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EWA Update NPS Comments Critical Of Navy-Hunt Battlefield Survey


NPS Comments Critical Of Navy-Hunt Battlefield Survey

HIGHLITES: From Attached Comments…

In short, the Ewa Battlefield retains quite a bit of integrity based on the

NR standards as set out in NR Bulletin 40


RE: Renewable Energy Park-

Recommend exploring options that would place the photovoltaic array away

from the Proposal runaway.


We do not consider the boundaries adequate for consideration since this

study was commissioned to represent the battlefield resources for this

portion of the Pearl Harbor engagement.

The evaluation is missing a presentation of the archeological battlefield

resources (especially field of fire) which might expand the boundary

significantly. There is no visual or view shed (observation) analysis, which

would certainly include more area than depicted. We recommend that the study

be revised to include archeological battlefield resources as well as view

shed analysis.

The report is generally well written and straight forward; however, we

believe that the findings of the evaluation are based on an incomplete

analysis that does not include some of the standard methodology used by the

American Battlefield Protection Program to evaluate battle fields. Given the

need for additional study and evaluation, we cannot concur with the findings

of AECOM’s Battlefield evaluation of Ewa Field.

Our American Battlefield Protection Program staff would happily work with

the contractor to remove some of the inconsistent references to the core

area versus the historic extent of the battlefield, the supporting

assertions, the role of the avenue of approach and egress on all

battlefields and a detailed analysis of the report.

A concern with the report and the summary conclusion is the finding of

minimal integrity.

This conclusion is based on a misapplication of the NR (National Register)

standards as applied to the Ewa Battlefield and is incorrect. For example

there appears to be some confusion between the application of NR standards

for integrity and the concept of condition, as well as several contradictory

statements pertaining to the NR standards vis a-vis the defining features.

In addition, the battlefield integrity conclusions for the standards of

Association and Feeling are incorrect (pg. 20). In short, the Ewa

Battlefield retains quite a bit of integrity based on the NR standards as

set out in NR Bulletin 40

Only a defensive posture is considered rather than both sides of the

conflict. It is standard battlefield evaluation methodology to consider the

battle vantage point of both combatants. In an air assault where the planes

may have been as low as 20 feet from the ground, the view sheds (both attack

and defense) becomes critical to the understanding of the site. We recommend

that the evaluation be revised to include an analysis of both vantage



APE = Area of Potential Effect

John Bond

Save Ewa Field


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