How to provide comments

This draft study report is available for public review 

and comment until July 15, 2014. We welcome your 

thoughts through email, our website, mail, or at one of 

the public meetings that we are hosting. Your comments 

will help us revise and finalize this report and will 

inform the recommendation that is made to Congress 

as part of this report. Thank you for your thoughtful 

feedback.

Mail: National Park Service

 Honouliuli Gulch and Associated Sites SRS

 Park Planning & Environmental Compliance

 909 First Avenue, Suite 548

 Seattle, WA 98104

Email: pwr_honouliuli@nps.gov

Website: http://www.nps.gov/pwro/honouliuli

Phone: Honolulu Office

 National Park Service, Pacific West Region

 (808) 541-2693

 Special Resource Study Project Leads:

 Anna Tamura, (206) 220-4157 

 Barbara Butler Baunsgard, (415) 623-2311

Detail, sketch of internees working on crafts at Honouliuli by Dan T. Nishikawa, 

April 29,1943. Courtesy of the Japanese Cultural Center of Hawai‘i, Dan Toru 

Nishikawa Family Collection.

PWRO 963 / 124441/ May 2014 

Printed on post-consumer recycled paper with 

soy-based inks.

you’re invited to a Public meeting! 

Please join us for a public meeting to share your 

comments relating to this draft special resource study 

and environmental assessment. We look forward to 

seeing and hearing from you! 

24 Honouliuli Gulch and Associated Sites Draft Special Resource Study & Environmental Assessment 

Tuesday, May 27, 2–4 pm 

KAPOLEI, o‘ahu

Lab Building E132, University of Hawai‘i—West O‘ahu 

91–1001 Farrington Highway

Wednesday, May 28, 6–8 pm 

Thursday, May 29, 10 am–noon

HONOlulu, o‘ahu

Japanese Cultural Center of Hawai‘i

2454 S Beretania Street, #101

Thursday, May 29, 6:30–8:30 pm 

lÏhu‘e, Kaua‘I

Līhu‘e Neighborhood Center

3353 Eono Street

Monday, June 2, 10 am–noon 

kaunakakai, molokai

Kaunakakai Elementary School Cafeteria

Ailoa Street

Monday, June 2, 6–8 pm

kahului, maui

Alexa Higashi Room, Maui Arts and Cultural Center

One Cameron Way

Tuesday, June 3, 2–4 pm 

lĀna‘I city, lĀna‘I

The Lāna‘i Senior Center

309 Seventh Street

Wednesday, June 4, 6–8 pm

hilo, island of hawai‘I

Hawai‘i Japanese Center

751 Kanoelehua Avenue

Tuesday, June 17, 10 am–noon (Hawai‘i Time), 

1–3 pm (Pacific Time), 4–6 pm (Eastern Time)

virtual meeting

Virtual meeting web access information will be 

posted at www.nps.gov/pwro/honouliuli 
2 Honouliuli Gulch and Associated Sites Draft Special Resource Study & Environmental Assessment 

Abstract

The National Park Service (NPS) prepared the Honouliuli 

Gulch and Associated Sites Draft Special Resource Study 

and Environmental Assessment to determine whether the 

Honouliuli Internment Camp and associated World War 

II internment sites in Hawai‘i are nationally significant, 

suitable, and feasible for inclusion in the national park 

system. Congress authorized this study in 2009. The study 

evaluates 17 sites.

Through the special resource study process, the NPS made 

the following determinations about the study sites:

•	 The Honouliuli Internment Camp and the U.S. 

Immigration Station on the island of O‘ahu are 

nationally significant for their central role as 

internment sites in Hawai‘i during World War II. 

They meet all four of the NPS criteria for national 

significance. The other 15 sites associated were used 

for shorter periods of time, interned fewer numbers 

of people, or have been substantially changed since 

the period of significance. As such, they do not meet 

the criteria for national significance. Many of these 

sites are, however, listed or eligible for listing in the 

National Register of Historic Places and/or provide 

opportunities to further interpret the history of 

internment in Hawai‘i during World War II.

•	 The Honouliuli Internment Camp and the U.S. 

Immigration Station depict a distinct and important 

aspect of American history associated with civil 

liberties in times of conflict that is not adequately 

represented or protected elsewhere, and are therefore 

suitable for inclusion in the national park system.

•	 The Honouliuli Internment Camp historic site is 

a feasible addition to the national park system 

conditional upon securing public access to the site. 

The U.S. Immigration Station complex is not a feasible 

addition to the national park system because the 

complex is currently used by the U.S. Department 

of Homeland Security and the State of Hawai‘i 

Department of Health.

•	 There is a need for NPS management of the 

Honouliuli Internment Camp historic site in 

partnership with others to fully protect resources 

and to enhance visitor appreciation of the nationally 

significant resources and important stories associated 

with it.

The NPS evaluated two alternatives in the draft study. One 

includes a role for the NPS.

Alternative A: Continuation of Management. This is the 

“no action” alternative. Sites, organizations, and programs 

significant to the internment history in Hawaiʻi would 

continue to operate independently by existing landowners, 

agencies, or organizations without additional NPS 

management or assistance other than what is currently 

available through existing authorities and grant programs.

Alternative B: Honouliuli National Historic Site or 

Monument–A Unit of the National Park System. 

Congress would establish Honouliuli National 

Historic Site as a new unit of the national park system. 

Alternatively, a national monument managed by the 

NPS could be established. The national historic site or 

national monument would include the historic site of 

the Honouliuli Internment Camp and adjacent lands 

that provide road access and opportunities for visitor 

facilities. The NPS would preserve the site and interpret 

the internment of Japanese Americans and European 

Americans in Hawaiʻi during World War II. The national 

historic site or monument would be supported by 

operational capacity at World War II Valor in the Pacific 

National Monument, Pearl Harbor. The NPS could 

provide technical assistance for the preservation and 

interpretation of other sites, features, and stories related to 

internment in Hawaiʻi during World War II. 

The NPS prepared an environmental assessment to 

identify and analyze the potential environmental and 

socioeconomic consequences of the two alternatives. 

The NPS concluded that alternative B would be the 

environmentally preferable alternative because it 

would protect nationally significant resources, provide 

opportunities for visitors to learn about the internment 

history in Hawai‘i during World War II, provide greater 

socioeconomic benefits, and apply long-standing NPS 

policies and actions to the Honouliuli Internment Camp 

historic site. 

Remaining World War II-era structure, Honouliuli Internment Camp. Photo: 

Valentino Valdez.
22 Honouliuli Gulch and Associated Sites Draft Special Resource Study & Environmental Assessment 

Environmentally Preferred

Alternative

The NPS is required to identify an “environmentally 

preferred alternative” in an EA. The environmentally 

preferable alternative is determined by applying the 

criteria suggested in the National Environmental 

Policy Act (NEPA) of 1969 and is further guided by the 

Council on Environmental Quality (CEQ). The CEQ 

(46 FR 18026 - 46 FR 18038) provides direction that the 

“environmentally preferable alternative is the alternative 

that would promote the national environmental policy as 

expressed in NEPA’s Section 101,” including: 

•	 Fulfill the responsibilities of each generation as trustee 

of the environment for succeeding generations;

•	 Assure for all Americans safe, healthful, productive, 

and aesthetically and culturally pleasing surroundings;

•	 Attain the widest range of beneficial uses of the 

environment without degradation, risk of health 

or safety, or other undesirable and unintended 

consequences;

alternative. The analysis includes consideration of the 

context, intensity, and duration of direct and indirect 

effects of all the alternatives. 

The NPS based analysis and conclusions on a review 

of existing literature, information provided by experts 

within the NPS as well as outside organizations, analysis 

of case studies of existing programs in other locations, 

and the professional judgment of the team members. 

The findings of this study will inform a recommendation 

by the Secretary of the Interior to Congress. If Congress 

takes action, then new environmental analysis would be 

undertaken prior to implementation actions. This new 

analysis would propose specific actions whose specific 

impacts would be assessed prior to implementation.

The NPS evaluated the environmental consequences 

of each alternative on the following topics: land use, 

water resources, vegetation, prehistoric and historic 

archeological resources, historic structures / cultural 

landscapes, museum collections, visitor experience, and 

socioeconomics.

The NPS finds that there would be no significant impacts 

associated with the proposed alternatives.

Aerial view of Honouliuli Gulch looking south, showing both Monsanto lands (left) and University of Hawai‘i—West O‘ahu lands (right). Board of Water 

Supply facilities are visible in the foreground. Photo: Monsanto Company.
4 Honouliuli Gulch and Associated Sites Draft Special Resource Study & Environmental Assessment 

Environmental Policy Act process for this special resource 

study. No significant impacts or effects are anticipated from 

the findings and recommendations of this study.

According to NPS management policies, a proposed 

addition to the national park system will receive a favorable 

recommendation from the NPS only if it meets all of the 

following four criteria for inclusion:

•	 it possesses nationally significant natural or cultural 

resources;

•	 it is a suitable addition to the system;

•	 it is a feasible addition to the system; and

•	 it requires direct NPS management, instead of 

alternative protection by other public agencies or the 

private sector.

These criteria are designed to ensure that the national park 

system includes only the most outstanding examples of the 

nation’s natural and cultural resources, while recognizing 

that there are other management alternatives for preserving 

the nation’s outstanding resources.

Alternatives for NPS management are developed for sites 

that meet all four of the criteria for inclusion.

Public Involvement

Public Scoping

The NPS launched public scoping for this study in 

February 2011. A notice of scoping was published in 

the Federal Register on May 2, 2011 (Vol.76, No. 83, 

24514–15). The study team produced and distributed an 

informational newsletter and press releases to the media, 

individuals, organizations, and government officials. Public 

information was made available on the National Park 

Service’s Planning, Environment and Public Comment 

(PEPC) website and project website at www.nps.gov/pwro/

honouliuli. 

In February and March 2011, the study team held eight 

public scoping meetings on the six main islands in Hawaiʻi. 

Over 100 people attended the public meetings. Local, 

state, and federal government officials and stakeholders 

were also consulted. During this time, numerous articles 

and opinion pieces about the study appeared in area 

newspapers. 

The comment period for public scoping extended to 

June 1, 2011, thirty days after publication of the notice of 

scoping in the Federal Register.

Photos: Honouliuli Day of Remembrance, 2011. NPS.
20 Honouliuli Gulch and Associated Sites Draft Special Resource Study & Environmental Assessment 

storage, operations, and maintenance. Possible partners 

include but are not limited to the University of Hawaiʻi—

West O’ahu and the Japanese Cultural Center of Hawaiʻi.

Technical Assistance

Internment sites in Hawai‘i other than Honouliuli 

Internment Camp would continue to be owned and 

managed by their respective public and private owners. 

The associated sites illustrate the broad-reaching effects 

of internment on the six major islands in Hawai‘i and are 

essential in accurately interpreting this history. 

The NPS could work cooperatively with associated 

site owners and managers to explore opportunities for 

interpretation and/or preservation of the associated 

sites. For example, the U.S. Immigration Station played 

a central role in the internment process. Almost every 

person interned passed through the U.S. Immigration 

Station either for initial detention, processing for transfer 

to internment camps on O‘ahu and the mainland, or for 

hearings and trials. The NPS could contribute to further 

evaluation of the U.S. Immigration Station as a national 

historic landmark and explore opportunities to interpret 

its significance through waysides and exhibits.

Where appropriate, the NPS could also conduct research 

and provide assistance to related sites that have yet to be 

identified.

Operations 

Staffing

Management of Honouliuli National Historic Site or 

Monument would be through World War II Valor in the 

Pacific National Monument at Pearl Harbor, given its 

close proximity and related history. Some staff positions 

at World War II Valor in the Pacific National Monument 

would be shared. However, management of the site would 

require additional staff as funding became available. A 

management plan would identify priorities, management 

emphases, and required staffing for a 15- to 20-year 

timeframe. 

Based on comparisons of staffing levels for existing 

national historic sites of similar scale and management 

models, the following types of staff would be 

recommended:

•	 Site manager

•	 Cultural resource specialist 

•	 Interpretive specialist 

•	 Interpretive ranger (2)

•	 Law enforcement ranger

•	 Maintenance (2)

•	 Exotic plant management technician

Positions could be permanent, temporary, or seasonal. 

In addition, partner organizations could provide staff or 

volunteers, with types and numbers dependent upon the 

functions provided. 

Operational and Visitor Facilities

Comprehensive management planning would guide the 

development of facilities for Honouliuli National Historic 

Site or National Monument. Facilities would be needed 

to support public access, circulation, orientation, and 

learning about the history of internment in Hawaiʻi. The 

7-acre overlook site could serve as an excellent location 

for a visitor staging area with ample space to provide 

for parking, visitor drop-off, interpretive features, and 

restrooms. The site is located just outside of the historic 

camp and offers views to Pearl Harbor, downtown 

Honolulu, and Diamond Head. Within the gulch, visitor 

facilities would be minimal to preserve the site’s historic 

integrity. Facilities might include trails, interpretive 

waysides, primitive roads, and vault toilets.

Photos (top to bottom): 1. Entry, former administration building, U.S. 

Immigration Station. 2. View to Pearl Harbor from overlook, Honouliuli. 

Photos: NPS, 2013.
6

Honouliuli Gulch and Associated Sites Draft Special Resource Study & Environmental Assessment 

Internment sites in Hawai‘i during World War II.
18 Honouliuli Gulch and Associated Sites Draft Special Resource Study & Environmental Assessment 

Alternative B: Honouliuli National 

Historic Site or National Monument—A

New Unit of the National Park System

Concept

Congress would establish Honouliuli National Historic 

Site as a new unit of the national park system. Alternatively, 

a national monument managed by the National Park 

Service could be established. The national historic site 

or national monument would include the historic site of 

the Honouliuli Internment Camp and adjacent lands that 

provide road access and opportunities for visitor facilities. 

The National Park Service would preserve the site and 

interpret the internment of Japanese Americans and 

European Americans in Hawaiʻi during World War II. The 

national historic site or monument would be supported 

by operational capacity at World War II Valor in the 

Pacific National Monument, Pearl Harbor. The National 

Park Service could provide technical assistance for the 

preservation and interpretation of other sites, features, and 

stories related to internment in Hawaiʻi during World War 

II. 

Proposed Area

The Honoululi National Historic Site or National 

Monument would total approximately 440 acres. The 

historic Honouliuli Internment Camp and the adjacent 

overlook parcel (approximately 123 acres) would be 

acquired by the NPS through a donation by the Monsanto 

Company. Additional Monsanto-owned lands (31 acres) 

with related resources would be protected through 

conservation easements or land acquisition. Adjacent 

parcels (285 acres), owned by the University of Hawaiʻi, 

would also be included in the boundary of the historic 

site to provide flexibility in establishing public access to 

the site (NPS can only expend funds on roads within an 

authorized boundary unless congressional legislation 

authorizes the use of funding for road maintenance on 

non-federally owned lands). Options for the University 

of Hawaiʻi parcels could include the University of 

Hawaiʻi maintaining ownership of the property, granting 

an easement to the NPS, or transferring ownership to 

the NPS by donation, exchange, or sale. Conservation 

easements could also be obtained for parcels directly 

adjacent to Honouliuli Internment Camp. Future 

development of road Easement 6134 could also provide 

opportunities for site access. All private property rights 

would be respected. 

Several parcels owned by the City and County of Honolulu 

Board of Water Supply would be inholdings within the 

proposed area and would remain under current ownership 

and management. The communications site would not be 

included in the proposed boundary.

Management

The NPS would have direct management responsibility 

for the Honouliuli National Historic Site or National 

Monument including: 1) interpretation and education 

associated with the Honouliuli Internment Camp and 

its resources, including the development of interpretive 

media and programs; 2) resource management for the 

historic site; and 3) operational facilities and infrastructure 

such as roads, restrooms, and trails.

Resource Protection

NPS staff would protect and preserve the resources and 

setting of Honouliuli Internment Camp. Management 

plans would guide appropriate historic preservation 

documentation and treatments. The NPS would seek 

partnership opportunities with existing organizations that 

have conducted research and documentation of the site. 

These include the Japanese Cultural Center of Hawaiʻi, 

which maintains the largest repository of archives and 

collection items related to Honouliuli and the internment 

in Hawai‘i, and the University of Hawaiʻi—West O‘ahu, 

whose faculty and students have been actively involved 

in researching the history of the site and conducting 

archeological field schools at Honouliuli. 

Visitor Experience 

Visitors would have the opportunity to learn about 

Honouliuli Internment Camp, World War II internment 

in Hawaiʻi, martial law, civil liberties, and peace and 

reconciliation through a wide variety of interpretive and 

educational programs onsite and at offsite locations. 

Interpretation would be accessible and relevant to diverse 

audiences and multiple generations. Virtual visitor 

experiences would be explored so that people could learn 

about and experience Honouliuli and related sites without 

actually visiting the sites. Programs could be provided by 

NPS rangers, partners, and volunteers. Information could 

be presented in multiple languages.

Partnerships

The NPS would explore, develop, and maintain 

partnerships for the preservation and interpretation of 

Honouliuli Internment Camp and related sites, features, 

and stories in Hawaiʻi. 

There are substantial opportunities for partnerships 

related to Honouliuli National Historic Site or Monument 

with public agencies, educational institutions, nonprofit 

entities, and individuals. Potential partnership projects 

could include the development of educational programs, 

development of facilities, resource stewardship activities 

such as preservation of historic features and vegetation 

clearing, and research projects. Partnerships could also 

include shared facilities for interpretation, curatorial 
8 Honouliuli Gulch and Associated Sites Draft Special Resource Study & Environmental Assessment 

from mainland incarceration. Through it, we are able to 

more fully understand the abrogation of civil liberties that 

occurred in the U.S. and its territories. 

More than 2,000 residents of Japanese and European 

ancestry living in Hawai‘i were incarcerated in at least 

17 locations in Hawai‘i during World War II, including 

Honouliuli Internment Camp, Sand Island, the U.S. 

Immigration Station, Honolulu Police Department, and 

Honolulu Military Police Station on O‘ahu; the Kilauea 

Military Camp, Waiakea Prison, and the Hilo Independent 

Japanese Language School on the Big Island; Haiku Camp 

and Maui County Jail on Maui; the Kaunakakai Jail on 

Molokai; the Lāna‘i City Jail on Lāna‘i; and the Kalaheo 

Stockade, Waimea Jail, Waialua Jail, Lihue Plantation 

Gymnasium, and Kaua‘i County Courthouse on Kaua‘i.

The 17 internment sites in Hawai‘i were evaluated for 

their role and importance in telling the internment story. 

Based on the findings and analysis in this study, two sites, 

Honouliuli Internment Camp and the U.S. Immigration 

Station, are found to be nationally significant as defined in 

the NHL guidelines. 

Honouliuli Internment Camp (Waipahu, 

O‘ahu)

The Honouliuli Interment Camp was located in Honouliuli 

Gulch, west of Waipahu, on the island of O‘ahu. Opened 

in 1943, the Honouliuli Internment Camp was the last, 

largest, and longest-used World War II confinement site 

in Hawai‘i. The camp was built to intern Japanese and 

European Americans, Japanese and European resident 

aliens, and POWs captured in military operations during 

World War II. Honouliuli Internment Camp, protected by 

its isolated location amidst agricultural lands and nearly 

hidden by dense vegetation for 60 years, appears to offer 

the greatest potential to preserve resources and interpret 

the history of the WWII internment. 

The internment camp held 320 internees, mostly secondgeneration Japanese Americans, but also Japanese, 

German, and Italian nationals. It was also the largest 

prisoner of war camp in Hawai‘i, incarcerating nearly 4,000 

individuals. Recent archeological surveys have resulted in 

the identification of over 130 archeological features. 

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

Dan Toru Nishikawa Family Collection.
16 Honouliuli Gulch and Associated Sites Draft Special Resource Study & Environmental Assessment 

Table 1: Existing Management of Sites Evaluated in the Study

Site Site Type and 

Location

Ownership and 

Management

Current Visitor Opportunities 

or Interpretation 

Nationally Significant Sites

Honouliuli Internment 

Camp

Primary, O‘ahu Private Currently not accessible to the 

general public. Site tours and 

use for educational purposes 

occur on occasion with 

landowner permission.

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

Homeland Security and 

Hawaiʻi Department of 

Public Health

None. Currently not accessible 

to the general public.

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

Kauaʻi County 

Courthouse

Secondary, Kauaʻi Public, County of Kauaʻi None

Kilauea Military Camp Primary, Island of 

Hawaiʻi

Public, National Park 

Service

Active military recreation camp. 

However, opportunities for 

interpretation exist.

Maui County Jail, 

Courthouse, and Police 

Station

Primary, Maui Public, Maui County None

Yokohama Specie Bank Secondary, O‘ahu Private None

Lānaʻi City Jail and 

Courthouse

Secondary, Lānaʻi Private None

Potentially Significant Sites—Additional Research Needed

Waiakea Prison Camp Secondary, Island of 

Hawaiʻi

Exact Location Unknown None

Hilo Independent 

Japanese Language School

Secondary, Island of 

Hawaiʻi

Unknown None

Lihue Plantation 

Gymnasium 

Secondary, Kauaʻi Privately owned structure 

adjacent to Isenberg Park

None

Kalaheo Stockade Primary, Kauaʻi Private None

Haiku Military Camp Secondary, Maui Private None

Other Related Sites—No Integrity Remaining

Sand Island Detention 

Camp

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

Wailua Jail Kaua‘i Public None/Non-Extant

Waimea Jail Kaua‘i Public None/Non-Extant

Kaunakakai Jail and 

Courthouse

Molokai Public None/Non-Extant

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

are those that were used as prisons for fewer prisoners, usually for shorter periods of time. Also included in the 

“secondary” category are sites where no internees were imprisoned, but where activities related to the internment 

occurred, such as hearings. 
10 Honouliuli Gulch and Associated Sites Draft Special Resource Study & Environmental Assessment 

U.S. Immigration Station (Honolulu, O‘ahu) 

The U.S. Immigration Station, located on Ala Moana 

Boulevard in Honolulu, is nationally significant as the 

location where all Hawai‘i internees were processed 

or temporarily incarcerated after the attack on Pearl 

Harbor on December 7, 1941. Unlike most of the other 

internment sites in Hawai‘i that only served local, shortterm needs, the U.S. Immigration Station had a broad, 

statewide role over an extended period. It served as a 

temporary internment location, but also as a center of legal 

administration.

Other Internment Sites in Hawai‘i

The other 15 sites associated with internment considered 

in this study were used for shorter periods of time, 

interned fewer numbers of people, or have been 

substantially changed since the period of significance. 

As such, they do not meet the criteria for national 

significance as defined in the special resource study and 

national historic landmark criteria. Many of these sites 

are, however, listed or eligible for listing in the National 

Register of Historic Places and/or provide opportunities to 

further interpret the story of internment and incarceration 

in the U.S. during World War II.

Suitability 

To be considered suitable for addition to the national 

park system, an area must represent a natural or cultural 

resource type that is not already adequately represented in 

the national park system, or is not comparably represented 

and protected for public enjoyment by other federal 

agencies; tribal, state, or local governments; or the private 

sector. 

Adequacy of representation is determined for nationally 

significant sites on a case-by-case basis by comparing the 

potential addition to other comparably managed areas 

representing the same resource type, while considering 

differences or similarities in the character, quality, quantity, 

or combination of resource values. The comparative 

analysis also addresses rarity of the resources, interpretive 

and educational potential, and similar resources already 

protected in the national park system or in other public or 

private ownership. The analysis results in a determination 

of whether the proposed new area would expand, 

enhance, or duplicate resource protection or visitor use 

opportunities found in other comparably managed areas. 

Honouliuli Internment Camp and the U.S. Immigration 

Station offer a special opportunity to expand our nation’s 

history of incarceration of civilians during World War 

II. The educational potential of these sites is enhanced 

by their quality, or high level of integrity, as well as 

the quantity of their extant resources. Based on the 

analysis of comparable resources and interpretation 

already represented in units of the national park system, 

or protected and interpreted by others, this study 

concludes that Honouliuli Internment Camp and the U.S. 

Immigration Station associated with the incarceration of 

civilians and prisoners of war in Hawaiʻi during World 

War II depict a distinct and important aspect of American 

history associated with civil liberties in times of conflict 

that is not adequately represented or protected elsewhere, 

and are therefore suitable for inclusion in the national park 

system.

Feasibility 

To be feasible as a new unit of the national park system, 

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

configuration to ensure sustainable resource protection 

and visitor enjoyment (taking into account current and 

potential impacts from sources beyond proposed park 

boundaries), and (2) capable of efficient administration by 

the National Park Service at a reasonable cost. 

In evaluating feasibility, the NPS considers a variety of 

factors for a study area, such as the following:

•	 Land use, current and potential site uses, ownership 

patterns, planning and zoning

•	 Access and public enjoyment potential

•	 Boundary size and configuration

•	 Existing resource degradation and threats to resources

•	 Public interest and support

•	 Social and economic impact 

•	 Costs associated with operation, acquisition, 

development, and restoration

Summer archeological field school, Honouliuli. Photo: Jeffery Burton.
14 Honouliuli Gulch and Associated Sites Draft Special Resource Study & Environmental Assessment 

Alternatives

The following section describes a range of management 

alternatives that are being considered by the National Park 

Service as part of the special resource study.

Overview of the Alternatives 

The study team developed two alternatives based on 

information gathered from public and stakeholder input, 

internal NPS discussions, evaluation of special resource 

study criteria, historical research, and NPS management 

models. The two alternatives considered are a “no action” 

alternative, which serves as a baseline for comparison, 

and an “action” alternative, which is also the preferred 

alternative. 

•	 Alternative A: Continuation of Current Management 

(No Action)

•	 Alternative B: Honouliuli National Historic Site or 

Monument—A Unit of the National Park System

For each alternative there is a description of the overall 

concept and key elements of the alternative, including 

management approaches, resource protection, visitor 

services, and the role of organizations and public agencies. 

Alternative A: Continuation of Current 

Management (No Action Alternative)

Concept

Sites, organizations, and programs significant to the 

internment history in Hawaiʻi would continue to operate 

independently by existing landowners, agencies, or 

organizations without additional NPS management or 

assistance other than what is currently available through 

existing authorities and grant programs.

Management of Sites Related to Internment 

Sites related to World War II internment in Hawai‘i 

would continue to be managed separately by their public 

and private landowners. With the exception of Kilauea 

Military Camp at Hawaiʻi Volcanoes National Park, there 

would be no NPS staffing or operational support at sites 

identified in the study other than technical assistance 

under existing authorities if requested. Organizations and 

programs devoted to commemorating and preserving 

Hawaiʻi’s internment history would continue to operate 

independently without NPS management or assistance 

other than that available through existing authorities. Table 

Students in a summer archeology course at the University of Hawai‘i—West O‘ahu conduct fieldwork at Honouliuli. Photo: Valentino Valdez.
12 Honouliuli Gulch and Associated Sites Draft Special Resource Study & Environmental Assessment 

The feasibility evaluation also considers the ability of the 

NPS to undertake new management responsibilities in 

light of current and projected availability of funding and 

personnel. An overall evaluation of feasibility is made after 

taking into account all of the above factors. 

Some management options are more feasible than others. 

The national park system includes many types of sites, and 

a range of ownership and management approaches. The 

NPS also offers grant and technical assistance programs 

that help local communities achieve their goals for 

conservation and recreation.

The feasibility analysis focuses on the two sites that have 

been found nationally significant, Honouliuli Internment 

Camp and the U.S. Immigration Station. 

The NPS finds that Honouliuli Internment Camp is 

feasible as an addition to the national park system as long 

as public access to the site can be secured. Current land 

use, ownership patterns, and zoning associated with 

Honouliuli Internment Camp would not conflict with 

management of a national park unit. Primary resources 

associated with the camp are located on property owned 

by the Monsanto Company, which has expressed interest 

in donating the property to the NPS for establishment 

of a national park unit. Surrounding lands are currently 

in agricultural use which is compatible with the camp’s 

historic setting. However, feasibility is conditional on 

securing public access to the site. As current access is 

primarily over unpaved agricultural roads, improvements 

would be needed to accommodate access by the general 

public. An appropriate boundary configuration would 

include the historic site and lands sufficient to provide site 

access and public staging facilities such as parking areas.

There are no current threats to Honouliuli Internment 

Camp that would preclude management as a unit of 

the national park system. Honouliuli Internment Camp 

contains resources with integrity sufficient for national 

historic landmark designation and NPS designation.

Outreach for this study has demonstrated significant public 

interest and support for an NPS park unit at Honouliuli 

Gulch in partnership with other organizations and local 

communities. The social and economic impacts of NPS 

designation or other support/coordination roles appear to 

be largely beneficial and would support the feasibility of 

NPS designation.

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

The feasibility evaluation also considers the ability of the 

NPS to undertake new management responsibilities in 

light of current and projected availability of funding and 

personnel. An overall evaluation of feasibility is made after 

taking into account all of the above factors. 

Some management options are more feasible than others. 

The national park system includes many types of sites, and 

a range of ownership and management approaches. The 

NPS also offers grant and technical assistance programs 

that help local communities achieve their goals for 

conservation and recreation.

The feasibility analysis focuses on the two sites that have 

been found nationally significant, Honouliuli Internment 

Camp and the U.S. Immigration Station. 

The NPS finds that Honouliuli Internment Camp is 

feasible as an addition to the national park system as long 

as public access to the site can be secured. Current land 

use, ownership patterns, and zoning associated with 

Honouliuli Internment Camp would not conflict with 

management of a national park unit. Primary resources 

associated with the camp are located on property owned 

by the Monsanto Company, which has expressed interest 

in donating the property to the NPS for establishment 

of a national park unit. Surrounding lands are currently 

in agricultural use which is compatible with the camp’s 

historic setting. However, feasibility is conditional on 

securing public access to the site. As current access is 

primarily over unpaved agricultural roads, improvements 

would be needed to accommodate access by the general 

public. An appropriate boundary configuration would 

include the historic site and lands sufficient to provide site 

access and public staging facilities such as parking areas.

There are no current threats to Honouliuli Internment 

Camp that would preclude management as a unit of 

the national park system. Honouliuli Internment Camp 

contains resources with integrity sufficient for national 

historic landmark designation and NPS designation.

Outreach for this study has demonstrated significant public 

interest and support for an NPS park unit at Honouliuli 

Gulch in partnership with other organizations and local 

communities. The social and economic impacts of NPS 

designation or other support/coordination roles appear to 

be largely beneficial and would support the feasibility of 

NPS designation.

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

Alternatives

The following section describes a range of management 

alternatives that are being considered by the National Park 

Service as part of the special resource study.

Overview of the Alternatives 

The study team developed two alternatives based on 

information gathered from public and stakeholder input, 

internal NPS discussions, evaluation of special resource 

study criteria, historical research, and NPS management 

models. The two alternatives considered are a “no action” 

alternative, which serves as a baseline for comparison, 

and an “action” alternative, which is also the preferred 

alternative. 

•	 Alternative A: Continuation of Current Management 

(No Action)

•	 Alternative B: Honouliuli National Historic Site or 

Monument—A Unit of the National Park System

For each alternative there is a description of the overall 

concept and key elements of the alternative, including 

management approaches, resource protection, visitor 

services, and the role of organizations and public agencies. 

Alternative A: Continuation of Current 

Management (No Action Alternative)

Concept

Sites, organizations, and programs significant to the 

internment history in Hawaiʻi would continue to operate 

independently by existing landowners, agencies, or 

organizations without additional NPS management or 

assistance other than what is currently available through 

existing authorities and grant programs.

Management of Sites Related to Internment 

Sites related to World War II internment in Hawai‘i 

would continue to be managed separately by their public 

and private landowners. With the exception of Kilauea 

Military Camp at Hawaiʻi Volcanoes National Park, there 

would be no NPS staffing or operational support at sites 

identified in the study other than technical assistance 

under existing authorities if requested. Organizations and 

programs devoted to commemorating and preserving 

Hawaiʻi’s internment history would continue to operate 

independently without NPS management or assistance 

other than that available through existing authorities. Table 

Students in a summer archeology course at the University of Hawai‘i—West O‘ahu conduct fieldwork at Honouliuli. Photo: Valentino Valdez.
10 Honouliuli Gulch and Associated Sites Draft Special Resource Study & Environmental Assessment 

U.S. Immigration Station (Honolulu, O‘ahu) 

The U.S. Immigration Station, located on Ala Moana 

Boulevard in Honolulu, is nationally significant as the 

location where all Hawai‘i internees were processed 

or temporarily incarcerated after the attack on Pearl 

Harbor on December 7, 1941. Unlike most of the other 

internment sites in Hawai‘i that only served local, shortterm needs, the U.S. Immigration Station had a broad, 

statewide role over an extended period. It served as a 

temporary internment location, but also as a center of legal 

administration.

Other Internment Sites in Hawai‘i

The other 15 sites associated with internment considered 

in this study were used for shorter periods of time, 

interned fewer numbers of people, or have been 

substantially changed since the period of significance. 

As such, they do not meet the criteria for national 

significance as defined in the special resource study and 

national historic landmark criteria. Many of these sites 

are, however, listed or eligible for listing in the National 

Register of Historic Places and/or provide opportunities to 

further interpret the story of internment and incarceration 

in the U.S. during World War II.

Suitability 

To be considered suitable for addition to the national 

park system, an area must represent a natural or cultural 

resource type that is not already adequately represented in 

the national park system, or is not comparably represented 

and protected for public enjoyment by other federal 

agencies; tribal, state, or local governments; or the private 

sector. 

Adequacy of representation is determined for nationally 

significant sites on a case-by-case basis by comparing the 

potential addition to other comparably managed areas 

representing the same resource type, while considering 

differences or similarities in the character, quality, quantity, 

or combination of resource values. The comparative 

analysis also addresses rarity of the resources, interpretive 

and educational potential, and similar resources already 

protected in the national park system or in other public or 

private ownership. The analysis results in a determination 

of whether the proposed new area would expand, 

enhance, or duplicate resource protection or visitor use 

opportunities found in other comparably managed areas. 

Honouliuli Internment Camp and the U.S. Immigration 

Station offer a special opportunity to expand our nation’s 

history of incarceration of civilians during World War 

II. The educational potential of these sites is enhanced 

by their quality, or high level of integrity, as well as 

the quantity of their extant resources. Based on the 

analysis of comparable resources and interpretation 

already represented in units of the national park system, 

or protected and interpreted by others, this study 

concludes that Honouliuli Internment Camp and the U.S. 

Immigration Station associated with the incarceration of 

civilians and prisoners of war in Hawaiʻi during World 

War II depict a distinct and important aspect of American 

history associated with civil liberties in times of conflict 

that is not adequately represented or protected elsewhere, 

and are therefore suitable for inclusion in the national park 

system.

Feasibility 

To be feasible as a new unit of the national park system, 

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

configuration to ensure sustainable resource protection 

and visitor enjoyment (taking into account current and 

potential impacts from sources beyond proposed park 

boundaries), and (2) capable of efficient administration by 

the National Park Service at a reasonable cost. 

In evaluating feasibility, the NPS considers a variety of 

factors for a study area, such as the following:

•	 Land use, current and potential site uses, ownership 

patterns, planning and zoning

•	 Access and public enjoyment potential

•	 Boundary size and configuration

•	 Existing resource degradation and threats to resources

•	 Public interest and support

•	 Social and economic impact 

•	 Costs associated with operation, acquisition, 

development, and restoration

Summer archeological field school, Honouliuli. Photo: Jeffery Burton.
16 Honouliuli Gulch and Associated Sites Draft Special Resource Study & Environmental Assessment 

Table 1: Existing Management of Sites Evaluated in the Study

Site Site Type and 

Location

Ownership and 

Management

Current Visitor Opportunities 

or Interpretation 

Nationally Significant Sites

Honouliuli Internment 

Camp

Primary, O‘ahu Private Currently not accessible to the 

general public. Site tours and 

use for educational purposes 

occur on occasion with 

landowner permission.

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

Homeland Security and 

Hawaiʻi Department of 

Public Health

None. Currently not accessible 

to the general public.

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

Honolulu Police 

Department

Secondary, O‘ahu Public, City and County of 

Honolulu

None

Kauaʻi County 

Courthouse

Secondary, Kauaʻi Public, County of Kauaʻi None

Kilauea Military Camp Primary, Island of 

Hawaiʻi

Public, National Park 

Service

Active military recreation camp. 

However, opportunities for 

interpretation exist.

Maui County Jail, 

Courthouse, and Police 

Station

Primary, Maui Public, Maui County None

Yokohama Specie Bank Secondary, O‘ahu Private None

Lānaʻi City Jail and 

Courthouse

Secondary, Lānaʻi Private None

Potentially Significant Sites—Additional Research Needed

Waiakea Prison Camp Secondary, Island of 

Hawaiʻi

Exact Location Unknown None

Hilo Independent 

Japanese Language School

Secondary, Island of 

Hawaiʻi

Unknown None

Lihue Plantation 

Gymnasium 

Secondary, Kauaʻi Privately owned structure 

adjacent to Isenberg Park

None

Kalaheo Stockade Primary, Kauaʻi Private None

Haiku Military Camp Secondary, Maui Private None

Other Related Sites—No Integrity Remaining

Sand Island Detention 

Camp

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

Wailua Jail Kaua‘i Public None/Non-Extant

Waimea Jail Kaua‘i Public None/Non-Extant

Kaunakakai Jail and 

Courthouse

Molokai Public None/Non-Extant

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

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

are sites where no internees were imprisoned, but where activities related to the internment occurred, such as hearings. 

Note: The Honolulu Police Department was inadvertently omitted from the printed versions of this table in the newsletter 

and draft report.
8 Honouliuli Gulch and Associated Sites Draft Special Resource Study & Environmental Assessment 

from mainland incarceration. Through it, we are able to 

more fully understand the abrogation of civil liberties that 

occurred in the U.S. and its territories. 

More than 2,000 residents of Japanese and European 

ancestry living in Hawai‘i were incarcerated in at least 

17 locations in Hawai‘i during World War II, including 

Honouliuli Internment Camp, Sand Island, the U.S. 

Immigration Station, Honolulu Police Department, and 

Honolulu Military Police Station on O‘ahu; the Kilauea 

Military Camp, Waiakea Prison, and the Hilo Independent 

Japanese Language School on the Big Island; Haiku Camp 

and Maui County Jail on Maui; the Kaunakakai Jail on 

Molokai; the Lāna‘i City Jail on Lāna‘i; and the Kalaheo 

Stockade, Waimea Jail, Waialua Jail, Lihue Plantation 

Gymnasium, and Kaua‘i County Courthouse on Kaua‘i.

The 17 internment sites in Hawai‘i were evaluated for 

their role and importance in telling the internment story. 

Based on the findings and analysis in this study, two sites, 

Honouliuli Internment Camp and the U.S. Immigration 

Station, are found to be nationally significant as defined in 

the NHL guidelines. 

Honouliuli Internment Camp (Waipahu, 

O‘ahu)

The Honouliuli Interment Camp was located in Honouliuli 

Gulch, west of Waipahu, on the island of O‘ahu. Opened 

in 1943, the Honouliuli Internment Camp was the last, 

largest, and longest-used World War II confinement site 

in Hawai‘i. The camp was built to intern Japanese and 

European Americans, Japanese and European resident 

aliens, and POWs captured in military operations during 

World War II. Honouliuli Internment Camp, protected by 

its isolated location amidst agricultural lands and nearly 

hidden by dense vegetation for 60 years, appears to offer 

the greatest potential to preserve resources and interpret 

the history of the WWII internment. 

The internment camp held 320 internees, mostly secondgeneration Japanese Americans, but also Japanese, 

German, and Italian nationals. It was also the largest 

prisoner of war camp in Hawai‘i, incarcerating nearly 4,000 

individuals. Recent archeological surveys have resulted in 

the identification of over 130 archeological features. 

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

Dan Toru Nishikawa Family Collection.
18 Honouliuli Gulch and Associated Sites Draft Special Resource Study & Environmental Assessment 

Alternative B: Honouliuli National 

Historic Site or National Monument—A

New Unit of the National Park System

Concept

Congress would establish Honouliuli National Historic 

Site as a new unit of the national park system. Alternatively, 

a national monument managed by the National Park 

Service could be established. The national historic site 

or national monument would include the historic site of 

the Honouliuli Internment Camp and adjacent lands that 

provide road access and opportunities for visitor facilities. 

The National Park Service would preserve the site and 

interpret the internment of Japanese Americans and 

European Americans in Hawaiʻi during World War II. The 

national historic site or monument would be supported 

by operational capacity at World War II Valor in the 

Pacific National Monument, Pearl Harbor. The National 

Park Service could provide technical assistance for the 

preservation and interpretation of other sites, features, and 

stories related to internment in Hawaiʻi during World War 

II. 

Proposed Area

The Honoululi National Historic Site or National 

Monument would total approximately 440 acres. The 

historic Honouliuli Internment Camp and the adjacent 

overlook parcel (approximately 123 acres) would be 

acquired by the NPS through a donation by the Monsanto 

Company. Additional Monsanto-owned lands (31 acres) 

with related resources would be protected through 

conservation easements or land acquisition. Adjacent 

parcels (285 acres), owned by the University of Hawaiʻi, 

would also be included in the boundary of the historic 

site to provide flexibility in establishing public access to 

the site (NPS can only expend funds on roads within an 

authorized boundary unless congressional legislation 

authorizes the use of funding for road maintenance on 

non-federally owned lands). Options for the University 

of Hawaiʻi parcels could include the University of 

Hawaiʻi maintaining ownership of the property, granting 

an easement to the NPS, or transferring ownership to 

the NPS by donation, exchange, or sale. Conservation 

easements could also be obtained for parcels directly 

adjacent to Honouliuli Internment Camp. Future 

development of road Easement 6134 could also provide 

opportunities for site access. All private property rights 

would be respected. 

Several parcels owned by the City and County of Honolulu 

Board of Water Supply would be inholdings within the 

proposed area and would remain under current ownership 

and management. The communications site would not be 

included in the proposed boundary.

Management

The NPS would have direct management responsibility 

for the Honouliuli National Historic Site or National 

Monument including: 1) interpretation and education 

associated with the Honouliuli Internment Camp and 

its resources, including the development of interpretive 

media and programs; 2) resource management for the 

historic site; and 3) operational facilities and infrastructure 

such as roads, restrooms, and trails.

Resource Protection

NPS staff would protect and preserve the resources and 

setting of Honouliuli Internment Camp. Management 

plans would guide appropriate historic preservation 

documentation and treatments. The NPS would seek 

partnership opportunities with existing organizations that 

have conducted research and documentation of the site. 

These include the Japanese Cultural Center of Hawaiʻi, 

which maintains the largest repository of archives and 

collection items related to Honouliuli and the internment 

in Hawai‘i, and the University of Hawaiʻi—West O‘ahu, 

whose faculty and students have been actively involved 

in researching the history of the site and conducting 

archeological field schools at Honouliuli. 

Visitor Experience 

Visitors would have the opportunity to learn about 

Honouliuli Internment Camp, World War II internment 

in Hawaiʻi, martial law, civil liberties, and peace and 

reconciliation through a wide variety of interpretive and 

educational programs onsite and at offsite locations. 

Interpretation would be accessible and relevant to diverse 

audiences and multiple generations. Virtual visitor 

experiences would be explored so that people could learn 

about and experience Honouliuli and related sites without 

actually visiting the sites. Programs could be provided by 

NPS rangers, partners, and volunteers. Information could 

be presented in multiple languages.

Partnerships

The NPS would explore, develop, and maintain 

partnerships for the preservation and interpretation of 

Honouliuli Internment Camp and related sites, features, 

and stories in Hawaiʻi. 

There are substantial opportunities for partnerships 

related to Honouliuli National Historic Site or Monument 

with public agencies, educational institutions, nonprofit 

entities, and individuals. Potential partnership projects 

could include the development of educational programs, 

development of facilities, resource stewardship activities 

such as preservation of historic features and vegetation 

clearing, and research projects. Partnerships could also 

include shared facilities for interpretation, curatorial 
6

Honouliuli Gulch and Associated Sites Draft Special Resource Study & Environmental Assessment 

Internment sites in Hawai‘i during World War II.
20 Honouliuli Gulch and Associated Sites Draft Special Resource Study & Environmental Assessment 

storage, operations, and maintenance. Possible partners 

include but are not limited to the University of Hawaiʻi—

West O’ahu and the Japanese Cultural Center of Hawaiʻi.

Technical Assistance

Internment sites in Hawai‘i other than Honouliuli 

Internment Camp would continue to be owned and 

managed by their respective public and private owners. 

The associated sites illustrate the broad-reaching effects 

of internment on the six major islands in Hawai‘i and are 

essential in accurately interpreting this history. 

The NPS could work cooperatively with associated 

site owners and managers to explore opportunities for 

interpretation and/or preservation of the associated 

sites. For example, the U.S. Immigration Station played 

a central role in the internment process. Almost every 

person interned passed through the U.S. Immigration 

Station either for initial detention, processing for transfer 

to internment camps on O‘ahu and the mainland, or for 

hearings and trials. The NPS could contribute to further 

evaluation of the U.S. Immigration Station as a national 

historic landmark and explore opportunities to interpret 

its significance through waysides and exhibits.

Where appropriate, the NPS could also conduct research 

and provide assistance to related sites that have yet to be 

identified.

Operations 

Staffing

Management of Honouliuli National Historic Site or 

Monument would be through World War II Valor in the 

Pacific National Monument at Pearl Harbor, given its 

close proximity and related history. Some staff positions 

at World War II Valor in the Pacific National Monument 

would be shared. However, management of the site would 

require additional staff as funding became available. A 

management plan would identify priorities, management 

emphases, and required staffing for a 15- to 20-year 

timeframe. 

Based on comparisons of staffing levels for existing 

national historic sites of similar scale and management 

models, the following types of staff would be 

recommended:

•	 Site manager

•	 Cultural resource specialist 

•	 Interpretive specialist 

•	 Interpretive ranger (2)

•	 Law enforcement ranger

•	 Maintenance (2)

•	 Exotic plant management technician

Positions could be permanent, temporary, or seasonal. 

In addition, partner organizations could provide staff or 

volunteers, with types and numbers dependent upon the 

functions provided. 

Operational and Visitor Facilities

Comprehensive management planning would guide the 

development of facilities for Honouliuli National Historic 

Site or National Monument. Facilities would be needed 

to support public access, circulation, orientation, and 

learning about the history of internment in Hawaiʻi. The 

7-acre overlook site could serve as an excellent location 

for a visitor staging area with ample space to provide 

for parking, visitor drop-off, interpretive features, and 

restrooms. The site is located just outside of the historic 

camp and offers views to Pearl Harbor, downtown 

Honolulu, and Diamond Head. Within the gulch, visitor 

facilities would be minimal to preserve the site’s historic 

integrity. Facilities might include trails, interpretive 

waysides, primitive roads, and vault toilets.

Photos (top to bottom): 1. Entry, former administration building, U.S. 

Immigration Station. 2. View to Pearl Harbor from overlook, Honouliuli. 

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

Environmental Policy Act process for this special resource 

study. No significant impacts or effects are anticipated from 

the findings and recommendations of this study.

According to NPS management policies, a proposed 

addition to the national park system will receive a favorable 

recommendation from the NPS only if it meets all of the 

following four criteria for inclusion:

•	 it possesses nationally significant natural or cultural 

resources;

•	 it is a suitable addition to the system;

•	 it is a feasible addition to the system; and

•	 it requires direct NPS management, instead of 

alternative protection by other public agencies or the 

private sector.

These criteria are designed to ensure that the national park 

system includes only the most outstanding examples of the 

nation’s natural and cultural resources, while recognizing 

that there are other management alternatives for preserving 

the nation’s outstanding resources.

Alternatives for NPS management are developed for sites 

that meet all four of the criteria for inclusion.

Public Involvement

Public Scoping

The NPS launched public scoping for this study in 

February 2011. A notice of scoping was published in 

the Federal Register on May 2, 2011 (Vol.76, No. 83, 

24514–15). The study team produced and distributed an 

informational newsletter and press releases to the media, 

individuals, organizations, and government officials. Public 

information was made available on the National Park 

Service’s Planning, Environment and Public Comment 

(PEPC) website and project website at www.nps.gov/pwro/

honouliuli. 

In February and March 2011, the study team held eight 

public scoping meetings on the six main islands in Hawaiʻi. 

Over 100 people attended the public meetings. Local, 

state, and federal government officials and stakeholders 

were also consulted. During this time, numerous articles 

and opinion pieces about the study appeared in area 

newspapers. 

The comment period for public scoping extended to 

June 1, 2011, thirty days after publication of the notice of 

scoping in the Federal Register.

Photos: Honouliuli Day of Remembrance, 2011. NPS.
22 Honouliuli Gulch and Associated Sites Draft Special Resource Study & Environmental Assessment 

Environmentally Preferred

Alternative

The NPS is required to identify an “environmentally 

preferred alternative” in an EA. The environmentally 

preferable alternative is determined by applying the 

criteria suggested in the National Environmental 

Policy Act (NEPA) of 1969 and is further guided by the 

Council on Environmental Quality (CEQ). The CEQ 

(46 FR 18026 - 46 FR 18038) provides direction that the 

“environmentally preferable alternative is the alternative 

that would promote the national environmental policy as 

expressed in NEPA’s Section 101,” including: 

•	 Fulfill the responsibilities of each generation as trustee 

of the environment for succeeding generations;

•	 Assure for all Americans safe, healthful, productive, 

and aesthetically and culturally pleasing surroundings;

•	 Attain the widest range of beneficial uses of the 

environment without degradation, risk of health 

or safety, or other undesirable and unintended 

consequences;

alternative. The analysis includes consideration of the 

context, intensity, and duration of direct and indirect 

effects of all the alternatives. 

The NPS based analysis and conclusions on a review 

of existing literature, information provided by experts 

within the NPS as well as outside organizations, analysis 

of case studies of existing programs in other locations, 

and the professional judgment of the team members. 

The findings of this study will inform a recommendation 

by the Secretary of the Interior to Congress. If Congress 

takes action, then new environmental analysis would be 

undertaken prior to implementation actions. This new 

analysis would propose specific actions whose specific 

impacts would be assessed prior to implementation.

The NPS evaluated the environmental consequences 

of each alternative on the following topics: land use, 

water resources, vegetation, prehistoric and historic 

archeological resources, historic structures / cultural 

landscapes, museum collections, visitor experience, and 

socioeconomics.

The NPS finds that there would be no significant impacts 

associated with the proposed alternatives.

Aerial view of Honouliuli Gulch looking south, showing both Monsanto lands (left) and University of Hawai‘i—West O‘ahu lands (right). Board of Water 

Supply facilities are visible in the foreground. Photo: Monsanto Company.
2 Honouliuli Gulch and Associated Sites Draft Special Resource Study & Environmental Assessment 

Abstract

The National Park Service (NPS) prepared the Honouliuli 

Gulch and Associated Sites Draft Special Resource Study 

and Environmental Assessment to determine whether the 

Honouliuli Internment Camp and associated World War 

II internment sites in Hawai‘i are nationally significant, 

suitable, and feasible for inclusion in the national park 

system. Congress authorized this study in 2009. The study 

evaluates 17 sites.

Through the special resource study process, the NPS made 

the following determinations about the study sites:

•	 The Honouliuli Internment Camp and the U.S. 

Immigration Station on the island of O‘ahu are 

nationally significant for their central role as 

internment sites in Hawai‘i during World War II. 

They meet all four of the NPS criteria for national 

significance. The other 15 sites associated were used 

for shorter periods of time, interned fewer numbers 

of people, or have been substantially changed since 

the period of significance. As such, they do not meet 

the criteria for national significance. Many of these 

sites are, however, listed or eligible for listing in the 

National Register of Historic Places and/or provide 

opportunities to further interpret the history of 

internment in Hawai‘i during World War II.

•	 The Honouliuli Internment Camp and the U.S. 

Immigration Station depict a distinct and important 

aspect of American history associated with civil 

liberties in times of conflict that is not adequately 

represented or protected elsewhere, and are therefore 

suitable for inclusion in the national park system.

•	 The Honouliuli Internment Camp historic site is 

a feasible addition to the national park system 

conditional upon securing public access to the site. 

The U.S. Immigration Station complex is not a feasible 

addition to the national park system because the 

complex is currently used by the U.S. Department 

of Homeland Security and the State of Hawai‘i 

Department of Health.

•	 There is a need for NPS management of the 

Honouliuli Internment Camp historic site in 

partnership with others to fully protect resources 

and to enhance visitor appreciation of the nationally 

significant resources and important stories associated 

with it.

The NPS evaluated two alternatives in the draft study. One 

includes a role for the NPS.

Alternative A: Continuation of Management. This is the 

“no action” alternative. Sites, organizations, and programs 

significant to the internment history in Hawaiʻi would 

continue to operate independently by existing landowners, 

agencies, or organizations without additional NPS 

management or assistance other than what is currently 

available through existing authorities and grant programs.

Alternative B: Honouliuli National Historic Site or 

Monument–A Unit of the National Park System. 

Congress would establish Honouliuli National 

Historic Site as a new unit of the national park system. 

Alternatively, a national monument managed by the 

NPS could be established. The national historic site or 

national monument would include the historic site of 

the Honouliuli Internment Camp and adjacent lands 

that provide road access and opportunities for visitor 

facilities. The NPS would preserve the site and interpret 

the internment of Japanese Americans and European 

Americans in Hawaiʻi during World War II. The national 

historic site or monument would be supported by 

operational capacity at World War II Valor in the Pacific 

National Monument, Pearl Harbor. The NPS could 

provide technical assistance for the preservation and 

interpretation of other sites, features, and stories related to 

internment in Hawaiʻi during World War II. 

The NPS prepared an environmental assessment to 

identify and analyze the potential environmental and 

socioeconomic consequences of the two alternatives. 

The NPS concluded that alternative B would be the 

environmentally preferable alternative because it 

would protect nationally significant resources, provide 

opportunities for visitors to learn about the internment 

history in Hawai‘i during World War II, provide greater 

socioeconomic benefits, and apply long-standing NPS 

policies and actions to the Honouliuli Internment Camp 

historic site. 

Remaining World War II-era structure, Honouliuli Internment Camp. Photo: 

Valentino Valdez.
How to provide comments

This draft study report is available for public review 

and comment until July 15, 2014. We welcome your 

thoughts through email, our website, mail, or at one of 

the public meetings that we are hosting. Your comments 

will help us revise and finalize this report and will 

inform the recommendation that is made to Congress 

as part of this report. Thank you for your thoughtful 

feedback.

Mail: National Park Service

 Honouliuli Gulch and Associated Sites SRS

 Park Planning & Environmental Compliance

 909 First Avenue, Suite 548

 Seattle, WA 98104

Email: pwr_honouliuli@nps.gov

Website: http://www.nps.gov/pwro/honouliuli

Phone: Honolulu Office

 National Park Service, Pacific West Region

 (808) 541-2693

 Special Resource Study Project Leads:

 Anna Tamura, (206) 220-4157 

 Barbara Butler Baunsgard, (415) 623-2311

Detail, sketch of internees working on crafts at Honouliuli by Dan T. Nishikawa, 

April 29,1943. Courtesy of the Japanese Cultural Center of Hawai‘i, Dan Toru 

Nishikawa Family Collection.

PWRO 963 / 124441/ May 2014 

Printed on post-consumer recycled paper with 

soy-based inks.

you’re invited to a Public meeting! 

Please join us for a public meeting to share your 

comments relating to this draft special resource study 

and environmental assessment. We look forward to 

seeing and hearing from you! 

24 Honouliuli Gulch and Associated Sites Draft Special Resource Study & Environmental Assessment 

Tuesday, May 27, 2–4 pm 

KAPOLEI, o‘ahu

Lab Building E132, University of Hawai‘i—West O‘ahu 

91–1001 Farrington Highway

Wednesday, May 28, 6–8 pm 

Thursday, May 29, 10 am–noon

HONOlulu, o‘ahu

Japanese Cultural Center of Hawai‘i

2454 S Beretania Street, #101

Thursday, May 29, 6:30–8:30 pm 

lÏhu‘e, Kaua‘I

Līhu‘e Neighborhood Center

3353 Eono Street

Monday, June 2, 10 am–noon 

kaunakakai, molokai

Kaunakakai Elementary School Cafeteria

Ailoa Street

Monday, June 2, 6–8 pm

kahului, maui

Alexa Higashi Room, Maui Arts and Cultural Center

One Cameron Way

Tuesday, June 3, 2–4 pm 

lĀna‘I city, lĀna‘I

The Lāna‘i Senior Center

309 Seventh Street

Wednesday, June 4, 6–8 pm

hilo, island of hawai‘I

Hawai‘i Japanese Center

751 Kanoelehua Avenue

Tuesday, June 17, 10 am–noon (Hawai‘i Time), 

1–3 pm (Pacific Time), 4–6 pm (Eastern Time)

virtual meeting

Virtual meeting web access information will be 

posted at www.nps.gov/pwro/honouliuli