‘Āina Momona believes that Cultural Impact Assessments (CIAs) and Ka Paʻakai Analyses are among the most significant documents prepared in Hawaiʻi's environmental review, land use, and historic preservation processes. These studies directly influence decisions affecting Native Hawaiian traditional and customary rights, cultural landscapes, cultural resources, and community well-being.

 

Because these studies frequently become the primary record relied upon by decision-makers, agencies, and the courts, ‘Āina Momona believes they should be prepared only by highly qualified individuals with extensive experience working alongside Native Hawaiian communities and should be accompanied by complete transparency regarding the qualifications, community relationships, and ethical commitments of those preparing them.

 

We have been dismayed at the poor quality of these assessments conducted in Hawai‘i by some firms. We firmly believe Native Hawaiian rights have been eroded as a direct result of this, as countless numbers of reports have failed to properly document Hawaiian practices and impacts to those practices. We have developed the following policy as a result and will encourage all other Native Hawaiian organizations to do the same.

 

I. Minimum Professional Qualifications

 

At a minimum, ‘Āina Momona believes that the principal investigator or primary author responsible for preparing a Cultural Impact Assessment or Ka Paʻakai Analysis should meet the professional qualifications for an ethnographer established under Hawaiʻi Administrative Rules §13-281-6.

 

Specifically, the individual shall possess one of the following professional qualifications:

 

1. A graduate degree from an accredited institution in anthropology, with a specialization in cultural or social anthropology, or in a closely related field; or

 

2. A bachelor's degree from an accredited institution in cultural or social anthropology, or in a closely related field, plus one of the following:

 

Two or more years of full-time experience in research, writing, teaching, interpretation, or other demonstrable professional activity with an academic institution, historic organization or agency, historic preservation consulting firm, or other professional institution; or

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Have made a substantial contribution through research and publication to the body of scholarly knowledge in cultural or social anthropology, ethnohistory, or related fields; or

 

3. Four or more years of full-time experience conducting research on the culture and history of ethnic groups in the State of Hawaiʻi under the tutelage of recognized cultural authorities.

 

In addition to meeting one of the qualifications above, the individual shall satisfy three or more of the following requirements, including one of the first two:

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• Be conversant in the language of the applicable ethnic group addressed by the ethnographic study;

• Have a demonstrated familiarity with the traditions, customs, practices, and beliefs of the applicable ethnic group addressed by the ethnographic study;

• Have a demonstrated ability to conduct and document interviews for ethnographic or historical purposes and to summarize information gained from interviews;

• Have contributed through teaching, presentations, research, or publication to the body of knowledge in cultural or social anthropology, ethnohistory, or related fields; or

• Have a working knowledge of the historic preservation review process.

 

II. Additional Qualifications Recommended by ‘Āina Momona

 

While HAR §13-281-6 establishes the minimum professional qualifications for ethnographic work, ‘Āina Momona believes that Cultural Impact Assessments and Ka Paʻakai Analyses addressing Native Hawaiian traditional and customary rights require substantially greater demonstrated experience.

 

Accordingly, ‘Āina Momona recommends that the principal investigator or primary author also possess:

 

• At least ten (10) years of demonstrated experience working closely with Native Hawaiian communities;

• Lifetime residency and/or Native Hawaiian ancestry is preferred, but not required;

• Extensive experience working with lineal descendants, Native Hawaiian Organizations, cultural practitioners, and community leaders;

• Demonstrated knowledge of Native Hawaiian history, ʻike kūpuna, customary and traditional practices, and contemporary Native Hawaiian issues; and

• A demonstrated record of producing culturally competent analyses that accurately reflect Native Hawaiian perspectives.

 

III. Transparency and Disclosure

 

To promote transparency and allow agencies, consulting parties, and the public to evaluate the qualifications and community accountability of those preparing Cultural Impact Assessments and Ka Paʻakai Analyses, ‘Āina Momona requests that the following information be provided to us and be included within every report:

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• The curriculum vitae or résumé of the principal investigator and all primary authors.

• A written statement describing how the principal investigator satisfies each applicable qualification contained in HAR §13-281-6.

• A summary of the individual's experience working with Native Hawaiian communities, including:

  • Total years of experience;

  • Representative projects completed;

  • Experience conducting ethnographic interviews, oral histories, and community consultation;

  • Experience evaluating Native Hawaiian traditional and customary rights and practices.

• A list of every Native Hawaiian Organization, lineal descendant organization, community organization, and Native Hawaiian community group with whom the individual or firm has worked during the preceding ten (10) years.

• A list identifying:

  • Every Native Hawaiian Organization for which the individual or firm has provided pro bono professional services;

  • Every Native Hawaiian Organization to which the individual or firm has made charitable donations or recurring financial contributions;

  • Volunteer service or other community investment supporting Native Hawaiian cultural stewardship, environmental restoration, education, or community capacity building.

  • IV. Indigenous Knowledge, Data Sovereignty, and Community Benefit Sharing

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‘Āina Momona recognizes that Cultural Impact Assessments and Ka Paʻakai Analyses derive substantial professional and economic value from Native Hawaiian knowledge, oral histories, cultural practices, genealogies, place-based expertise, and generations of lived experience shared by lineal descendants, cultural practitioners, Native Hawaiian Organizations, and Native Hawaiian communities.

 

Private consulting firms are compensated for preparing these reports. In doing so, they are frequently extracting Native Hawaiian knowledge that has been developed, protected, and perpetuated over generations by Native Hawaiian communities. While this knowledge is often shared voluntarily in the interest of protecting cultural resources and Native Hawaiian traditional and customary practices, the resulting reports create economic value for private firms while providing little direct economic benefit to the communities whose knowledge forms the foundation of the work.

 

‘Āina Momona believes this imbalance should be addressed through principles of Indigenous data sovereignty, ethical research, community reciprocity, and equitable benefit sharing. Native Hawaiian knowledge is a form of cultural and intellectual heritage. Those who derive professional or financial benefit from documenting, interpreting, analyzing, and presenting that knowledge have a corresponding ethical responsibility to ensure that Native Hawaiian communities share in the benefits created through its use.

 

Accordingly, ‘Āina Momona requests that every private consulting firm preparing a Cultural Impact Assessment or Ka Paʻakai Analysis make a minimum charitable contribution of One Thousand Dollars ($1,000) to a qualified Native Hawaiian Organization (NHO), preferably one whose mission directly serves the community and preserves traditional practices in which the proposed project is located.

 

‘Āina Momona further strongly encourages both the project applicant and the project planning or engineering firm to likewise make meaningful charitable contributions to qualified Native Hawaiian Organizations serving the affected community. The preparation and use of Cultural Impact Assessments and Ka Paʻakai Analyses benefits not only the consulting firm preparing the document, but also the project applicant and the broader project team whose projects advance through the environmental review process. Equitable benefit sharing should therefore extend to all entities deriving professional, financial, or regulatory benefit from the use of Native Hawaiian knowledge.

 

These contributions are not permit fees, consulting fees, mitigation measures, regulatory requirements, or payments in exchange for support, endorsement, consultation, or participation in any governmental process. Rather, they are voluntary acts of community reciprocity that recognize the value of Native Hawaiian knowledge and support Native Hawaiian organizations working to preserve, perpetuate, restore, and protect Native Hawaiian cultural heritage for future generations.

 

IV. Required Reproduction in Cultural Impact Assessments and Ka Paʻakai Analyses

 

The following statement shall be reproduced verbatim in your Cultural Impact Assessment and/or Ka Paʻakai Analysis immediately preceding the appendices.

 

Community Qualifications and Benefit Sharing Disclosure

 

Pursuant to the ‘Āina Momona Policy on Qualifications, Transparency, and Community Reciprocity for Cultural Impact Assessments and/or Ka Paʻakai Analyses, the preparer hereby provides the following disclosures:

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• Professional Qualifications, including

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Résumé(s) of the principal investigator and primary author(s) are attached.

 

A written statement describing how the principal investigator satisfies HAR §13-281-6 is attached.

 

A summary of Native Hawaiian community experience is attached.

 

A list of Native Hawaiian Organizations and community organizations with whom the preparer has worked during the preceding ten (10) years is attached.

 

A list of Native Hawaiian Organizations receiving pro bono services, charitable donations, or recurring financial support from the preparer is attached.

 

• Community Benefit Sharing

 

• Consulting Firm:

 

☐ A charitable contribution of at least $1,000 has been made.

 

Recipient Organization:

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Contribution Amount:

 

• Project Applicant (not expected for or applicable to government or nonprofit projects, including schools and health care organizations):

 

☐ A charitable contribution has been made.

 

Recipient Organization:

 

Contribution Amount:

 

• Planning/Engineering Firm:

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☐ A charitable contribution has been made.

 

Recipient Organization:

 

Contribution Amount:

 

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• If no contribution has been made by any of the above entities, the following explanation is provided:

 

‘Āina Momona believes that transparency regarding qualifications, accountability to Native Hawaiian communities, and equitable sharing of the benefits derived from Native Hawaiian knowledge strengthens the credibility of Cultural Impact Assessments and Ka Paʻakai Analyses, improves public confidence in Hawaiʻi's environmental review process, and advances more ethical and respectful relationships between private industry and the Native Hawaiian communities whose knowledge makes these studies possible.

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