Pave way for office buildings to be converted into housing

The following testimony was submitted by the Grassroot Institute of Hawaii for consideration by the Honolulu City Council on Oct. 4, 2023.

October 4, 2023
10 a.m.
Honolulu City Council Chambers 

To: Honolulu City and County Council
      Councilmember Tommy Waters, Chair
      Councilmember Esther Kiaʻāina, Vice Chair

 From: Grassroot Institute of Hawaii
            Ted Kefalas, Director of Strategic Campaigns


Comments Only

Dear Chair and Councilmembers:

The Grassroot Institute of Hawaii would like to offer its comments on Bill 54 (2023), which would for a five-year period facilitate the conversion of commercial buildings to multifamily residential units by creating alternate natural light and ventilation regulations.

The practice of converting commercial buildings to residential use is commonly known as “adaptive reuse,” and is one of many ways Honolulu can increase its housing stock.

As Grassroot Institute of Hawaii President Keli‘i Akina put it in his “President’s Corner” column in April: “Given Hawaii’s high material and construction costs that contribute to the high price of housing in the islands, adaptive reuse is a great way to make housing more affordable.”[1]

According to the real estate firm Colliers, Honolulu’s office vacancy rate stood at 13.66% in the first quarter of 2023,[2] with the downtown area being hit the hardest.

It said it expects “office building conversion activity” to make up for decline in office space demand. However, because many of the large commercial buildings constructed do not have openable windows, ventilation regulations in the building code can make adaptive reuse cost prohibitive. It is simply too expensive to retrofit windows for a large office building.

Thus, Bill 54 proposes a temporary avenue for adaptive reuse projects to meet certain ventilation standards.

These standards would not require openable windows for all housing units, but specify that non-openable windows must provide a certain amount of natural light. The bill provides that natural and mechanical ventilation systems may take the place of openable windows in some instances.

Any project seeking approval under this bill would have to submit a detailed application to the city Department of Planning and Permitting and receive Council approval in order to proceed. Factors to be considered in the approval process would include whether the project would harm the health of the occupants.

Clearly, this measure takes individual and community concerns into account while providing an avenue for old buildings to take on new life as much-needed housing.

Our only concern with the bill is that if it were enacted, it would sunset after five years. We see no good reason for that, as some building conversions might not even be considered until after the five-year deadline has passed.

Thank you for the opportunity to submit our comments.


Ted Kefalas
Director of Strategic Campaigns
Grassroot Institute of Hawaii

[1] Keli’i Akina, “Is there life after Downtown Walmart?” Grassroot Institute, April 2, 2023.
[2] Mike Hamasu, “Office Market Takes A Step Backward,” Colliers, April 20, 2023.

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