From:  COMPLAINT FOR INJUNCTIVE AND DECLARATORY RELIEF  May 12, 2011

Plaintiffs:  HONOLULUTRAFFIC.COM; CLIFF SLATER; BENJAMIN J. CAYETANO; WALTER HEEN; HAWAII’S THOUSAND FRIENDS; THE SMALL BUSINESS HAWAII ENTREPRENEURIAL EDUCATION FOUNDATION; RANDALL W. ROTH; and DR. MICHAEL UECHI

This is an action to compel Defendants to comply with the National Environmental Policy Act (“NEPA”), with Section 4(f) of the Department of Transportation Act (“Section 4(f)”), with the National Historic Preservation Act (the “NHPA”), and with the regulations and guidance implementing those statutes.

Specifically, Plaintiffs seek declaratory and injunctive relief to ensure that Defendants do not implement the Honolulu High-Capacity Transit Corridor Project (“Project”) — an expensive, elevated railroad acknowledged by all parties to have significant negative impacts on historic and cultural resources, parks, schools, views, and public safety without materially improving current traffic conditions — before complying fully with federal environmental laws.

The Project will have an adverse impact on at least 32 historic resources, such as the Chinatown Historic District, the Merchant Street Historic District, the Pearl Harbor National Historic Landmark, the National Historic Landmark at the Pacific Fleet Headquarters, the Aloha Tower, the Dillingham Building, eight historic bridges and four parks.

On information and belief — the FTA having failed to complete its required historic resource inventory and analysis before approving the Project — the Project will also result in the unnecessary disruption of numerous Native Hawaiian burial sites. In addition, the Project will significantly interfere with protected views and take land from parks and schools.

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Full Text: http://www.honolulutraffic.com/Complaint.pdf