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David Croxford/Civil Beat/2023

About the Author

Christine Camp

Christine Camp is President and CEO of Avalon Group, a real estate development company that she founded 23 years ago. As a young immigrant in Hawaii she experienced the rise from poverty to middle class though the stability provided by her mother鈥檚 purchase of their first home. That impression has made her passionate about finding pathways to building homes that are financially accessible to Hawaii鈥檚 residents.

Bill 21 would allow office buildings to be converted to much-needed housing without giving up light or ventilation.

Editor’s note: This commentary is in response to the recently published Civil Beat story, “No Window In Your Bedroom? It Could Be The Future Of Low-Cost Housing In Honolulu.

As a supporter and proponent of Bill 21, I agree that there should not be homes without windows. None of the developments approved under this bill will encompass any residential unit without any windows.

The development community as a whole, who need to compete in the marketplace, and invest hundreds of millions of dollars for an office-to-residential conversion project would never consider building a home without windows. That would not be responsible and would, in fact, be reprehensible. If I were asked how I feel about housing people in windowless units, I would be repulsed and would think it inhumane as well. 

But crucially, this is not what is being proposed.

The flexibility offered by Bill 21 is NOT about homes without windows. Rather, it is about allowing bedroom designs that, for example, may have a glass door/transparent door that opens into an area WITH windows.

We鈥檝e already seen this with the two projects which have received waivers: 1132 Bishop Street and the Fort Street Mall Senior Affordable Housing Project, which was recently approved by the City Council.

Both received the flexibility which Bill 21 calls for — a waiver from the specific prescriptive provisions of . In neither of these cases were windowless units created or even ever contemplated. Instead, these buildings were able to offer floor plans that made sense given the building shape and most importantly, were able to create spaces that could be livable for their future tenants.

Without Bill 21, we would likely see office-to-residential conversions and other properties with unique site constrains create very large studios, because the current Housing Code does not recognize rooms without windows as habitable rooms.

In a converted office building, providing more window frontage means adding width to the already deep floorplates, resulting in larger apartments. Larger units will mean that construction costs per unit, which are driven by a unit鈥檚 square footage, would be higher. Larger units result in higher rents, and fewer units overall to share in the building鈥檚 common costs.

In essence, without the flexibility offered by Bill 21, conversions of office buildings will result in only very expensive units with higher maintenance fees to be shared by fewer units.

Being forced to build larger, more expensive units means that we lose the limited opportunities to convert existing buildings to homes that are affordable to many.

Instead of being able to add thousands of units into our downtown area, to create a more thriving around-the-clock community, we end up with a just a few hundred at the very most, as larger units would lead to loss of density that could have been built.

With Bill 21, we have an opportunity to look at adaptive re-use as a whole and make it feasible — without giving up light or ventilation.

The complex at 1132 Bishop used to be offices but is being converted by Douglas Emmett into the Residences at Bishop Place. (David Croxford/Civil Beat/2023)

However, instead of helping to explore options and engage in constructive dialogue, this article reduced the issue down to a hysteric and unrealistic scenario, evoking an image of greedy developers creating opaque boxes without lights and air. I ask for your fair consideration to have all sides heard and to help clarify and explain what is really going on. 

As for a few more critical points, mechanical ventilation isn’t all about air conditioning. The International Building Code requires ventilation air channels, with dedicated fresh air-intakes. There will be generators that will address power failures. Additionally, buildings that are going through adaptive re-use will be equipped with energy efficient systems and will use less energy than the current buildings do with their existing aging systems.

Civil Beat is one of the responsible reporting channels available to Hawaii residents and I ask for your consideration to allow those who build housing a fair voice.

Thank you again for your article. You are helping all of us have the right dialogue to ensure that we are doing right by the community. I ask Civil Beat鈥檚 readers and reporters to please give a fair chance at clarifications to help those who are not in our industry to understand the issues. While those in the comment section may provide kneejerk reactions, I believe the readership can find a way to think about all sides of this issue so that we are not polarized and can have a meaningful dialogue around our island鈥檚 housing needs.

Community Voices aims to encourage broad discussion on many topics of community interest. It鈥檚 kind of a cross between Letters to the Editor and op-eds. This is your space to talk about important issues or interesting people who are making a difference in our world. Column lengths should be no more than 800 words and we need a photo of the author and a bio. We welcome video commentary and other multimedia formats. Send to news@civilbeat.org. The opinions and information expressed in Community Voices are solely those of the authors and not Civil Beat.


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About the Author

Christine Camp

Christine Camp is President and CEO of Avalon Group, a real estate development company that she founded 23 years ago. As a young immigrant in Hawaii she experienced the rise from poverty to middle class though the stability provided by her mother鈥檚 purchase of their first home. That impression has made her passionate about finding pathways to building homes that are financially accessible to Hawaii鈥檚 residents.


Latest Comments (0)

What's not discussed is that bill 21 allows for new building construction to follow these guidelines, but the discussion is always re-use. Why?If projects have received exemptions already, why not proceed with this same process? What's wrong with a "large studio" versus one bedroom. The problem with housing is overcrowding when prices go up.

time4truth · 1 year ago

Thank you Civil Beat for clarifying what is being proposed. We can all agree that we need more housing, and this is one way to do it. Let芒聙聶s lower our carbon footprint and reuse these buildings. Adaptive reuse of office buildings has happened and is happening in other major cities so why can芒聙聶t it be done in Honolulu? We need to amend our building codes to allow these types of uses and give developers flexibility to give these buildings new life. Let芒聙聶s revitalize downtown, which will provide more opportunities for those existing businesses in the area and welcome new ones.

HawaiiGirl26 · 1 year ago

These types of units are common in other cities. They are Not windowless! There is typically a large window, or windows, to the Living Room. The bedroom is tucked behind the Living Room with indirect light coming through the hallway or at the ceiling. Plenty of light where you need it, in the living areas. Indirect light where you typically don't need as much light, in the sleeping areas. Christine Camp, and other developers, take considerable financial risks to turn an old, underused office building into much needed residential units. This should be a positive story. No good deed goes unpunished.

SteveBaldridge · 1 year ago

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