Below are my comments i am sending to the Dept. of Interior’s “Procedures for Reestablishing a Formal Government-to-Government Relationship with the Native Hawaiian Community”. https://www.doi.gov/ohr/hawaiian-govt-to-govt-procedures-proposed-rule

This is targeting a specific participation requirement for Federal Recognition, not addressing the history of our 200 year relationship.

If you agree, please submit the same comments or your own comments under your own name by Dec 30, 2015. http://www.regulations.gov/#!docketDetail;D=DOI-2015-0005

Subject: The “affirmative” voter participation threshold should be 55,000 to 90,000, not 30,000 to 50,000

The minimum “affirmative” voter participation threshold to accept a formal request for Federal Recognition should be 55,000 to 90,000, not 30,000 to 50,000. Referring to criteria § 50.16 (g).

The Dept. of Interior (DOI) calculations of voting age Native Hawaiians is based on census data of 527,000 in the U.S. and 290,000 in the State of Hawaii. 65% are voting age, so 65% of 527,000 = 342,550. 65% of 290,000 is 188,500.

“But those figures do not include Native Hawaiian voters who reside outside the State of Hawaii, who also could participate in the referendum; the Department believes that the rate of participation among that group is sufficiently uncertain that their numbers should be significantly discounted when establishing turnout thresholds.” pg.43, NPRM Part 50 9.29.15

Even if the DOI cannot calculate the voter participation numbers for mainland Native Hawaiians, that doesn’t mean they should be discounted. We are Native Hawaiians, and we are recognized as U.S. Citizens of voting age.

DOI’s expected participation rate is between 60,000 and 100,000. So the minimum “affirmative” threshold to show community support will be 30,000. If you factor the total Native Hawaiians of voting age in the U.S. the correct minimum “affirmative” voter participation threshold should be 30,000 / 188,500 x 342,550 = 54,517 votes. The top range should be 50,000 / 188,500 x 342,550 = 90,862 votes.

55,000 votes in the “affirmative” for ratifying a Native Hawaiian Governing Entity document must be the minimum number for the Secretary of Interior to accept a formal request for Federal Recognition. Anything less will fail “to demonstrate broad-based community support” and should be rejected outright. The reasonable total demonstrating “broad-based community support” should be 90,000 affirmative votes.