Office of the County Auditor

County of Hawaiʻi

November 2024

Performance Audit of the Department of Public Works

Bridge and Culvert Maintenance

Why OCA Conducted this Audit
The safety and reliability of the County's bridges and culverts are critical to public safety, as these structures ensure safe travel, protect communities from flooding, and support emergency response efforts.  Proper maintenance and efficient management of resources, including work order processes, are essential to prevent structural failures that could endanger lives and property.  This audit was conducted to evaluate whether the Department of Public Works' repair, maintenance, work order processes, and resource utilization practices comply with federal, state, and local regulations and standards.  The audit aims to strengthen public safety, ensure infrastructure resilience, and promote efficient use of public resources.
What OCA Found
A review of DPW’s Bridge section revealed areas where efforts could be better aligned, and improvements could be made.  More specifically, we identified the following findings: 

Finding 1: Non-Compliance with HRS 464

Finding 2: Incomplete Culvert Inventory

Finding 3: Lack of Culvert Policies and Procedures

Finding 4: Undefined Roles and Responsibilities

Finding 5: Lack of Interdepartmental Communication

Finding 6: Lack of Routine Maintenance and Repairs

Finding 7: Reliance on Contractors

What OCA Recommends
We make seven recommendations to help DPW’s bridge section identify improvement opportunities and perform its management responsibilities more effectively.  Key recommendations include:

• Ensure compliance with HRS § 464-4
• Enhance and Expand the County’s Culvert Inventory
• Formalize Written Policies and Procedures
• Establish Clear Roles and Responsibilities
• Establish an Effective Communication Protocol
• Develop and Implement a Maintenance Schedule
• Establish a Process for Independent Review

These changes can help DPW support good decision-making and continual improvement and ensure the current processes continue to meet the needs of the County.  DPW generally agreed with our recommendations. 

Mission

It is our mission to serve the Council and citizens of Hawaiʻi County by promoting accountability, fiscal integrity, and openness in local government.  Through performance and/or financial audits of County agencies and programs, the Office of the County Auditor examines the use of public funds, evaluates operations and activities, and provides findings and recommendations to elected officials and citizens in an objective manner.  Our work is intended to assist County government in its management of public resources, delivery of public services, and stewardship of public trust .

Audit Authority

Hawaiʻi County Charter § 3-18 establishes an independent audit function within the Legislative Branch through the Office of the County Auditor.

Purpose

This engagement evaluated the safety, efficiency, and responsibility of managing county bridges and culverts.  Our audit reviewed safety, risks, asset management, performance, best practices, and stakeholder involvement.  Results assure stakeholders about bridge and culvert safety and guide future decisions and spending.

Performance Audit Definition

Performance audits provide objective analysis, findings, and conclusions to assist management and those charged with governance and oversight with, among other things, improving program performance and operations, reducing costs, facilitating decision-making by parties responsible for overseeing or initiating corrective action, and contributing to public accountability.

Our objective in performance auditing is to improve public services provided by the County government.  We do this by recommending specific actions to address the issues we raised and by providing valuable information to the public, the administration, program leadership, the county council, and the mayor. 

Objective

Is the Department of Public Works’ repair and maintenance practices, work order processes, infrastructure conditions, and resource utilization for the County’s bridges and culverts in compliance with the US Department of Transportation’s Federal Highway Administration (FHWA) standards and other applicable governance?

Scope

The audit engagement began in July 2023.  The Office of the County Auditor engaged with the Department of Public Works in September 2023.

This audit evaluated the repair, maintenance, and work order procedures for bridges and culverts from July 2021 through June 2023.  We also assessed infrastructure conditions and resource use.  Our examination encompassed regulatory compliance, inspection methods, and the overall success of maintenance activities.

We focused on identifying areas for improvement and provided actionable recommendations to enhance the safety, efficiency, and longevity of the County’s bridges and culverts.  

Disclaimer: While the audit team possesses the collective knowledge necessary to review processes, procedures, and compliance with regulatory standards, we do not possess the technical expertise required to independently assess or judge the safety of the infrastructure. Nor does our audit override any technical analyses, recommendations, or assessments made by licensed engineers and other qualified professionals. Any conclusions or recommendations made in this audit should be considered complementary to, and not a substitute for, expert technical evaluation and safety determinations.

Methodology

To accomplish our objective, we conducted the following activities:

Developed an understanding of policies, procedures, and maintenance processes and identified key stakeholders.

Conducted interviews and corroborated with department administration and staff.

Collected and analyzed data, including maintenance records, budgets, inspection reports, and other relevant information.

      o Assessed compliance with applicable laws, governance, and standards such as: 
      o Federal Highway Administration (FHWA)
      o National Bridge Inspection Standards (NBIS)
      o Hawaiʻi Bridge Inspection Manual (HBIM)
      o Hawaiʻi Revised Statute Chapter 464

Reviewed, as necessary, information pertinent to the maintenance of bridges and culverts, along with work order processes.

Conducted site visits to observe monitoring and oversight practices.

Noted exceptions and identified areas for improvement.

Remained mindful of potential fraud, waste, and abuse during the audit.

We conducted this performance audit in accordance with generally accepted government auditing standards.  These standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives.  We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives. 

Definitions
23 CFR 650: The abbreviation for the term “Code of Federal Regulations – Title 23”.  The Code of Federal Regulations (CFR) is a codification of the general and permanent rules published in the Federal Register by the departments and agencies of the Federal Government.  Title 23 is the section designated for Highways, while Section 650 is designated for Bridges.  

AASHTO Manual: The term “AASHTO Manual" means the American Association of State Highway and Transportation Officials (AASHTO) “Manual for Bridge Evaluation”, including interim Revisions, excluding the 3rd paragraph in Article 6B.7.1, incorporated by reference in § 650.317.

Bridge: Defined in CFR 650.305 as “A structure including supports erected over a depression or an obstruction, such as water, highway, or railway, and having a tracking or passageway for carrying traffic or other moving loads, and having an opening measured along the center of the roadway of more than 20 feet between under coping of abutments or spring lines of arches, or extreme ends of openings for multiple boxes; it may also include multiple pipes, where the clear distance between openings is less than half of the small contiguous opening.” 

BrM: A comprehensive bridge management system that can assist agencies in allocating scarce resources to protect existing infrastructure investments, ensure safety, and maintain mobility.  It stores inventory and inspection information about an agency’s bridges, culverts, and other structures and provides a rich set of modeling and analysis tools to support project development, budgeting, and program development.  It can be used to define and schedule projects for individuals or groups of structures. 

Critical Finding: A structural or safety-related deficiency that requires immediate action to ensure public safety. 

Culvert: A pipe or small structure used for drainage under a road, railroad, or other embankment.  A culvert with a span length greater than 20 feet is included in the NBI and receives a rating using the NBI scale.
     As defined by the Department of Public Works: Pipes or structures which are designed to allow water to flow under or through roadways and other structures that might otherwise impede the passage of stormwater.  

Drywell: An underground structure that disposes of unwanted water, typically stormwater runoff, by dissipating the runoff into the subsurface soils.  

Federal Highways Administration (FHWA):  The agency within the US Department of Transportation that supports State and local governments in the design, construction, and maintenance of the Nations highway system (Federal Aid Highway Program) and various federally and tribal owned lands (Federal Lands Highway Program).

Maintenance: FHWA Guidance on Highway Preservation and Maintenance, dated February 25, 2016, describes work performed to maintain the transportation system's condition or respond to specific conditions or events that restore the highway system to a functional state of operations.  Maintenance is a critical component of an agency’s asset management plan, including routine and preventive maintenance.

• Routine maintenance involves work performed in reaction to an event, season, or activities that are done for short-term operational needs that do not have preservation value.  This work requires regular reoccurring attention.  Per 23 USC 116 (d), owner agencies are required to properly maintain projects financed with Federal-aid funds.  Therefore, routine maintenance activities are not eligible for Federal funds.  Examples of routine maintenance include:

     o Trash, Litter, and Dead Animal Removal
     o Graffiti Removal
     o Hazardous Material Removal
     o Asphalt Patch with No Membrane on Concrete Deck
     o Accident Damage to Bridge and Its Appurtenances (Signs or bridge barriers)
     o Storm Damage

• Preventive maintenance (PM) or preservation activities retard future deterioration and avoid large expenses in bridge rehabilitation or replacements and are eligible for Federal funds.  PM is a cost-effective strategy for extending the service life by applying cost-effective cyclical or condition-based treatments.

Examples of Cyclical maintenance activities
     o Clean/Wash Bridge Deck and/or Super/Substructure
     o Clean and Flush Deck Drains
     o Clean Deck Joints
     o Deck/Parapet/Rail Sealing and Deck Crack Sealing
     o Seal Super/Substructure Concrete

Examples of Condition Based maintenance activities
     o Deck Drain - Repair/Replace
     o Deck Joint Seal Replacement
     o Deck Joint Repair/Replace/Elimination
     o Electrochemical Extraction (ECE)/Cathodic Protection (CP)
     o Concrete Deck Repair in Conjunction with Overlays, CP Systems or ECE Treatment
   o Deck Overlays (thin polymer epoxy, asphalt with waterproof membrane, rigid overlays)
     o Repair/Replace Approach Slabs

National Bridge Inventory (NBI): An aggregation of the State transportation department, Federal agency, and Tribal government bridge and associated highway data maintained by the Federal Highway Administration (FHWA).  The NBIS requires each State transportation department, Federal agency, and Tribal government to prepare and maintain a bridge inventory, which must be submitted to FHWA per these specifications annually or whenever requested (23 CFR 650.315). 

National Bridge Inspection Standards (NBIS): Federal regulations establish requirements for inspection procedures, frequency of inspections, qualification of personnel, inspection reports, and preparation and maintenance of a state bridge inventory.  The NBIS applies to all structures defined as bridges located on all public roads.  

Non-NBI Bridge: Bridges or culverts are not in the NBI, as they are not subject to the NBIS regulations.  This is a type of “Non-Reportable Structure.”  Non-NBI bridges may have one or more of the following characteristics: (a) less than twenty feet long; (b) not subject to highway loads (i.e., may carry only pedestrians, water, etc.); (c) publicly owned but not on a public road; (d) not publicly owned.

Non-Reportable Structure: A structure that is not required to be included in the annual NBI or NTI data submittal but may be included and managed in the BrM database.  Examples include pedestrian bridges, privately owned structures, culverts, and bridges less than 20 feet. 

Private Bridge: A bridge open to public travel and not owned by a public authority as defined in 23 USC 101.

Routine Inspection: Regularly scheduled comprehensive inspection consisting of observations and measurements needed to determine the physical and functional condition of the bridge and identify changes from previously recorded conditions.  

Undermining: An erosion phenomenon which can cause collapse, the rupture of dykes and flooding.  The hollowing action of flowing water (sea water or fresh water) on a riverbed, bank, cliff, or engineering works (dykes, bridge, piers, etc.).  

Underwater Inspection: Inspection of the underwater portion of a bridge substructure and surrounding channel, which cannot be inspected visually at low water or by wading or proving and generally requiring diving or other appropriate techniques.

Water System: Defined in the context of bridge inspections as a system that includes any water body or waterflow that affects or is affected by the bridge.  This encompasses rivers, streams, lakes, reservoirs, and other bodies of water, including their associated drainage systems.  

Chapter 1
Introduction
Department of Public Works (DPW) Primary Functions
DPW directs and administers departmental functions, programs, and activities for the public’s health, safety, and environment through planning, design, construction, operation, and maintenance of the County’s infrastructure.  DPW administers applicable Federal, State, and local laws and rules governing public works programs.  

Department of Public Works’ Mission and Goals

Mission
DPW’s mission is to serve the community by building, operating, and maintaining the County’s infrastructure in order to create a safe, resilient, and sustainable Hawaiʻi Island community.  

Goals
Further, its goals are:

1. Safety – No one gets hurt on the job!  Building a culture of safety through training, education, and policy development; strive to minimize accidents; promote employee personal responsibility; maintain a safe work environment for our employees, customers, vendors, and the entire public.

2. People – Our employees are our greatest resource!  Treat all employees with respect, build highly functioning teams; encourage growth and technical development in the job; foster a sense of personal worth for every employee.

3. Transparency – Promote honesty and openness with our employees and the public.

4. Customer service – Strive to provide high quality customer service, treating every member of the public like ʻohana.

5. Continuous improvement – committed to continuously improve our operations and enhancing our customers’ experience.  

Department of Public Works - Engineering Division

Hawaiʻi County Code Chapter § 2-41(1) states, “The engineering maintenance division is responsible for coordinating the planning, engineering, and implementation of the highway and drainage capital improvement projects, coordinating all land surveying, conducting necessary land rights acquisition, and providing construction inspectional services.” 

The Engineering Division provides civil engineering, land surveys, and regulatory services in accordance with Chapters 10, 22, and 27 of the Hawai‘i County Code (HCC).  The Division is comprised of the following six sections:

   • Administration
   • Land Surveying
   • Regulatory Review
   • Design and Investigation
   • Bridge
   • Inspection

The Administration section provides the following services:

1. Provides general supervision and administrative support.

2. Coordinates civil engineering (non-building) projects and programs using County, State, and Federal funds.

3. Supervises and coordinates land acquisition activities for the Department.

The Land Surveying section provides the following services:
1. Provides general land surveying services, including topographic maps and boundary studies.

2. Produces parcel maps and their descriptions for the County.

3. Reviews privately generated survey maps and descriptions.

4. Addresses survey issues and complaints related to County facilities, such as road encroachments.

5. Maintains an inventory/file of all road and drainage rights-of-way, Public Works parcels, and survey records generated by the County.

6. Provides County maps and survey information to the public.

The Regulatory Review section provides the following services:

1. Implements/enforces the applicable regulatory requirements of Chapters 10, 22 and 27, HCC.

2. Provides comments to the Planning Department on land-use related matters, such as subdivision, ‘ohana, variance, and change of zone applications; and on Special Management Area (SMA), Use, and Special Permits.

3. Investigates and resolves regulatory complaints (except for building permit plans), reviews and/or coordinates the review and approval of all private construction plans, traffic reports, flood studies, environmental documents, as they relate to the interests and regulatory authority of the Department.

The Design and Investigation section provides the following services:

1. Plans, designs, and constructs civil engineering (non-building) County Capital Improvement Projects (CIP).

2. Investigates and resolves roadway, drainage, and other related complaints.

3. Provides drafting services. 

The Bridge section provides the following services:

1. Plans, designs, and constructs County bridge repair, maintenance and replacement projects.

2. Manages bridge inspections in accordance with National Bridge Inspection (NBI) regulations.

3. Conducts structural analysis to determine NBI bridge load ratings as required.

The Inspection section provides the following services:

1. Inspects civil engineering (non-building) County CIP; private subdivision, and development construction.

2. Inspects grading, grubbing and stockpiling work per Chapter 10 of the HCC.

3. Inspects construction within the County right-of-way (R-O-W) per Chapter 22 of the HCC.

Department of Public Works - Highway Maintenance Division

Hawaiʻi County Code Chapter § 2-41(4) states, “The highway maintenance division shall be responsible for the construction and maintenance of all roads, streets, highways, footpaths, storm drains, bridges, flood channels, and certain cemeteries.” 

Highway Administration
The Highway Maintenance Division oversees and directs the maintenance of roadways, drainage systems, and public flood control structures. The Division also completes in-house resurfacing projects and responds to various road emergencies as well as natural disasters.

District Baseyards
Each District Baseyard maintains and repairs roads, streets, highways, bridges, storm drains and other flood control structures in their respective geographical area.  

Highway Maintenance Districts
Hawaiʻi County is made up of nine unique districts covering a span of approximately 4,028 square miles.  To better meet the demands of each unique district, the Department of Public Works Highways Maintenance Division has incorporated six unique districts where staff are tasked with the upkeep and maintenance of unique responsibilities.  These districts are as follows:

     1. South Hilo
     2. Puna
     3. Kaʻu
     4. Kona
     5. North and South Kohala
     6. Hāmākua  

Funding of Bridge Activities

Bridge activities are funded through the County’s Highway Fund.  This fund is sourced from the Hawaiʻi fuel tax under Hawaiʻi Revised Statutes (HRS) § 243-6, § 248-8, and § 248-9.  This tax is comprised of three parts: a state fuel tax, a county fuel tax, and the environmental response, energy, and food security tax.  Rates vary on the type of fuel (i.e., diesel, gasoline, or alternative fuel) and the use of the fuel (on highway or off-highway).  County rates further vary by County and are governed by Hawaiʻi County Ordinance pursuant to HRS § 243-5.  Hawaiʻi County’s fuel tax rate is $0.23 per gallon of gasoline or diesel. 

Noteworthy Achievements

Engineering
Committed to improving infrastructure and transportation safety, DPW's Engineering Division has made progress in creating and managing an inventory of non-National Bridge Inventory (NBI) bridges in Hawaiʻi County.  Through innovative planning and maintenance techniques, DPW has demonstrated a commitment to engineering excellence, contributing to the stability, structural integrity, and reliability of bridges and culverts essential for community connectivity.  

DPW’s efforts help to ensure crucial transportation routes remain resilient, promoting economic success and safety.  Moving forward, DPW’s Engineering Division is dedicated to further innovation and collaboration, fostering a resilient and interconnected infrastructure landscape.

Highway Maintenance
DPW is committed to enhancing the efficiency and effectiveness of its operations.  As part of this commitment, in November 2023, DPW Highways implemented its work management system, iWorQ, aimed at better managing certain county assets and work orders.  This new system will revolutionize the way Highways Maintenance tracks, maintains, and optimizes the use of its assets, ensuring that its resources are utilized to their fullest potential.  

The new system will provide a centralized, digital platform for the real-time monitoring and management of certain county assets.  This includes infrastructure such as roads, bridges, and drainage systems.  Key features of the system include:

• Work order management: Streamlined processes for generating, assigning, and tracking work orders, ensuring timely completion of maintenance and repair tasks.

• Inventory tracking: Real-time tracking of certain county assets, providing detailed information on their location, conditions, and maintenance history.

• Work order management: Streamlined processes for generating, assigning, and tracking work orders, ensuring timely completion of maintenance and repair tasks.

• Predictive maintenance: Utilizing data analytics to predict and prevent asset failures, thereby reducing downtime and extending the lifespan of county assets.

• Resource allocation: Improved allocation of resources, ensuring that the right tools and personnel are available for each task.   

In addition to implementing its work management system, DPW has recognized the need to review and optimize its policies and procedures.  To achieve this, DPW has contracted consultant, Berry, Dunn McNeil & Parker, LLC, in April 2024, to review standard operating procedures (SOPs) of the department’s Highways Maintenance Division.  The consultant’s role will include:

• Identify missing policies and procedures in addition to updating all existing Highways Maintenance policies and procedures where necessary.

• Comprehensive review: Conducting a thorough review of all current Highway Maintenance Division policies and procedures to identify areas for improvement.

• Stakeholder engagement: Engaging appropriate staff to gather input and ensure that proposed changes align with operational realities and best practices.  

• Implementation support: Assisting in the implementation of new or revised policies and procedures, providing training and support to DPW staff as needed. 

The introduction of the work management system and the comprehensive review of Highway Maintenance Division’s policies and procedures represent significant steps forward for DPW.  These initiatives will not only enhance the department’s operational capabilities but also improve service delivery to the community.  

The Highway Maintenance Division has taken a significant step forward in modernizing its infrastructure management by establishing a Geographic Information System (GIS) mapping system to assist in the management of culverts.  This initiative reflects the department's recognition of the importance of leveraging technology to enhance efficiency and effectiveness in infrastructure management.

The GIS mapping system represents a valuable tool for visualizing and organizing culvert data, including location, size, condition, and maintenance history.  It can streamline decision-making processes, improve asset management strategies, and prioritize maintenance and repair efforts based on accurate and up-to-date information. 

This development yields significant benefits for infrastructure resilience, efficiency, and safety.  DPW may enhance its capacity to manage and safeguard critical culvert assets, ultimately contributing to improved transportation networks and community resilience.

Bridges within the NBI strictly adhere to stringent inspection protocols outlined in the Manual for Bridge Evaluation by the American Association of State Highway and Transportation Officials (AASHTO).  Adherence underscores a commitment to upholding critical structures' structural robustness and operational efficiency, setting them apart from non-NBI bridges.  AASHTO further requires states to maintain these inspections and information in a database known as the Bridge Management system (BrM).

Overview

Hawaiʻi County road systems relies on a  system of bridges and culverts to keep its transportation infrastructure functioning smoothly.  These structures are vital for connectivity, ensuring safe passage and accessibility throughout the County.  Maintaining these bridges involves thorough assessment and upkeep, considering various factors such as safety, structural integrity, environmental impact, and functionality.  
DPW’s Bridge Section adheres to the AASHTO Manual with the latest Hawaiʻi Department of Transportation (HDoT) Bridge Management, Bridge Inspection Manual (BIM) to ensure compliance with federal regulations CFR 650 Subpart C and Subpart E. 

[1] Changing How Engineers Think About Bridge Maintenance | FHWA (dot.gov) by Judy Francis 09/2017, accessed 01/10/2024

Further regulating the process of bridges and culverts and providing additional quality assurance, the United States Army Corps of Engineers (USACE), in agreement with FHWA, has taken on additional responsibilities to ensure compliance with the NBIS as it relates to levee systems within the United States.  

Bridges and Culverts

Bridges included as part of the NBI are defined as a structure including supports erected over a depression or an obstruction, such as water, highway, or railway, and having a tracking or passageway for carrying traffic or other moving loads, and having an opening measured along the center of the roadway of more than 20 feet between under coping of abutments or spring lines of arches, or extreme ends of openings for multiple boxes; it may also include multiple pipes, where the clear distance between openings is less than half of the small contiguous opening.  This includes culverts with a span length greater than 20 feet, which are also included in the NBI and receive a rating using the NBI scale.  

Examples – NBI Bridge Lengths

Source: https://www.fhwa.dot.gov/bridge/snbi/snbi_march_2022_publication.pdf

Hawaiʻi County currently has 144 bridges qualifying under the NBI and requiring inspections on a 24-month interval or routine inspection (RTN), and two underwater bridges that also require underwater inspections (UW) not to exceed a 48-month interval.

Map of Hawaiʻi County’s National Bridge Inventory

Source: National Bridge Inventory | National Bridge Inventory | Hawaiʻi Statewide GIS Program

As of February 2024, the County currently has nine NBI bridges in poor condition, 6% of the total.  Two of the nine are closed, and one is not slated for repair. 

• Pauahi Street Bridge (#22-2) – Bridge construction currently in progress as of April 2024.
• Hanawī Stream Bridge (#27-5) – Bridge design work is ongoing as of March 2022.
• Kawainui Stream Bridge (#27-7) – Bridge design work is ongoing as of February 2023.
• Waimaauau Stream Bridge (#28-1) – Bridge replacement design commenced in 2017.
• Kaʻahakini Stream Bridge (#29-1) – Closed; bridge replacement design ongoing as of March 2024.
• ʻŌpeʻa Stream Bridge (#31-2) – Bridge design work is ongoing as of March 2022.
• Kaiwilahilahi Stream Bridge (#35-1) – Bridge construction repair commenced August 2024.
• Kaʻula Gulch Bridge (#41-1) – Bridge design work is ongoing as of February 2023.
• Lauhala Bridge (#42-1) – Bridge has been permanently closed since 2011. 

Although not required, the FHWA and several engineering associations, including the USACE, strongly recommend that states adopt guidelines to monitor shorter structures or those known as non-NBI bridges.  Additionally, the Hawaiʻi Bridge Inspection Manual states that owners [of Non-NBI Structures] “may want to track or be aware of structures that do not meet the definitions contained in the NBIS or the NTIS such as Pedestrian bridges, privately owned bridges, or structures < 20 feet.  These structures are not included in the National Inventories but may be included in the BrM database at the owner’s discretion.”   

Non-NBI bridges or non-reportable structures are those that are not subject to the NBIS regulations and may have one or more of the following characteristics: 

(a) less than 20 feet long, 
(b) not subject to highway loads (i.e., may carry only pedestrians, water, etc.), 
(c) publicly owned but not on a public road, and 
(d) not publicly owned.  

As of July 2023, there are currently 17 non-NBI bridges in the County’s inventory, which is continually being updated and developed.  Currently, there are no requirements for the inspection frequency of non-NBI bridges, and they are typically investigated only when complaints are received.

Contracted NBI Inspection Engineers

In November 2023, the audit team joined DPW’s Engineering Consultants in inspecting four NBI bridges and culverts.  The inspections revealed the conditions of the bridges inspected and the challenges the engineers encountered. The engineers demonstrated high expertise, complied with strict criteria and guidelines, and were proficient in explaining and addressing the queries raised by the auditors. The contracted engineers noted that DPW staff had never accompanied them during inspections and expressed concerns regarding the comments and edits requested by engineering staff to bridge reports.

External Challenges

Private Property Owner Obligations
Many layers affect the County’s ability to maintain the bridges and culverts properly.  For example, DPW staff can only complete maintenance or repair efforts within the County’s right-of-way.  This may pose issues when overgrowth or blockage occurs on private property.  Under Hawaiʻi Revised Statute § 46-11.5, each County must ensure that channels, streambeds, streambanks, and drainageways are maintained to carry off storm waters and remove debris to prevent public nuisances.  Private owners are responsible for upkeep, but the County can enforce this obligation.  Failure to comply may result in a civil penalty of up to $500 per day.  The County is responsible for maintenance unless the areas are privately or state-owned, in which case the respective owner is responsible.

Further, Hawaiʻi County Code Chapter 27, § 27-37 states, “In addition to any other section, if any encroachment or obstruction exists, under, over or through any portion of a drainage, floodway, levee system, or watercourse within the County and the encroachment or obstruction is observed, or a complaint made to the department of public work of the County of Hawaiʻi, then the 
department of Public Works shall investigate and forthwith, give notice to the owner to remove the encroachment and/or obstruction in the manner provided in this article.” 

Generally, this process involves an investigation initiated through a complaint, and if warranted, a notice of violation to the property owner is issued for any potential obstruction. 

Property owner obligations add a layer of complexity, potentially inhibiting the County’s eligibility to retain insurance or obtain emergency reimbursement funding.  One such example relates to the Paʻauau Stream, which impacts up to 30 properties.  The waterway system was declared inactive in August 2008 due to encroachments, mainly on private property, including fences, sheds, and vegetation.  Staff have commenced efforts to increase public communication, and department staff have sent correspondence, held meetings, and gone door-to-door.

Additionally, County efforts to maintain bridges and culverts can be delayed by regulatory groups including the State’s Department of Land and Natural Resources (DLNR) Division of Conservation and Resources Enforcement and the State Historic Preservation Division (SHPD).

Division of Conservation and Resources Enforcement

The Division of Conservation and Resources Enforcement is “responsible for enforcement activities of the department.  The division, with full police powers, enforces all State laws and rules involving State lands, State Parks, historic sites, forest reserves, aquatic life and wildlife areas, coastal zones, Conservation districts, State shores, as well as county ordinances involving county parks.”

One specific example of the delays experienced can be noted in the Wailoa Stream.  Repair efforts commenced in response to Hurricane Lane (August 2018).  Initially identified as a Federal Emergency Management Agency (FEMA) project, a plan of action was underway.  However, this was sidelined due to the USACE indicating the waterway was under their jurisdiction.  Subsequently, their efforts were put on hold when DLNR stepped in with concerns regarding possible turtle nesting in the sedimentary material.  Ultimately, it has now been deemed the County’s responsibility due to required dredging, where DPW is currently trying to secure funding to hire a consultant to design and plan.

State Historic Preservation Division (SHPD)

SHPD is responsible for protecting and preserving the state’s cultural and historical sites.  They ensure that projects follow state and federal laws related to historic preservation or those structures 50 years or older.

Bridge #25-2, Piʻihonua Bridge, qualifies under SHPD and was identified in March 2019 as a critical finding.  The Hawaiʻi Department of Transportation’s Highway Division defines critical findings as a “structural or safety-related deficiency that requires immediate follow-up or action, as described in CFR 650.313(h)”.  As of April 2024, DPW has experienced SHPD delays and is currently in the project's design phase, where DPW is awaiting permitting and approval of final design plans.

DPW doesn't have a licensed engineer to oversee maintenance work as required by HRS § 464-4.

Effect of the Condition

DPW is operating out of compliance with state law, leading to maintenance work being conducted without mandated professional oversight, which may result in discrepancies between the executed work and required standards.

Finding 1: DPW is non-compliant with HRS § 464-4.

Recommendation 1: Ensure compliance with HRS § 464-4
We recommend that DPW review and, where necessary, revise its organizational structure to ensure compliance with HRS § 464-4.  This should include, but not be limited to:

• Updating position descriptions and job qualifications to require the appropriate skillsets.

• Establishing protocols for project oversight by licensed professionals appropriately placed within the department ensures that all activities are conducted with the necessary expertise and accountability.

 

Audit Activity

We conducted site visits, interviewed management and staff, reviewed various documents and industry best practices, and identified the following:

• DPW is improving its operations with a new system called iWorQ, launched in November 2023.  This system will help DPW’s Highway Maintenance Division manage certain county assets and work orders more effectively.  This digital platform will assist in tracking and managing assets such as roads, bridges and drainage systems in real time and will include features: 

o Work order management
o Inventory tracking
o Predictive maintenance
o Resource allocation

• DPW lacks a comprehensive inventory of all County culverts.  While the Highway Maintenance Division has prioritized compiling this information into a County GIS system, updates have been inconsistent.

• DPW’s Highway Maintenance Division does not have policies and procedures governing culvert mapping and inventory.

• While staff know many problematic culverts that require maintenance, they lack information regarding the total number and condition of culverts within each district.

• Historical maps and culvert information have often been inaccessible, limiting the accuracy of inputting data into maps without additional fieldwork or site visits.

• GIS personnel inputting information may lack the necessary training or permissions to interpret engineer legacy maps and legal descriptions effectively.  

Cause of the Condition

As of March 2024, the Highway Maintenance Division did not have a complete culvert inventory.

Effect of the Condition

The lack of a comprehensive inventory increases inefficiencies in maintenance planning and allocation of resources, leading to potential delays in repairs, increased risk of infrastructure failures, and difficulties in addressing critical issues promptly.

Finding 2: DPW lacks a comprehensive culvert inventory.

Recommendation 2: Enhance and Expand the Existing County’s Culvert Inventory 

We recommend that DPW’s Highway Maintenance Division refines and strengthens its existing culvert inventory to ensure it more effectively supports the management and maintenance of county-owned culverts.  This should include, but not be limited to:

Overview

Preserving the structural soundness and operational efficiency of culverts across Hawaiʻi County is pivotal to maintaining infrastructure functionality and durability, regulating water flow, and minimizing environmental impacts. 

Comprehensive policies and procedures ensure a prolonged lifespan, increase safety, and sustain efficiency.  While not explicitly highlighted, FHWA and various engineering associations, such as the National Society of Professional Engineers (NSPE), advocate for local governments and municipalities to develop meticulous protocols.  

 We reviewed FHWA guidelines, historical policies, and industry benchmarks, conducted on-site inspections, and interviews with appropriate management and staff.  Our assessment revealed the following:

• Our evaluation found that the Highway Maintenance Division was practicing a process for culvert maintenance; however, as of August 2023, formal written policies and procedures were lacking.  The last set of written policies and procedures, which were used in December 2011, are obsolete.  

• Highway Maintenance staff acknowledged the necessity of documented policies and procedures and confirmed efforts were underway to compile and formalize these essential guidelines.

• Subsequently, during the audit, the Highway Maintenance Division Chief took proactive steps.  In November 2023, written policies and procedures were formulated and disseminated among division staff. 

o Additionally, staff were encouraged to openly discuss any concerns or changes necessary to better integrate policies and procedures into daily practices.  

• In an effort to ensure all activities are considered and have appropriate guidance, DPW has contracted a consultant to identify, review and update all policies and procedures for the Highway Maintenance Division.

Our audit monitored the transition from a functional yet undocumented process to formalizing and distributing written policies and procedures.   

Overview

Bridge and culvert management depends on clear roles and responsibilities, eliminating confusion and ensuring task completion.  Defined roles streamline workflows for better prioritization and resource allocation, and risk management tasks, including assessments and emergency plans, are assigned, enhancing regulatory compliance.

The Government Accountability Office's (GAO) Greenbook Section 3.07 supports this approach, stating that management should assign key roles based on unit responsibilities, maintaining a clear accountability chain.  Effective management extends beyond task assignment, emphasizing the need for roles matched to individual expertise and qualifications, fair workload distribution to prevent burnout, clear communication for collaboration, and performance metrics to track role effectiveness and identify improvement areas.

Audit Activity

We reviewed relevant documents and guidance, policies, procedures, and past audits related to bridges and culverts, conducted site visits, and interviewed relevant management and staff.  Our review revealed the following:

• The Highway Maintenance and Engineering Divisions are not delineating their respective roles and responsibilities.  

• Hawaiʻi County Code Chapter 2, Section 2-41 assigns bridge and culvert maintenance to the Highway Maintenance Division:

(1) Engineering Division. The engineering division is responsible for coordinating the planning, engineering, and implementation of the highway and drainage capital improvement projects, coordinating all land surveying, conducting necessary land rights acquisition, and providing construction inspectional services. 

(4) Highway Maintenance Division. The highway maintenance division shall be responsible for the construction and maintenance of all roads, streets, highways, footpaths, storm drains, bridges, flood channels, and certain cemeteries.

• Historically, the Highway Maintenance Division was responsible for performing concrete spall and crack maintenance on bridges in addition to vegetation work requests.  

o Larger bridge and culvert repairs  (>20 feet or higher) that pose significant safety concerns or require equipment beyond the county's capabilities are not performed by the Highway Maintenance Division but are instead contracted out.

• In August 2021, the Engineering Division identified a partial collapse and undermining of the Wilder Road Culvert, possibly due to inconsistent maintenance.  The Engineering Division is currently in the design and permitting stage to reconstruct and replace the culvert, estimated to cost $3.4 million.  Without intervention, the road may experience significant undermining, leading to unsafe conditions and accelerated deterioration of the roadway and culvert. 

 • Additionally, challenges have emerged concerning timber bridge maintenance projects, such as the Kawainui Stream Bridge.  Meetings were conducted to coordinate and assign responsibilities for various project aspects.  When the Engineering Division requested a status update, the Highway Maintenance Division questioned the assignment of roles instead of providing the requested update. 

• The Highway Maintenance Division is responsible for storing and inventorying timber bridge deck materials.  In April 2023, Engineering requested an updated inventory.  To date, no inventory has been provided by the Highway Maintenance Division.

Cause of the Condition

The lack of clearly defined roles and responsibilities stems from a lack of communication and coordination within DPW, coupled with discrepancies between position descriptions and actual responsibilities regarding various bridge and culvert maintenance elements.  

Effect of the Condition

The absence of clearly defined roles and responsibilities has led to confusion and a lack of accountability, hindering the department’s ability to manage maintenance, allocate resources, and effectively fulfill its responsibilities in maintaining bridges and culverts. 

Finding 4: DPW lacks clearly defined roles and responsibilities over the department’s various duties. 

Recommendation 4: Establish Clear Roles and Responsibilities

We recommend that DPW work to thoroughly review its organizational structure and establish clear roles for all staff members, ensuring alignment with project needs and departmental objectives.  

Additionally, divisions should properly document communication to facilitate coordination and mitigate risks associated with ambiguous responsibilities.

Footnote: 2* Our audit did not include a detailed assessment of the underlying data or procedures used in the previous audit.  Therefore, we do not express an opinion on the effectiveness or accuracy of the work.  

Cause of the Condition

DPW has not fully developed mechanisms for effective interdepartmental communication.

Effect of the Condition

Persistent over time, the absence of strong communication mechanisms has led to challenges in project coordination, resulting in unresolved tasks, confusion regarding roles and responsibilities, and delays in maintenance timelines.

Finding 5: Interdepartmental communication plagues DPW, impacting maintenance oversight and productivity. 

Recommendation 5: Establish an Effective Communication Protocol

We recommend that DPW institute an effective communication protocol between the Engineering and Highway Maintenance Division.  This protocol should include, but not be limited to:

• Standardized reporting procedures
• Regular updates on maintenance statuses
• Training and guidelines on various assessments to improve accuracy in maintenance evaluations.    

Several water structures, like levees and floodwalls, are labeled inactive by the US Army Corps of Engineers due to poor conditions.  In the event of failure, Hawaiʻi County would be ineligible for funds under the Restoration and Inspection Program and responsible for covering the costs associated with the failure.

Overview

Maintenance, in accordance with FHWA Guidance on Highway Preservation and Maintenance, “describes work that is performed to maintain the condition of the transportation system or respond to specific conditions or events that restore the highway system to a functional state of operations.”  Maintenance includes both routine and preventive maintenance.

Routine maintenance includes tasks performed in response to short-term needs, like removing trash and graffiti or fixing storm or accident damage.  Preventive maintenance aims to prevent future deterioration and avoid costly repairs.  It includes cyclical maintenance, such as cleaning and sealing, and condition-based maintenance, such as replacing deck joints or repairing approach slabs.

The FHWA’s guide advises roadway agencies to establish vegetation management programs to determine optimal maintenance practices for each area.  Such a program involves various strategies like mowing, mechanical and hand brush cutting, herbicide use, livestock grazing, cultivating desired plants, and re-vegetation.

The USACE established the Rehabilitation and Inspection Program (RIP) to ensure the continued effectiveness of flood control projects in agreement with the FHWA.  This program applies to federal and non-federal projects, with inspections for rehabilitation needs and the condition of federally authorized hurricane/shore protection projects.

The primary goal of RIP is to maintain reliable flood protection for people, communities, and property.  It aligns with Public Law 84-99 (PL 84-99) and other relevant USACE authorities, emphasizing the responsible use of taxpayer dollars entrusted to the Corps.

Inspections go beyond the structures themselves.  They also consider stream characteristics like meandering, braiding, and sediment buildup.  Additionally, inspectors look for signs that might affect future stream changes, such as bridge debris buildup or historical accounts of flooding.
Failing to maintain these structures properly can result in a poor condition report, making them ineligible for RIP funding and potentially placing them in an "inactive" status.

Audit Activity

We reviewed historical records and documentation, including Department and Council records, conducted site visits to examine repair and maintenance efforts, reviewed other relevant guidance, such as work orders, and interviewed appropriate management and staff, compared to industry best practices and Federal regulations, and found:

• After inspections or public complaints, the Engineering Division assigns and forwards appropriate work orders to the Highway Maintenance Division for bridge and culvert maintenance.  

o These work orders detail each structure's condition and necessary maintenance, like deck cleaning or repainting.  
o The Highway Maintenance Division Chief is responsible for assigning the work.  
o Work orders are scheduled by District Road Overseers.  
o Not all work has been scheduled.  

• While some requests in the work orders are complex or costly, many are minor tasks such as removing debris from surfaces, cleaning and sealing bridge joints, painting bridge elements, and clearing vegetation.  Routine maintenance items typically do not involve substantial costs but require a maintenance schedule and adequately trained personnel.  

• Several water structures, like levees and floodwalls, are labeled inactive by the USACE due to poor conditions.  In the event of failure, Hawaiʻi County would be ineligible for funds under the RIP program and responsible for covering the costs associated with the failure.

• From September 2021 to June 2023, 116 work orders were generated for the Highway Maintenance Division to complete.  During this time, 26 of the 116 were completed, leaving 93, or 80% of the work orders, outstanding.  

• Further exacerbating the issue, Ordinance 2022-003, made effective July 1, 2022, by the Hawaiʻi County Council, prohibited glyphosate-based products, also known as weed killer,  in County parks and recreational facilities.  DPW voluntarily followed suit and prohibited using such products in July 2023.  DPW administration have provided some alternatives to help with vegetation maintenance and management, but staff have expressed concerns about whether these measures are sufficient.  

• Highway Maintenance Division staff expressed frustrations in their inability to properly handle vegetation growth with limited alternatives and noted vegetation growth occurs quicker in Hawaiʻi conditions.

Cause of the Condition

The Highway Maintenance Division lacks a schedule for prioritizing and managing routine maintenance and repairs.

The Engineering Division does not provide deadlines for work order requests to be completed.

DPW’s decision to voluntarily prohibit the use of certain products potentially increases the demand for maintenance and repairs as the department works to rebalance its workload.  

Effect of the Condition

The Highway Maintenance Division’s lack of maintenance schedules and the Engineering Division’s absence of work order deadlines cause inefficiencies in handling routine maintenance and repairs. 

DPW’s decision to voluntarily prohibiting the use of certain products increases pressure to conduct more frequent routine maintenance. 

Finding 6: DPW lacks a maintenance schedule and clear deadlines to effectively manage the County’s bridges and culverts.  

Recommendation 6: Develop and Implement a Maintenance Schedule

We recommend DPW develop a comprehensive maintenance schedule inclusive of but not limited to:

• Develop a cohesive maintenance schedule for various tasks to reduce unnecessary work orders while increasing timeliness, consistency, and overall efficiency.

• Implement a data monitoring system to oversee, verify, and provide details related to maintenance and repair activities.

• Improve collaboration efforts between the Engineering and Highway Maintenance Divisions and other stakeholders to strengthen communication defining expectations and goals.

Overview

Inspecting bridges and culverts under the NBIS represents a key aspect of infrastructure management, ensuring their safety, functionality, and longevity.  In many cases, governmental bodies, or private entities responsible for infrastructure maintenance often rely on engineering contractors to conduct these inspections.  While this approach can offer several benefits, such as expertise, efficiency, and cost-effectiveness, it also presents certain challenges and potential risks, particularly when there’s a lack of independent confirmation or review of the inspection findings.  

Independently inspecting bridges and culverts and conducting sampling is necessary for verifying contractor findings, ensuring quality, and reducing errors.  It mitigates risks, demonstrates compliance, and streamlines the process, minimizing back-and-forth edits between DPW and contractors.

• Contracted engineers expressed concerns regarding edits and changes requested by DPW to reports.  Contractors stated that of the three state counties they conduct inspections for, Hawaiʻi County is the only jurisdiction that scrutinizes the reports to such an extent, which may prolong the time it takes for the contracted engineers to complete and publish the required reports. 

o Despite these delays, Hawaiʻi County has not had past due or late bridge inspection reports as required by the NBIS.  

• Drawing out timelines further, comments by DPW are not all requested after the initial review.  Occasionally, the drafts are returned to the contractors three to four times with additional comments.

o The current bridge inspection program manual requires inspectors to specify the precise location and measurements of defects in close-up photos.  DPW frequently asks contractors to incorporate redundant details into overall images referring to defect details observed and noted in close-up photos.  Replicating these notes in the overall photo is unnecessary and can sometimes clutter the image. 

o Defect sizes are requested to be added to photos when the information is noted in the photo’s caption. 

o Historically, contractors would mark crack locations and measurements using arrows.  Instead, DPW requested cracks be indicated by drawing a line over their length in the photos.  This change has two drawbacks: 

1. Cracks are no longer naturally visible in the image.

2. It becomes challenging for future inspectors to visually discern differences between inspection photos and the real-time condition of the crack.  

Cause of the Condition

DPW’s Bridge Section staff does not accompany contracted engineers on inspections to confirm what is being reviewed.

Effect of the Condition

Increased edits and questions from the Engineering Bridge Section delayed the publishing of required reports.  Additionally, DPW cannot independently confirm the condition of various structures without at least completing spot checks or sample testing on bridges inspected during the year. 

Finding 7: DPW Lacks a Process for Independent Reviews.

Recommendation 7: Establish a Process for Independent Reviews
We recommend that DPW’s Bridge Section establish processes to verify and confirm accuracy and continuity in contracted bridge inspections.  

As a practice, we remain mindful and document instances of fraud, waste, and abuse within the scope of the audit objective and not specifically Countywide.
Management reported no fraud, ongoing investigations, or pending litigation that may impact this audit. 

What is Waste?
“Waste” involves needless and careless expenditures of county funds or the misuse or mismanagement of county resources and property.  Waste can be both intentional or unintentional.  

The deferral of necessary maintenance tasks, intended to preserve infrastructure conditions and prolong operational life, has led to considerable inefficiency.  This delay elevates routine maintenance into substantial capital projects, escalating expenses, and strains public funds.

This trend represents a hazard to public safety.  Postponing maintenance raises the probability of infrastructure failure, potentially causing severe consequences.  Failing to address maintenance requirements promptly increases costs and jeopardizes public welfare, emphasizing the critical necessity of prioritizing timely maintenance practices.

Ultimately, the lack of investment in proactive maintenance wastes resources and poses a significant risk to public safety, thus contributing substantially to inefficient expenditure within the Department of Public Works.

In closing, the improper use of government resources or positions are commonly uncovered by employees and the public.  We strongly encourage reporting of any concerns through our fraud and whistleblower hotlines: 

Fraud and Waste Hotline: 
Whistleblower Hotline: (808) 480-8213
(808) 480-8279
Email: concern@hawaiicounty.gov 

Fax Number: (808) 961-8905
Mail: Office of the County Auditor
        120 Pauahi St. Ste. 309
         Hilo, HI 96720

Through our evaluation of the Department of Public Works’ (DPW) practices and procedures related to bridge and culvert maintenance, we determined that while DPW generally complies with the FHWA’s NBIS for inspection processes, there are notable areas needing improvement.

Notably, DPW’s failure to fully comply with Hawaiʻi Revised Statutes (HRS) Chapter 464, which mandates that key engineering functions be overseen by licensed professional engineers, raises concerns. The current lack of qualified engineering oversight in some areas exposes the County to potential legal risks and compromises the integrity of inspection and maintenance operations.

In addition to this statutory non-compliance, deficiencies in inventory management, procedural guidelines, information accessibility, and staff training were noted. These gaps hinder effective culvert management and may compromise full compliance with FHWA standards. Unclear delineation of responsibilities between the Highway Maintenance and Engineering Divisions leads to inefficiencies, conflicts, and project delays, affecting task statuses, roles, and overall staff expectations.

Increased issues in vegetation management due to restrictions on certain products and delays in completing work orders further impede maintenance efforts and could lead to increased future costs. Restrictions on certain products compound these issues. Furthermore, interactions between DPW staff and contracted engineers regarding inspection reports reveal concerns about efficiency and clarity, with scrutiny over inspection reports and redundant detail requests potentially delaying report completion and compromising future inspections’ effectiveness.

In conclusion, addressing these challenges requires a comprehensive approach that includes improved communication and coordination, clarification of roles and responsibilities, compliance with HRS 464 requirements, enhancing inspection processes, and providing adequate resources for maintenance and vegetation management. By tackling these issues, the Department of Public Works can better ensure compliance with FHWA standards and other relevant regulations while safeguarding the integrity of the County's bridges and culverts.

To improve government accountability and ensure audit recommendations are implemented or resolved, we will continuously monitor the status of pending recommendations using our remediation tracker.  To view the status, visit us at: https://www.hawaiicounty.gov/our-county/legislative/office-of-the-county-auditor/remediation-tracker