, reliably 

over time, and defensibly against challenge by 

such as motorized/commercial sources.” 

•	 “The NPS is invited to address how this 1.0 


dBA standard is to be applied. Is it a standard 


for ‘Desired Conditions’? Is it a standard 


for identifying ‘Unacceptable Impacts’ vs. 


‘Major Adverse’; or ‘Major Adverse’ vs. 


‘Moderate Adverse’.”
 

NPS Response: 

The indicators and standards for identifying 

carrying capacity (subject of these comments) in 

a GMP do not typically contain the level of detail 

requested by the comments above (see page 162 

for a full description of defining user capacity 

within Hawai‘i Volcanoes National Park). That 

said, the following information and responses 

should provide clarification on the indicator and 

standard (associated with soundscapes and the 

acoustic environment) identified for protecting the 

visitor experience within the wild/primitive zone 

developed in the GMP. 

Director’s Order 41, Wilderness Stewardship states 

that “Commercial air tours are inconsistent with 

preservation of wilderness character” (DO 41, 16). 

The GMP affirms this statement (although not all 

lands within the wild/primitive zone are designated 

wilderness in the preferred alternative, page 118) 

by clarifying that visitor activities within the wild/ 

primitive zone “are unstructured, self-guided, and 

human-powered...Activities do not degrade the 

integrity of resources or compromise wilderness 

values...Typical activities include hiking, camping, 

backpacking, equestrian, lava viewing, route 

finding, exploring, and cultural demonstrations, 

and include some stewardship programs consistent 

with wilderness values” (page 93). The GMP also 

establishes desired conditions and indicators and 

standards for the wild/primitive zone to ensure 

management action is taken before impacts from 

visitor use unacceptably impact natural and cultural 

resources and the visitor experience in these areas 

of the park. See also page 90 for a description of the 

desired conditions for soundscapes within the wild 

and primitive zone. 

Within the wild/primitive zone, the park 

has identified soundscapes and the acoustic 

environment, specifically the difference between 

existing and natural ambient sound levels, as an 

important indicator for measuring impacts to the 

visitor experience from overall visitor use in these 

areas of the park. The standard established for 

this zone is a minimum of 1 dBA mean difference 

between natural and existing ambient dBA (L50). 

This park-specific standard (1 dBA mean difference) 

was identified based on the lack of existing human 

caused noise sources (such as noise from road 

traffic or high altitude commercial jets) in the wild/ 

primitive zone in the park as documented in acoustic 

measurements taken at the park between 2002 and 

2013 (USDOT-FAA 2006, NPS 2008, NPS 2013c). 

During these measurement periods, the existing 

sound levels generally differed from the predicted 

natural sound level by less than 1.0 dBA during the 

12 | PUBLIC REVIEW AND COMMENTS FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS 
day; so by using 1.0 dBA in the primitive zone, the 

park would be preserving the existing condition. 

If this standard is met or exceeded, the park could 

implement the management actions identified on 

page 446 to minimize impacts and protect the visitor 

experience within this zone. 

This standard would be monitored through the 

development and implementation of a soundscape 

monitoring program (identified in the GMP on 

page 141) that would largely be based on previous 

acoustic monitoring in the park in 2002, 2003, 2008, 

and 2013 (page 243) and on the scientific methods 

and technology identified by the NPS Natural 

Sounds and Night Skies Division for acoustic 

monitoring within units of the national park system. 

While this division has developed soundscape 

modeling to inform planning processes across 

the country, the indicator and standard identified 

in this plan would be based on actual acoustic 

measurements in the field that would be consistently 

applied over time - in specific locations and at 

specific intervals established by the soundscape 

monitoring program and associated protocols. 

Again, this 1.0 dBA standard would serve as an 

indicator for taking management action to prevent 

further impacts, rather than defining the intensity of 

impacts, to the visitor experience. For example, the 

NPS could establish a long-term acoustic monitoring 

site at measurement site 8C (identified through 

monitoring in 2002 and 2003; page 245) where 

NPS staff would complete acoustic monitoring 

several times a year following protocols established 

under the soundscape monitoring program. Using 

the data collected from a sound level meter, staff 

would identify the mean difference between natural 

and ambient dBA (L50) within this zone for the 

monitoring period. If this mean is greater than 1 dBA 

-- which could be impacted by a number of factors 

such as development outside the park, visitor use, 

commercial air tours, or administrative flights, etc. -- 

the park would consider the following management 

actions depending on the source of the issue: 1) 

educate visitors about soundscapes in the park; 2) 

educate visitors about self-noise at night-time near 

eruptive areas; 3) enforce noise ordinances 36 CFR 

Section 2.12; 4) implement temporary or long-term 

standoffs for aircraft; 5) reduce noise caused by 

administrative activities; and 6) limit administrative 

use of aircraft in the area (see page 446). 

Concern 29: 

The GMP needs to explain the rationale for 

identifying specific indicators and standards for 

monitoring fire risk at Hawai‘i Volcanoes National 

Park (reference to User Capacity). 

Representative Comment: 

•	 “The number of human-caused fires reported 

is not a useful indicator for “fire risk” (page 

440). While this is a simple metric, the 

simple occurrence of a fire only indicates the 

effectiveness of the fire prevention program. 

More useful indicator(s) would tie together 

fire occurrence, fuel beds that are conducive to 

spread and/or resistant to control, fire indices 

at time of ignition, and proximity of ignition to 

at-risk resources (e.g. structures, invasive species, 

etc)....Since you are also concerned about natural 

ignitions, which account for approximately half of 

the fires in HAVO, I would advise against ignoring 

them when evaluating fire risk. Fires, regardless 

of cause, have similar effects. Given the concern 

about invasive species, and the greatly increased 

flammability of the Park over the past 100-years 

that has accompanied the spread of those species, 

every fire should be considered for some level 

of suppression.” 

NPS Response: 

Visitor use in the park, including additional public 

use at Kahuku over time, may result in more humancaused fires, which would trigger an action under 

Table G.1. Indicators, Standards, Management 

Strategies, and Monitoring Strategies. Fire risk in this 

table is specifically related to human-caused fires, 

not natural ignitions. This table is intended to guide 

park management when a threshold is triggered as 

described under the ‘Standard’ and is only related 

to impacts related to human use of the park (see 

also pages 162-163). This does not mean that these 

are the only things the park considers in its fire 

management program. The park’s Fire Management 

Plan (see page 36) took the various indicators of 

fire risk into account when developing the Fire 

Management Units and fire management strategies. 

At this time, all fires are closely monitored and 

receive a full suppression response to protect human 

life, property, and cultural resources, as well as 

limit the spread of invasive species and the loss of 

native plant communities. Limited exceptions are 

made for small isolated kīpukas where fire poses 

FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS PUBLIC REVIEW AND COMMENTS | 13 
no threat to park resources or human life and when 

the information gained from fire effects studies will 

benefit overall fire management in the park. The 

park evaluates the effectiveness of fuels treatment 

and restoration projects in determining if we are 

moving toward the park’s desired condition for 

fire management (page 57) and native vegetation 

(page 58). This evaluation may result in changes in 

management strategies over time. 

Concern 30: 

Mitigations need to be established to protect 

resources from the spread of invasive species within 

the park, especially as the preferred alternative 

would expand human use in Kahuku. 

Representative Comments: 

•	 “Also boot/shoe brushes for when visitors 

hike to areas like Mauna Ulu and Kilauea Iki. 

Supplemented by informational displays on why 

it is important to brush shoes before hiking into 

these areas. This could help with reducing the 

spread of invasives especially grasses.” 

•	 “The park needs to plan in advance for keeping 

ants and other invasive insects and plants out 

of pristine areas.... If these areas are going to be 

opened to the public, how will ants be kept out?” 

NPS Response: 

The locations of boot/shoe brush stations within the 

park is an operational issue and can be expanded as 

managers evaluate the need for additional locations. 

The park has Invasive Species Standard Operating 

Procedures which outline procedures necessary 

to reduce the risk of introducing invasive species. 

Other management tools can be used to reduce 

the risk of introductions. For example, under 

the preferred alternative, no vehicles, bicycles, 

or horses are allowed west of Upper Glover or 

above 1916 flows to the east to reduce risk of new 

introductions. Any new trails will undergo planning 

and compliance where mitigations and monitoring 

will be outlined in advance. In addition, the park 

currently monitors key invasive species and takes 

management actions when necessary. 

CLIMATE CHANGE (5 COMMENTS) 

Concern 31: 

Increase recycling opportunities for visitors. 

Representative Comment: 

•	 “This may not apply to this type of plan, but 

I’ve always thought that there should be more 

visible areas for recycling for visitors. I do not 

think that those few “Hi 5” recycling containers 

(which do not seem to be clearly marked) that are 

sometimes located adjacent to trash containers to 

be sufficient.” 

NPS Response: 

Any improvements made to solid waste collection 

within the park are primarily operational in nature 

and could be made at any time outside the purview 

of the GMP. That said, the GMP includes guidance 

for park managers to increase conservation and 

sustainability (page 145). 

BOUNDARIES (14 COMMENTS) 

Concern 32: 

The highest priority for acquisition is the 

Pōhue Bay Parcel. 

Representative Comment: 

•	 “Pōhue/Makai Kahuku between KS lands south 

east and Kawanakoa to northwest along coast 

below Hawn Ranchos = highest priority (higher 

than Great Crack).” 

NPS Response: 

The Pōhue Bay, Great Crack, and Ala Wai‘i Holdings 

parcels, which are all identified within the Analysis 

of Boundary Modification and Land Protection 

(Appendix E in the GMP), are part of a Land and 

Water Conservation Fund Collaborative Landscapes 

Proposal and are identified as priority acquisitions. 

PARTNERS (7 COMMENTS) 

Concern 33: 

More native Hawaiians need to become involved 

in the park in order to connect native Hawaiians 

with their culture and heritage and to improve the 

visitor experience. 

Representative Comments: 

•	 “More native Hawaiians need to become 

involved in the park. The park should work with 

the University of Hawai‘i and or Kamehameha 

Schools to make the park part of the curriculum 

for their studies and or degrees. A once a week 

hula show for an hour is not enough to connect 

native Hawaiians with their culture and heritage.” 

14 | PUBLIC REVIEW AND COMMENTS FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS 
• “Also, visitors want to experience the park with 

native Hawaiians, like how many of us would 

rather speak with Native Americans when visiting 

the Grand Canyon or Yellowstone.” 

NPS Response: 

Specific hiring processes and partnerships are 

operational and are not within the scope of a GMP. 

That said, the park currently (as of December 2015) 

employs several people of Native Hawaiian ancestry 

in various positions in the park. In addition, the 

park implements a number of proactive methods 

to involve more Native Hawaiians, cultural 

practitioners, and other local youth and adults 

in its operations. For example, the Kahuku Unit 

has a special hiring authority that allows them 

to hire directly from the local communities near 

Kahuku. The park partners with Friends of Hawai‘i 

Volcanoes National Park and Hawai‘i Pacific Parks 

Association to provide a summer internship program 

through the Youth Internship Ranger Program. In 

2015, this program provided 28 local high school 

and college youth with the opportunity to work for 

and learn about the park. The park provides many 

cultural programs throughout the month, in addition 

to the regular hula program. The park meets with 

the park’s Kupuna Consultation Group to discuss 

proposed projects and plans in the park and get 

their input and feedback. These are just some of the 

methods the park uses to involve Native Hawaiians, 

cultural practitioners, and other local community 

members in the protection and management of the 

park. The park will continue to investigate ways to 

further involve local community members. 

COMMERCIAL SERVICES (2 COMMENTS) 

Concern 34: 

Please do not allow any more commercial services or 

concessions within the park due to their impacts to 

Native Hawaiian cultural practitioners. 

Representative Comment: 

• “Impacts of visual disfigurement allowing 

commercial activities at the eternal home of 

Tutu Pele (aka Hawai‘i Volcanoes National Park) 

are disconcerting at best. More on par with 

exasperating, upholding the sacred religious 

practices of the Native Hawaiian people/Pele 

Practitioner’s. Religions around the world 

are not subject to commercialization. Why in 

Hawai‘i Nei? Please, no new commercial services 

or concessions!” 

NPS Response: 

The GMP includes a Commercial Services Strategy 

(Appendix F) that identifies criteria for evaluating 

whether or not a type of commercial service is 

appropriate and/or necessary within Hawai‘i 

Volcanoes National Park (see page 419 for a 

further explanation). According to this strategy, all 

commercial services within the park must: 

• be consistent with laws, regulations, and policies; 

• not compromise public health and safety; 

• not significantly impact or impair park
 

resources or values;
 

• not unduly conflict with other park uses
 

and activities;
 

• not exclude the public from participating in
 

similar recreational opportunities.
 

Therefore, the park can deny permits to any 

commercial services that do not meet these criteria. 

Although this strategy identifies commercial services 

that are not appropriate within the park due to 

potential impacts they have on park resources or 

public safety (see pages 421-422), this strategy does 

not identify a limit to the number of commercial 

services allowed in the park. Should limits be 

needed for things like ensuring visitor safety or 

resource protection, etc., the park could complete 

a commercial services plan, or similar analysis, 

that would rely on monitoring data within the park 

to help establish these limits. This commercial 

services plan, or another plan such as a wilderness 

stewardship plan, could also include a determination 

of extent necessary for providing commercial 

services in wilderness. 

AIR TOURS (9 COMMENTS) 

Concern 35: 

The alternatives should provide general guidance 

for noise and wilderness issues concerning 

park overflights. 

Representative Comments: 

• “The preferred alternative fails to provide the
 

general guidance that is needed for noise and
 

wilderness issues concerning park overflights.”
 

• “[T]he plans I submitted to reasonably and fairly 

deal with the air tour problem on November 

30, 2011 were completely ignored. This is a 

violation of NEPA requirements to consider all 

proposed alternatives.” 

FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS PUBLIC REVIEW AND COMMENTS | 15 
NPS Response: 

General management plans provide broad 

management guidance for a park, but often 

recommend the development of other plans to 

address more specific issues that would demand 

more extensive information and analysis, such 

as air tour management. For years, the park has 

recognized the need for and has worked towards 

completion of an Air Tour Management Plan 

(ATMP) (page 39). The GMP reinforces this need 

by also identifying and calling for the completion 

of an ATMP/EIS “that would develop measures to 

limit or prevent any significant impacts that may be 

caused by commercial air tour operations upon the 

natural and cultural resources, or visitor experiences 

at the park” (page 141). This plan is the appropriate 

venue for identifying and evaluating the alternatives 

suggested by this commenter, which are outside the 

scope of a typical GMP. 

That said, the GMP does provide general guidance 

on noise and wilderness issues that are impacted 

by park overflights and identifies several actions to 

protect the acoustic environment and wilderness as 

they relate to overflights, including: 1) implementing 

temporary or long-term standoffs for aircraft 

in sensitive areas; 2) providing commercial air 

tour operators with information and training 

on wilderness boundaries and the location of 

these sensitive areas; and 3) calling for acoustic 

monitoring, with associated indicators and standards 

for taking management action, and a possible 

soundscape management plan (page 141 and 446). 

Concern 36: 

The current number of air tours over Hawai‘i 


Volcanoes National Park are adversely impacting 


soundscapes, wilderness, neighboring communities, 


and environmental justice. The Draft GMP/
 

WS/EIS needs to assess impacts to these 


resources from this use.
 

Representative Comments: 

•	 “I do not believe that the importance of the 


acoustical environment has been adequately
 

discussed. I am especially dismayed that this 


document does not even mention the damage 


done to our island by air tour operations the 


park is profiting from. This failure to take the 


NEPA requirement of accepting responsibility
 

for auxiliary effects of park programs on the 


surrounding neighborhoods into consideration 

jeopardizes the validity of the entire plan.” 

•	 “I do not feel any of these alternatives adequately 

address the environmental impacts HVNP 

administrators’ policies and management 

practices are having on our park and the 

surrounding neighborhoods, either now or in the 

future.” [Related to impacts from Air Tours] 

•	 “The devastating effects of the park’s air tours 


and aviation operations are centered over 


the socially and economically disadvantaged 


population of the District of Puna and the 


Keaukaha Hawaiian Homesteads. Yet the 


topic of Environmental Justice was dismissed 


from this analysis. This is another violation of
 

NEPA requirements.”
 

NPS Response: 

Environmental impact statements “must take 

a ‘hard look’ at impacts that alternatives under 

consideration would have on the human 

environment if implemented” (DO12 Handbook, 

61). While this plan identifies the need for an 

ATMP, none of the alternatives propose actions 

that would directly increase air tours within the 

park which could, as the comments above suggest, 

further impact the resources mentioned above. 

The EIS associated with this GMP only assesses 

impacts to resources that could be impacted by the 

alternatives in the plan. The GMP does not assess 

impacts to minorities and low-income populations 

and communities because “The actions evaluated 

in this document would not have an effect (either 

beneficial or adverse) on socially or economically 

disadvantaged populations” (page 34). 

Furthermore, because alternatives in the GMP 

would impact soundscapes, wilderness, and 

adjacent land management, the document discusses 

cumulative impacts to these resources from activities 

like air tours within the park (see pages 306 and 

309 for cumulative impacts to wilderness and the 

acoustic environment from commercial air tours). 

Concern 37: 

Hawai‘i Volcanoes National Park should implement 

monitoring for air tours over the park. 

Representative Comments: 

•	 “[I]t is essential that the park staff develop a 

system to monitor and ensure compliance to the 

established regulations [for air tours] whatever 

16 | PUBLIC REVIEW AND COMMENTS FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS 
direction you choose to take our park. I certainly 

hope these suggestions will help you to make wise 

choices when deciding how to manage the future 

of our precious wilderness areas.” 

NPS Response: 

The airspace above the park is under the jurisdiction 

of the Federal Aviation Administration. The 

NPS currently monitors the number of air tours 

over Hawai‘i Volcanoes National Park through 

interim operating authority (IOA) reports that 

commercial air tour operations are required to 

submit under the FAA Modernization and Reform 

Act of 2012 (amended the National Parks Air Tour 

Management Act of 2000). 

While the GMP calls for additional monitoring 

of the acoustic environment, the monitoring that 

is requested in the above comment would be 

addressed and identified in an Air Tour Management 

Plan or other specific planning document 

regarding air tours. The GMP identifies the need 

for such a plan. 

PLANNING PROCESS (12 COMMENTS) 

Concern 38: 

The results of consultations with Native Hawaiian 

stakeholders should be included in the FEIS. 

Representative Comments: 

•	 “EPA encourages the NPS to ensure that 

meaningful consultation with all potentially 

affected Native Hawaiian stakeholders occurs 

throughout the NEPA process. The project area 

is culturally and spiritually important to Native 

Hawaiians and consultation is an important 

component of the decision-making process 

associated with this project. We recommend that 

the results of consultations with Native Hawaiian 

stakeholders be included in the FEIS.” 

NPS Response: 

The following information will be included 

within the Record of Decision that will document 

the NPS decision on the proposals evaluated 

in this Abbreviated Final and associated 

Draft GMP/WS/EIS. 

Consultation with Native Hawaiians has been a key 

component of this planning process as it is both 

mandated by the National Historic Preservation Act 

(Section 106) and informative for identifying and 

reviewing proposed actions as they relate to cultural 

and natural resources within the park. A description 

of the consultation process with Native Hawaiians 

from project initiation up to the release of the Draft 

GMP/WS/EIS is described on page 353 in the 

Draft GMP/WS/EIS. 

To continue consultation on the Draft GMP/WS/ 

EIS, the park mailed Native Hawaiian individuals 

and organizations on the park’s NHPA Section 

106 mailing list 1) a cover letter announcing the 

release of the document, explaining the plan and 

the planning/commenting process, requesting 

consultation, and inviting the recipient to attend a 

Kupuna meeting or the public talk story session; 2) 

a newsletter that fully outlined the three alternatives 

in the plan, encouraged the public to participate 

in the planning process, and included notification 

of the talk story session and wilderness hearing; 

and 3) a CD-ROM electronic version of the full 

Draft GMP/WS/EIS for their review. The park then 

hosted a Kupuna meeting on June 9, 2015 at the 

Kilauea Military Camp (in the park). At this meeting, 

the park planner presented information on the 

GMP and the preferred alternative, and the park’s 

Native Hawaiian liaison encouraged attendees to 

send comments to her, mail in comment sheets, or 

submit comments online on the project website. 

Some provided positive feedback on the preferred 

alternative, and two people asked questions: 1) 

about the status of the facility at the end of Chain of 

Craters Road, and 2) about the potential disposition 

of Jaggar Museum. 

The park did not receive any formal comments 

from individuals or organizations that are part 

of the Kupuna Consultation Group on the 

Draft GMP/WS/EIS. 

Concern 39: 

It was difficult to navigate the document and find 

information needed. It was difficult to determine the 

date and time of the public meeting. 

Representative Comments: 

•	 “This is a heavy and cumbersome book.” 

•	 “Not enough info to make informed comment 


(between the alternatives).”
 

FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS PUBLIC REVIEW AND COMMENTS | 17 
NPS Response: 

To comply with regulations and NPS policies, 

environmental impact statements, especially those 

associated with general management plans, are 

typically long and complex documents that can be 

challenging to navigate for those not familiar with 

the organization and scope of these documents. 

To make the documents easier to navigate, the full 

GMP includes a detailed table of contents, an index 

in the back, and a “how to use and comment on 

this plan” section within the first few pages of the 

document. The online version of the document, 

which has been available to the public since the 

public review period opened on May 1, 2015, is also 

bookmarked for easier navigation. The planning 

team also put together an executive summary of the 

plan (Newsletter #4) to share with the public via mail 

and the park’s and plan’s websites, and provided 

more succinct information about the alternatives 

and overall plan in the form of posters at the talk 

story session. 

The NPS announced the public release of the 

Draft GMP/WS/EIS, invited public comments, 

and notified the public of the talk story session and 

wilderness hearing through a notice in the Federal 

Register, press releases, websites, social media, 

and mailings, which included a 16-page newsletter 

(Newsletter #4) sent to over 800 people on the 

park’s mailing list and available on the project 

website. The newsletter fully outlined the three 

alternatives in the plan, encouraged the public to 

participate in the planning process, and included 

notification of the correct time and date of the 

talk story session and wilderness hearing. It also 

included phone numbers for how to reach key 

planning staff to ask questions about the plan. 

18 | PUBLIC REVIEW AND COMMENTS FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS 
	 	

	 	

	 	

	 	

ERRATA: CHANGES AND CLARIFICATIONS
 

TO THE DRAFT GMP/WS/EIS
 

This section contains those changes that should be 

made to the Draft GMP/WS/EIS. Some of these 

changes are a result of public comments while others 

are editorial in nature. If text has a strikethrough the 

text, it is deleted from the text; if it is underlined, it is 

added text. 

Page xviii, last paragraph under Actions Common 

to All Alternatives; Page xxii, last paragraph under 

Chain of Craters Road; Page xxv, under Chain of 

Craters Road; Page 102 under Chain of Craters 

Road; Page 108, last paragraph under End of Chain 

of Craters Road; and Page 127, last paragraph 

under End of Chain of Craters Road 

• Change text: A 5.5 mile segment of the Chain of 

Craters Road that ran through the park towards 

Kalapana was buried by lava flows generated 

by Pu‘u ‘Ō‘ō. Due to a change in the direction 

of the lava flow in 2014, an unpaved emergency 

access route was constructed - following the 

historic road alignment. Due to commitments 

made by the NPS during the construction 

of this road (County of Hawai‘i funded the 

construction of this route with the anticipation 

of being reimbursed by FEMA; FEMA includes 

specific mandates in their funding), the NPS 

is responsible for ensuring that the route is 

protected and maintained as an emergency access 

route regardless of temporary uses like trail 

access. This route is for emergency access only. 

When this route is not needed as an emergency 

access routeno longer needed for emergency 

access, it cwould be used as a trailan equestrian, 

biking, and hiking trail (similar in character 

and functionality to the Escape Road from the 

summit to Mauna Ulu) to provide a quality nonmotorized visitor use opportunity while ensuring 

the route is protected and maintained for its 

original intent. These uses would ensure that 

natural values are not compromised and future 

emergency route without compromising natural 

values and without adding the management 

complexity of managing a coastal entrance for 

public vehicles to enter the park. 

Page 121, second paragraph under 

Kīlauea Visitor Center 

• Change text: The covered outdoor lanai at
 

Kīlauea Visitor Center offers 24-hour trip
 

planning and orientation. To provide more
 

interpretive space on the often crowded lanai, 

the park would consider either expanding the 

lanai itself or removing and replacing the current 

restroom would be removed and replaced with 

a facility of similar capacity behind the visitor 

center and closer to the 1877 Volcano House, 

where Volcano Art Center Gallery is located. 

Relocating the restrooms would lessen the 

noise level and reduce congestion in this visitor 

use area, improving the experience for visitors 

using the displays and attending interpretive 

programs and information sessions on the lanai. 

The relocated restrooms would also replace the 

restrooms near the 1877 Volcano House building 

and may include a covered walkway to provide 

rain-free path to the restrooms. However, simply 

expanding the lanai may be less costly and 

require less ground disturbance than relocating 

the restrooms while still accomplishing the 

goal to increase the interpretive space outside 

the visitor center. Considering the potential 

benefits and impacts from implementing these 

various alternatives, the park would assess 

these alternatives through the completion of 

the site plan for the complex of buildings on the 

summit of Kīlauea. 

Page 179, second sentence under 

Kīlauea Visitor Center 

• Change text: To provide more interpretive
 

space, consider either expanding the lanai
 

itself or removing and replacing the current
 

restroomsRemove the current restroom and
 

replace with a facility of similar capacity
 

behind the visitor center and closer to the 1877
 

Volcano House.
 

Page 373, Hawai‘i Volcanoes National Park 

Adjustment Act of 2000 (P.L. 10-510) 

• Change text: “Public Law 87-278 (75 Stat. 

577) is amended by striking “Hawai‘iHawaii 

Volcanoes National Park” each place it appears 

and inserting “Hawai`iHawai‘i Volcanoes 

National Park...Any reference in any law (other 

than this Act), regulation, document, record, 

map, or other paper of the United States to 

“Hawai‘iHawaii Volcanoes National Park” shall 

be considered a reference to “Hawai`iHawai‘i 

Volcanoes National Park” 

FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS ERRATA | 19 
	 	

	 	

	 	

	 	

	 	 	 	 	 	

	 	 	 	 	 	

	 	 	 	

	 	 	 	 	

	 	 	 	

	 	 	 	 	

	 	 	 	 	

• All apostrophes within Hawaiian words shall be
 

changed to an ‘okina (‘) in this section.
 

Page 374, Hawai‘i Volcanoes National Park 

Adjustment Act of 2000 (P.L. 10-510) 

• Change text: “(a) Section 401(8) of the National 

Parks and Recreation Act of 1978 (Public Law 

96~-25; 92 Stat. 3489) is amended by striking 

“Hawai‘iHawaii Volcanoes” each place it appears 

and inserting “Hawai`iHawai‘i Volcanoes”.” 

• Change text: “(b) The first section of Public Law 

94?-667 (90 Stat. 2692)” 

• All apostrophes within Hawaiian words shall be
 

changed to an okina (‘) in this section.
 

Page 444-446 

• Change all references to temporary
 

flight restrictions (TFRs) to temporary
 

standoffs for aircraft.
 

Page 465, Hoawa 

• Correct spelling: Remove Hawaiian diacritical
 

from the word hawai‘iense in both the
 

header and the text. Correct species name is:
 

Pittosporum hawaiiense.
 

Page 481, Preparers and Consultants 

• Add “Kahuku Site Manager” after “Keola Awong” 

• Change “David Benite” to “David Benitez” 

• Add ‘okina to “Nainoa Keana‘aina” 

• Add “(Retired)” after “Bill Leek,
 

Landscape Architect”
 

• Add “(Retired)” after “Talmadge Magno, Chief
 

Ranger, Visitor and Resource Protection”
 

• Add makron to “Kūpono McDaniel” 

• Add “(Retired)” after “Walt Poole, Concessions
 

Management Specialist”
 

• Add “(Retired)” after “Rita Pregana,
 

Kahuku Site Manager”
 

Page 483, Glossary, Caldera 

• Change text: “Calderas are large geologic 

depressions that are found only at the very 

summit of volcanoes. A caldera is a large, usually 

circular depression. It is formed by collapses or 

large explosions at the center of the volcanoforms 

over ten of thousands of years and can change in 

shape with the likes of one large eruption.” 

Page 486, Glossary, Talk-Story Session 

• Change text: “Known in Hawai‘i as mo‘olelo,
 

is the tradition of personally sharing important
 

stories to preserve them for future generations.
 

The phrase is also often used in Hawai‘i to 

connotate general chatting, gossiping, or 

“shooting the breeze.” A talk-story session in 

the case of this general management plan is 

an open house-style meeting, where people 

can talk to subject matter experts, as well as 

other participants.” 

Page 492, Selected Bibliography, Bio, K. 

• Correct spelling: Yoshiokao. 

Page 500, Selected Bibliography 

• Add the following bibliographic sources to the

Selected Bibliography:

» National Park Service, U.S. Department of 

the Interior (NPS). 2015. Director’s Order 12 

NEPA Handbook. Washington, DC: Office of 

Policy. September 2015. Available at <http:// 

www.nps.gov/applications/npspolicy/ 

DOrders.cfm>. Accessed 15 October 2015. 

» National Park Service, U.S. Department of 

the Interior (NPS). 2013b. Director’s Order 

41: Wilderness Stewardship. Washington, 

DC: Office of Policy. 13 May 2013. Available 

at <http://www.nps.gov/policy/DOrders/ 

DO_41.pdf>. Accessed 15 October 2015. 

» National Park Service, U.S. Department of 

the Interior (NPS). 2013c. Hawaii Volcanoes 

National Park Acoustical Monitoring 

Snapshot. Fall 2013. NPS Natural Sounds and 

Night Skies Division. 6 pgs. 

Page 509, Index 

• Add text to beginning of Index: “The spelling 

of geographic locations in this document is based 

on the  Geographic Names Information System 

(GNIS), which is official vehicle for geographic 

names use by the Federal Government and the 

source for applying geographic names to Federal 

maps & other printed and electronic products.” 

• Correct spelling of all instances: ‘āhinahina. 

• Correct spelling of all instances: kKa‘ūpūlehu 

• Correct spelling of all instances: Kīpuka Kkī 

• Correct spelling of all instances: Kipuka 

Nnēnē Campground 

Page 510, Index 

• Correct spelling of all instances:

Kuūlanaokuaiki Campground 

• Correct spelling of all instances: Kuūpa‘ianahaā 

• Correct spelling of all instances: ‘Ōohi‘a Wing 

• Correct spelling of all instances: ‘ōlapa 

20 | ERRATA FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS 
APPENDIX A: AGENCY AND ORGANIZATION COMMENTS
 

FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS APPENDIX A | 21 

Correspondences - Hawaii Volcanoes National Park General Management Plan - PEPC ID: 24888 

Page 1 of 2

Comments:

">

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

PEPC Project ID: 24888, DocumentID: 64395 

Correspondence: 8 

Author Information 

Keep Private: No 

Name: Aric P. Arakaki 

Organization: Ala Kahakai National Historic Trail 

Organization Type: I - Unaffiliated Individual 

Address: 73-4786 Kanalani Street, #14 

Kailua-Kona, HI 96740
�

Kailua-Kona, HI 96740
�

USA
�

E-mail: aric_arakaki@nps.gov 

Correspondence Information 

Status: Reviewed Park Correspondence Log: 

Date Sent: 06/05/2015 Date Received: 06/05/2015 

Number of Signatures: 1 Form Letter: No 

Contains Request(s): No Type: Web Form 

Notes: 

Correspondence Text 

Topic Question 1:
�

Alternative 2 since it is the park's preferred alternative but this is conditioned on including language pertaining the
�

Ala Kahakai NHT cited in the No Action Alternative under section, Trails: Hiking Biking and Equestrian, page
�

113(top) where it mentions HAVO working with ALKA staff on the establishment of the ALKA in the park. This is 

not mentioned in the same section in the Preferred Alternative - Alternative 2.
�

Topic Question 2:
�

To reiterate, inclusion of the ALKA in the Preferred Alternative is actually mandated by Public Law 106-509 

which established the ALKA corridor within all NPS units on Hawaii Island. As such it needs to be included in all
�

Alternatives.
�

Topic Question 4:
�

None
�

Topic Question 5:
�

To re-reiterate, inclusion of the ALKA in the Preferred Alternative is actually mandated by Public Law 106-509
�

which established the ALKA corridor within all NPS units on Hawaii Island. As such it needs to be included in all
�

Alternatives. ALKA and HAVO will be better enabled to establish the ALKA in the park when it is cited as
�

requested above in the Final GMP.
�

22 | APPENDIX A FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

· REGION IX 

75 Hawthorne Street 

San Francisco, CA 94105 

July 2, 2015 

Cindy Orlando, Superinten g · / ~/ 

Hawaii Volcanoes Nationa 

Attn: DEIS-GMP, P.O. Box 52 

Hawaii National Park, HI 96718-0052 

Subject: Draft Environmental Impact Statement/General Management Plan /Wilderness 

Study, for the Hawaii Volcanoes National Park Project, Hawaii. 

(CEQ# 20150117). . 

Dear lY[rs. Orl~do: 

The U.S. Environmental Protection Agency has reviewed the Draft Environmental Impact 

Statement for the Hawaii Volcanoes National Park Project, Hawaii. Our review is provided 

pursuant to the National Environmental Policy Act, the Council on Environmental Quality's 

NEPA Implementing Regulations (40 CFR 1500-1508), and Section 309 of the Clean Air Act. 

EPA supports the National Park Service's goals ·of protecting fundamental resources, such as 

marine, terrestrial, cultural and archeological assets. Based on our review of the DEIS, we have. 

rated the proposed project as Lack of Objections (LO), please see the enclosed Summary of EPA 

Rating Definitions. Our rating is based on the Preferred Alternative 2, which promotes 

preservation of Hawaii Volcanoes National Park's Native Hawaiian values while strengthening 

and broadening opportunities to connect people with the park's volcanic treasures. 

The project proposes to treat invasive plants with herbicide (page: 169). We recommend that the 

FEIS clearly identify which herbicide or pesticide products, if any, would be approved for use 

and in which areas. We recommend that the NPS include a commitment in the FEIS to adhere to 

pesticide label directions for any pesticide or herbicide application. We also recommend that the 

FEIS specify appropriate buffer zones to protect water quality from any pesticide/herbicide 

applications. We recommend that the FEIS describe how pesticide mixing and storage areas 

would be sited and managed to further protect water sources and other sensitive areas, such as 

food source and/or herb gathering areas. 

On June 20, 2014, President Obama issued a memorandum directing Federal departments and 

agencies to evaluate and use their resources, facilities, and land management responsibilities to 

expand knowledge of pollinator health and to increase habitat quality and availability. While the 

DEIS acknowledges the importance of native pollinators to specific plant species, it is unclear 

what potential adverse impacts may occur to pollinators from proposed herbicide/pesticide use 

associated with the initial action. In May 2015, the Forest Service released a draft document in 

response to the President's memorandum, titled "Pollinator-Friendly Best Management Practices 

FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS APPENDIX A | 23 
for Federal Lands", which states that "Eight broad considerations are key when evaluating 

projects for conserving pollinator habitat: 

• determining the quality of foraging habitat; 

• identifying important pollinator reproduction sites; 

• determining important nesting and overwintering sites; 

• identifying pollinators of sensitive or at-risk plant species on Federal, 

State, local, or nongovernmental organization (NGO) (e.g., 

NatureServe) lists as outlined in the National Academy of Sciences 

report Status of Pollinators in North America. 

• identifying and removing invasive species to improve polli11ator 

habitat; 

• identifying, collecting, and using local, genetically appropriate native 

seeds; 

• implementing adaptive management; and 

• engaging and informing the public." 

We recommend the NPS include, where appropriate in the FEIS, include similar best 

management practices to support pollinator health and affected ecosystems. 

EPA encourages the NPS to ensure that meaningful consultation with all potentially affected 

Native Hawaiian stakeholders throughout the NEPA process. The project area is culturally and 

spiritually important to Native Hawaiian's and consultation is an important component of the 

decision-making process associated with this project. We recommend that the results of 

consultations with Native Hawaiian stakeholders be included in the FEIS. 

The proposed action could result in some new facilities, such as education pavilions 

campgrounds and picnic areas (page 293 ). EPA encourages the NPS to include a commitment to 

the development of sustainable green infrastructure as a guiding principle for future 

developments in the park. 

EPA appreciates the opportunity to review this DEIS. When the FEIS is released, please send 

one hard copy and one CD to the address above (mail code: ENF-4-2). If you have any 

questions, please contact me at (415) 972-3521, or have your staff contact James Munson, the 

lead reviewer for this project. James.can be reached at (415) 972-3852 or 

Munson.James@epa.gov. 

Enclosure: Summary of the EPA Rating System 

{;, 

oforth, Manager 

Environmental Review Section 

24 | APPENDIX A FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS 
SUMMARY OF EPA RATING DEFINITIONS* 

This rating system was developed as a means to summarize the U.S. Environmental Protection Agency's 

(EPA) level of concern with a proposed action. The ratings are a combination of alphabetical categories 

for evaluation of the environmental impacts of the proposal and numerical categories for evaluation of the 

adequacy of the Environmental Impact Statement (EIS). 

ENVIRONMENTAL IMPACT OF THE ACTION 

"LO" (Lack of Objections) 

The EPA review has not identified any potential environmental impacts requiring substantive changes to 

the proposal. The review may have disclosed opportunities for application of mitigation measures that 

could be accomplished with no more than minor changes to the proposal. 

"EC" (Environmental Concerns) 

The EPA review has identified environmental impacts that should be avoided in order to fully protect the 

environment. Corrective measures may require changes to the preferred alternative or application of 

mitigation measures that can reduce the environmental impact. EPA would like to work with the lead 

agency to reduce these impacts. 

"EO" (Environmental Objections) 

The EPA review has identified significant environmental impacts that should be avoided in order to 

provid~ adeguate_J.lrotection for the environment. Ggrrecti:v~ m~sures ~may r~quire su_t,stanti~!~h.a!!ges to 

the preferred alternative or consideration of some other project alternative (including the no action 

alternative or a new alternative). EPA intends to work with the lead agency to reduce these impacts. 

"EU" (Environmentally Unsatisfactory) 

The EPA review has identified adverse environmental impacts that are of sufficient magnitude that they 

are unsatisfactory from the standpoint of public health or welfare or environmental quality. EPA intends 

to work with the lead agency to reduce these impacts. If the potentially unsatisfactory impacts are not 

corrected at the final EIS stage, this proposal will be recommended for referral to the Council on 

Environmental Quality (CEQ). 

ADEQUACY OF THE IMPACT STATEMENT 

Category "1" (Adequate) 

EPA believes the draft EIS adequately sets forth the environmental impact(s) of the preferred alternative 

and those of the alternatives reasonably available to the project or action. No further analysis or data 

collection is necessary, but the reviewer may suggest the addition of clarifying language or information. 

Category "2" (Insufficient Information) 

The draft EIS does not contain sufficient information for EPA to fully assess environmental impacts that 

should be avoided in order to fully protect the environment, or the EPA reviewer has identified new 

reasonably available alternatives that are within the spectrum of alternatives analyzed in the draft EIS, 

which could reduce the environmental impacts of the action. The identified additional information, data, 

- analyses, or discussion should be included in the final EIS. 

Category "3" (Inadequate) 

EPA does not believe that the draft EIS adequately assesses potentially significant environmental impacts 

of the action, or the EPA reviewer has identified new, reasonably available alternatives that are outside of 

the spectrum of alternatives analyzed in the draft EIS, which should be analyzed in order to reduce the 

potentially significant environmental impacts. EPA believes that the identified additional information, 

data, analyses, or discussions are of such a magnitude that they should have full public review at a draft 

stage. EPA does not believe that the draft EIS is adequate for the purposes of the NEPA and/or Section 

309 review, and thus should be formally revised and made available for public comment in a 

supplemental or revised draft EIS. On the basis of the potential significant impacts involved, this proposal 

could be a candidate for referral to the CEQ. 

*From EPA Manual 1640, Policy and Procedures for the Review of Federal Actions Impacting the Environment 

FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS APPENDIX A | 25 
PEPC Project ID: 24888, DocumentID: 64395 

Correspondence: 19 

Author Information 

Keep Private: No 

Name: Andrew C. Powers 

Organization: Digital Tours - Hawaii, LLC 

Organization Type: I - Unaffiliated Individual 

Address: 92-510 Akaula St 

Kapolei HI 96707 

Kapolei, HI 96707 

USA 

E-mail: afowers@selfguidedhawaii.com 

Correspondence Information 

Status: Reviewed 

Date Sent: 06/30/2015 

Number of Signatures: 1 

Contains Request(s): No 

Notes: 

Correspondence Text 

Topic Question 1: 

Park Correspondence Log: 

Date Received: 06/30/2015 

Form Letter: No 

Type: Web Form 

Alternative 3. I have visited the park many times in the past year and found the Visitor experience ( outside the 

park) to be completely focused on a few information displays with long drives in between each stop. The rangers 

are very helpful at VIS but when visitor's are driving on the road, all they have is a copy of the park map to not 

only guide them but entirely instruct them what they are seeing. I encourage HVNP administration to see the 

visitor's experience as not a limited to each stop but rather the very first minute they arrive at the park up until the 

last minute when they leave the park; basically their entire driving experience. 

I realize there is a plethora of books that help explain all that is to see at the park but sadly to say, it is very hard for 

visitors to read a book while they are driving. Or even to spend their precious time at the park pouring over the 

amazing back-stories of the park and all it's volcanic history. 

In my extensive research of the park, I have found many fascinating features in the park that are not clearly 

described prior to or during the visitors's driving experience. Without the visitor's understanding the back-story 

and significance of each crater and volcanic occurrence, what they see has far less meaning. We need to connect 

the stories with the place in real time to make them have more meaning. 

I feel strongly that the park needs to explore new ways to connect visitors with how they experience the park in 

between each major stop, bringing a deeper understanding on every level - geologically, biologically and 

culturally. 

I propose that HVNP consider the pairing of mobile technology with an audio narrated experience to be the way 

in which we can elevate and enhance the overall experience of visitors to the park, especially as they drive. 

26 | APPENDIX A FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS 
Topic Question 2: 

Audio tours are not something that is new. HVNP uses wands with displays as VIS with mixed results. Mount 

Rushmore on the other hand has incorporated an audio tour into its very operations creating an additional 

revenue source and an improved visitor's experience for many years with great success. 

The problem with the Mount Rushmore model is the initial purchase and the ongoing maintenance of the 

hardware. With the technology nowadays, all of that has changed. 

Majority of people both domestic and international now carry their own smartphone with sophisticated GPS 

technology that can support a data-free offline map and an audio-based driving experience. 

Great Smokey Mountain National Park has already partnered to build a mobile app for its park on both Android 

and iOS. 

Topic Question 3: 

I have read it and it appears to thoroughly address all impacts to each resource and how they are being managed. 

Topic Question 4: 

Again, I have read it and it appears all in order. 

Topic Question 5: 

In my experience as a outside business seeking to work with the HVNP in forming a partnership, 1 found the staff 

and bureaucracy surrounding the staff to be non-conducive in seeding and maturing meaningful partnerships. In 

my many attempts to try to communicate and propose mutually beneficial partnerships with HVNP (as I will 

explain below), the only response I received was to speak to this person or that. It seemed that no one had any 

incentive or motivation to directly consider outside proposals because it seemed to be outside their normal scope 

of work, despite any benefits it would bring to Visitors. 

This is taken from the NPS website about partnerships: 

"Partnerships are encouraged throughout the government as a way of leveraging resources and accomplishing 

more than anyone group could do on its own. We need to exponentially grow partnering awareness, skills and 

management capacity. This is only possible through highly motivated and empowered NPS employees and a 

supportive organizational culture. 

Partnership management has become a core competency to carry out our NPS mission and deliver public service 

at a higher level. Our challenge is to more effectively grow that competency by building on past partnership 

successes and develop new capacity servicewide. Our management challenge at every level is to effectively align 

and leverage resources to enable NPS employees and partners to create and sustain more effective partnerships." 

http://www.nps.gov/partnerships/ about.htm 

Comments: This is my experience in trying to work with HVNP: 

I initally contacted park rangers who forwarded my information to HPP A. I sent over a detailed proposal to HPPA 

outlining an idea to rent GPS devices with installed audio-based driving tour in multiple languages (as I have done 

for many years on all the islands). I then meet in person with them. There seemed to be initial interest but it feel 

apart when HPPA tried to further the discussion through the Director of Marketing, the Chief of Interpretation 

and the Operations Manager. From start to finish I went back and forth with HPPA and some NPS staff for over a 

year to try and move the proposal forward with no success. 

FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS APPENDIX A | 27 
In the meantime my company has moved forward without NPS support in writing an extensive script narration 

that covers the entire Hawaii Volcanoes National Park that is to be released as an offline mobile app in September 

of 2015. This app will be a driving tour that visitors can download to their smartphones and experience as they 

drive through the park. There are still opportunities to work together if there is interest. 

But my hope in writing this is not for my company but for HVNP to change the way in which it handles and vets 

partnerships in the future. It is especially important to effectively use outside partnership as a source of innovation 

in times of budget cuts and fewer park rangers. 

"> 

28 | APPENDIX A FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS 
PEPC Project ID: 24888, DocumentID: 64395 

Correspondence: 13 

Author Information 

Keep Private: 

Name: 

Organization: 

Organization Type: 

Address: 

E-mail: 

No 

Erik Storm 

Kilauea EcoGuides 

I - Unaffiliated Individual 

PO BOX 550 Volcano, HI 96785 

Volcano, HI 96785 

USA 

info@kilaueaecoguides.com 

Correspondence Information 

Status: Reviewed 

Date Sent: 06/22/2015 

Number of Signatures: 1 

Contains Request(s): No 

Notes: 

Correspondence Text 

Topic Question 1: 

Park Correspondence Log: 

Date Received: 06/22/2015 

Form Letter: No 

Type: Web Form 

We like alternative #2 - Nahukus parking situation needs to be addressed as the big buses and vans take up all the 

space! The idea for a cultural museum at the Ohia Wing is also great. More Hawaiian people working in the park 

should also be a priority. 

Topic Question 2: 

There needs to be more rubbish and recycling at locations like the steam vent parking lot and devastation trail. 

Also more covered picnic areas around the summit and on chain or craters road. More paths for bicycles to 

continue to promote eco-friendly ways to explore the park! 

Topic Question 3: 

The culture should always come first from our perspective. Respect for place and people thru in depth education. 

Also boot/shoe brushes for when visitors hike to areas like Mauna Ulu and Kilauea Iki. Supplemented by 

informational displays on why it is important to brush shoes before hiking into these areas. This could help with 

reducing the spread of invasives especially grasses. 

Topic Question 4: 

No. 

Topic Question 5: 

This park does a great job, and we hope to continue to see staff focus on cultural interpretation. Having visitors 

learn about how special this National Park is seems to be a top priority. Continue to promote sustainability thru 

concepts like re-useable water bottles, and hiking/biking as opposed to driving around in a car all day. Reduce 

waste by NOT allowing the hundreds of styrofoam lunches that many of the big bus tours use every single day! 

FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS APPENDIX A | 29 
Eco friendly shuttle services would be great, and even shuttle between Volcano Village and the National Park 

would be nice to see. 

Comments: You all do a great job with such a massive and culturally significant resource, keep up the good work!l 

"> 

30 | APPENDIX A FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS 
Correspondences - Hawaii Volcanoes National Park General Management Plan - PEPC ID: 24888 

Page 1 of 2

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

PEPC Project ID: 24888, DocumentID: 64395 

Correspondence: 7 

Author Information 

Keep Private: No 

Name: Sarah (Sally) H. Rice 

Organization: Ka Ahahui O Ka Nahelehele 

Organization Type: I - Unaffiliated Individual 

Address: 71-1361 Hawaii Belt Road 

Kailua, Kona, HI 96740 

USA 

E-mail: sally@riceohana.com 

Correspondence Information
�

Status: Reviewed Park Correspondence Log: 

Date Sent: 05/13/2015 Date Received: 05/13/2015 

Number of Signatures: 1 Form Letter: No 

Contains Request(s): No Type: Web Form 

Notes: 

Correspondence Text 

Topic Question 1: 

Alternative 2: It seems to strike the correct balance.
�

Topic Question 2:
�

I find the preferred alternative quite comprehensive.
�

Topic Question 3:
�

No.
�

Topic Question 4:
�

No.
�

Topic Question 5:
�

The inclusion of the two Kahuku parcels, the 222 acre parcel and the coastline parcel from Pohue Bay, are
�

extraordinary potential additions to the Park. The coastline area has absolutely amazing petroglyphs and
�

Hawaiian habitation sites, much of which was well documented by Kenneth Emory of Bishop Museum and later
�

by Violet Hansen in the '60's with some very interesting interpretations of a few petroglyphs by Ruth Knudsen
�

Hanner of Kauai. I have some of Violet's work left to me by Violet which I would happily give access to anyone
�

who is interested. Most of the information is I believe also at the Bishop Museum. If the Park is able to incorporate
�

these parcels into the Kahuku Unit, it would be a marvelous legacy for the people of Hawaii as well as visitors.
�

Comments:
�

">
�

FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS APPENDIX A | 31 
Correspondences - Hawaii Volcanoes National Park General Management Plan - PEPC ID: 24888 

Page 1 of 3

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

PEPC Project ID: 24888, DocumentID: 64395 

Correspondence: 17 

Author Information 

Keep Private: No 

Name: Dick Hingson 

Organization: Sierra Club - National Parks and Monuments Committee 

Organization Type: I - Unaffiliated Individual 

Address: 

Flagstaff, AZ 86001 

USA 

E-mail: 

Correspondence Information 

Status: Reviewed Park Correspondence Log: 

Date Sent: 06/30/2015 Date Received: 06/30/2015 

Number of Signatures: 1 Form Letter: No 

Contains Request(s): No Type: Web Form 

Notes: 

Correspondence Text 

Topic Question 1:
�

not applicable - deferred to Hawaii Chapter
�

Topic Question 2:
�

not applicable - deferred to chapter
�

Topic Question 3:
�

not applicable
�

Topic Question 4:
�

see response to Question 5 below
�

Topic Question 5:
�

see response below, added under "Comments"
�

Comments:
�

We are VERY SUPPORTIVE of any/all attempts by the National Park Service to ensure appropriate use , and
�

appropriate, strong environmental soundscape standards, for wild/primitive zones of the park. In this way, it
�

becomes much easier to avoid Impairment of said zones.
�

These comments and questions thus pertain to wilderness character (i.e., "solitude") preservation goals and
�

Standards for the "Wild/Primitive" Zone. They refer to the Table G.1 in Appendix G, Page 446.
�

32 | APPENDIX A FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS 
Correspondences - Hawaii Volcanoes National Park General Management Plan - PEPC ID: 24888 

Page 2 of 3

 

 

 

________________________________________________________________________ 

 

 

 

 

 

 

 

 

 

 

________________________________________________________________________ 

 

 

 

 

 

(excerpted here is taken from Table G.1 but with added ** asterisk markings , to identify the particular points of 

comment and questioning) 

Table G.1. Indicators, Standards, Management Strategies, and Monitoring Strategies 

Indicator Topic
�

Indicator
�

Indicator Rationale
�

Zone
�

*Standard* 

*Standard Rationale*
�

Management Strategies 

Monitoring Strategies and Timeline
�

**Soundscapes and the Acoustic Environment**
�

**Difference between existing and natural ambient sound levels - Mean L50 Impact (dBA) **
�

**WILD/PRIMITIVE ZONE**
�

**Mean difference between natural and ambient dBA (L50) is not more than 1.0 dBA.**
�

**This standard is set to ensure that natural sounds dominate the soundscape. Distant artificial sounds may be 

heard in some areas of this zone. Human-caused noise should be rare or very infrequent in occurrence and in 

limited areas of the zone. Pristine soundscapes should occur in some areas of this zone. ** 

COMMENT, RESUMED: 

1. The NPS should (1) state if it believes ANY air tours are appropriate use (including constructive use of 

soundscape, i.e., impact on natural quiet) in the wild/primitive zone. NPS Director's revised Order on Wilderness 

Stewardship says air tours are NOT appropriate use in such zones because of negative impact on wilderness 

character, i.e., on "solitude"; if so, that should be re-articulated for Hawaii Volcanoes National Park, specifically. 

2. The NPS should re-affirm the excerpted Wild/Primitive Acoustic standard above, that the standard is no noise 

difference more than 1.0 dBA. 

FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS APPENDIX A | 33 
Correspondences - Hawaii Volcanoes National Park General Management Plan - PEPC ID: 24888 

Page 3 of 3

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

3. The NPS should usefully offer further rationale as to WHY it set said standard at 1.0 dBA difference between 

natural and ambient dBA. (As opposed to say, 1.5 dBA or 3 dBA, for example). 

3a. The rational might state if for any reason the 1.0 dBA standard is Park-specific? Or would it be a reasonable 

standard appropriate to apply in other Parks with Wild/Primitive Zoning? If not, why is this particular unit-ofdifference being applied specifically for Hawaii Volcanoes National Park? 

4. the NPS should explain whether/how current acoustical measurement technology is available to capture this 1.0 

dBA difference accurately, reliably over time, and defensibly against challenge by such as motorized/commercial 

sources. 

This answer should address both using *acoustic modelling* techniques, and *acoustic measurement* techniques 

in the field. It should address the costs and practicability of doing sufficient measurements, over time, needed to 

defensibly enforce the Standard. 

5. The NPS is invited to address how this 1.0 dBA standard is to be applied.
�

Is it a standard for "Desired Conditions"? Is it a standard for identifying "Unacceptable Impacts" vs. "Major
�

Adverse" ; or "Major Adverse" vs. "Moderate Adverse".
�

NPS should explain with a *case example* or two, if possible, how this standard would be applied.
�

For example, it could use aircraft noise data from its own management aircraft operations, or it could compute
�

aircraft noise based on commercial air tours in the vicinity. This is reasonable, because NPS itself indicates that it
�

would like to address commercial air tour management, via an ATMP, in the future, and, thus expressing this
�

Standard is therefore relevant as a key step, right now. At least this much preparation could be very
�

helpful/supportive to the next planning steps, in documents to come such as GMP, or Soundscape Management
�

Plan, or ATMP.
�

(Our assumption is "Existing Ambient" noise levels (elevating the "Natural Ambient") noise levels would be
�

primarily or solely increased by commercial air tours, in substantial areas of the Wild/Primitive Zones. (Since
�

there is virtually nothing else of mechanized noise to be heard in said areas.)
�

If this is not a correct assumption, we invite further NPS statement or clarification.)
�

Thank you for attending to this response.
�

Dick Hingson, noise/aviation analyst for the Sierra Club's National Parks and Monuments Committee, which has 

approved my forwarding of this comment.
�

">
�

34 | APPENDIX A FINAL HAWAI‘I VOLCANOES NATIONAL PARK GMP/WS/EIS 
 

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. 

NPS/HAVO/124/125673A 

Printed on Recycled Paper 

Native old growth rain forest in ‘Ōla‘a Unit. NPS photo. 
National Park Service 

U.S. Department of the Interior 

Prepared by: National Park Service | Pacific West Region-Seattle Office 

Park Planning and Environmental Compliance 

909 1st Avenue | Seattle, WA 98104 

EXPERIENCE YOUR AMERICA 

Rainbow over Halema‘uma‘u Vent and Kīlauea Caldera. Photo by Peter Anderson