Attachment_9-Specs_KPLH_Section_106_Compliance.pdf

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Attached to
KP LIGHTHOUSE REPAIRS Federal contract opportunity
Solicitation number
140FHR24R0005
Issued by
Department of the Interior Fish and Wildlife Service

About this file

This document is a set of comments and feedback from the Historic Hawai'i Foundation (HHF) regarding Section 106 compliance for the repair and maintenance of the Daniel K. Inouye Kilauea Point Lighthouse. Key points include:

The Kilauea Lighthouse is a historically significant structure, containing a rare French-made Fresnel lens and being one of only eight surviving reinforced concrete lighthouse towers built before 1916. HHF has several areas of concern regarding the proposed work, including the need for a professionally-developed conservation plan for the Fresnel lens, the proper handling and documentation of the lantern glazing, and the potential destructive impact of replacing the cast iron vent framing. HHF recommends the work be overseen by professionals with specific lighthouse restoration qualifications. The State Historic Preservation Division also requests the opportunity to review any long-term treatment plans.

The document references a related federal contract opportunity, Solicitation Number 140FHR24R0005, for the "KP Lighthouse Lantern Repairs" project, to be awarded by the U.S. Department of the Interior Fish and Wildlife Service.

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Section 106 Compliance for the Repair and Maintenance of the Daniel K. Inouye Kīlauea Point Lighthouse

Historic Hawai‘i Foundation Comments

The Kīlauea Lighthouse is unique in several key aspects as described in the documentation provided and summarized below:

• The French-made Fresnel lens, was one of the largest in the Pacific, and is one of only seven second-order lenses that are extant among lighthouses in the United States

• There are only eight surviving reinforced concrete lighthouse towers in the U.S. that were built before the ACI standardized reinforced concrete specifications were published in 1916.

• Of these early concrete lighthouses, only the Kilauea Lighthouse still has its lens.

Because of the uniqueness of the Kilauea Lighthouse HHF has the following areas of concern regarding potentially conflicting specifications and extent of removal of historic materials:

A. Fresnel Lens: Enclosure 1 of the FWS letter states that the contractor will assess the condition of the lens and will also develop a conservation treatment plan (Step 1, paragraphs C and D). Considering the significance of the Kīlauea Lighthouse, the evaluation and conservation plan should be prepared by a professional meeting the Coast Guard’s Lampist Qualifications (see attached for reference). The professionally developed plan should be a requirement of the bid documents.

B. Lantern Glazing: Enclosure 1 lists steps for documentation and labeling of glazing stops and glass panels (Reference Step 1, paragraph E) 1. Documentation is to be photographed and approved prior to beginning work.

Due to the specialized nature of this work, the approving authority needs to be professionally qualified and identified.

(Follow up email on 5/8/24 from HHF) Regarding the professional qualifications for the Kīlauea Lighthouse, HHF is recommending several levels and types of subject matter expert:

1. The Lampist qualifications for the actual contractor doing work on the lens itself.

2. Historic Architect qualifications for the architect and/or contractor developing the plans for the overall rehabilitation and repair project (especially related to the corrosion removal, since the proposed methods seem potentially destructive).

3.FWS oversight qualifications to check the proposed solution for the Lantern specifically as well as the overall project. Since the Lantern is a unique feature that needs careful handling, we are recommending that whoever reviews and approves the plans knows the right questions to ask and to understand the proposed scope. We’re assuming this is a specialty that only a few people have, so hope you can tap into one of them.

If FWS doesn’t have someone on staff, maybe DOI/NPS or Coast Guard could assist? It’s just to add another layer of checking the work before it begins.

2. The General Notes on page A-101 state that the bronze sash frames and glazing stops are to be cleaned to bright metal (Notes 2B and 2G), yet the instructions in Exhibit 2 (maintenance plan) note clearly that the bronze has developed a brown patina which should never be polished. Photographs of the lantern show a more silver metal appearance. This discrepancy should be clarified and re-stated as needed for clear direction to the contractor.

ckreiser Callout curtainwall frames shall be cleaned ckreiser Callout bronze lens frames shall never be polished`

Section 106 Compliance for the Repair and Maintenance of the Daniel K. Inouye Kīlauea Point Lighthouse

3. Enclosure 1 indicates that following documentation the glass is to be removed and safely stored for re-installation. Yet the General Notes state that “all materials associated with glass panel and glazing installation to be replaced new”. These statements require restating for clear direction regarding extent of glass replacement to the contractor as well as the reviewing authorities.

C. Cast Iron Vent Framing: Enclosure 1, step 6 states that the cast iron vent frames are to be replicated and replaced with new stainless steel components. However, details 2 and 3 on sheet A-115 (pasted below for refence) clearly show that the vent frame is embedded and keyed into the exterior concrete wall on all four sides. To remove this will require destructive removal of the existing wall fully surrounding each of the vents. Please confirm that this is the intent and if so, please propose a less destructive way to arrest the corrosion. We fully understand the corrosive shoreline environment, but recommend prioritizing modern protective coatings and more frequent maintenance of these ferrous metal vents in order to provide maintenance while avoiding the demolition of the historic wall.

D. Need for removal of the lantern glazing: The documents state that “in 2011 the lighthouse underwent a comprehensive restoration…” If this prior restoration work included removal of the lantern glazing and restoration of the sash framing, please explain the need to remove the glass again after only 13 years.

E. Work to be supervised by persons meeting Professional Qualifications specific to lighthouse restoration:

The drawings contain the following notation

“DRAWING DETAILS DUPLICATED FROM FISH AND WILDLIFE SERVICE 2009 KILAUEA POINT

REHABILITATION PROJECT.”

• Please clarify that the work will be overseen and supervised by professionals meeting specific lighthouse restoration qualifications.

• Please clarify that the bid and contract documents will require documented lighthouse restoration experience.

F. Description of Proposed Maintenance (Enclosure 2): Historic Hawai‘i Foundation appreciates the inclusion of proposed maintenance Guidelines and the recognition that a maintenance program is essential in this corrosive environment.

State Historic Preservation Division Comments

Requests an opportunity to review any long-term treatment plans, such as the conservation treatment plan for the stabilization and treatment of the lighthouse lens.

ckreiser Callout except the glass itself ckreiser Text Box For bidding purposes assume vent framing replacement as described in the scope of work.

United States Coast Guard Curatorial Program

Professional Lampist Standards

In order to be considered a qualified Coast Guard lampist with the authorization to professionally conserve, restore, repair, treat, disassemble or assemble, any or all components of a Coast Guard-owned classical Fresnel lens, the following standards and requisites must be met:

1. Two years of direct supervised training by a qualified and approved professional lampist or trained industrial equipment conservator with experience in optical glass, metal, wood, or historic lighthouse optical navigational equipment.

2. At least three years of demonstrated full-time experience (or part-time equivalent) of working directly on Fresnel lens conservation, restoration, treatments, repair, assembly and disassembly. Internships will not be counted toward this requirement.

3. Documented continuing education courses (via accredited conservation programs or through the American Institute of Conservation (AIC)) completed with a concentration on materials and treatment methods pertaining to industrial artifacts made of multiple materials and/or Fresnel lenses.

4. Knowledge of and experience in industry standard conservation methods specifically related to historic optical equipment and metals.

2024-04-05 HHF Comments_USFWS_Sec 106_Kilauea Lighthouse Rehab w encl
2024-04-05 HHF Comments_USFWS_Sec 106_Kilauea Lighthouse Rehab.pdf
140505_LAMPIST_STANDARDS.PDF

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