Office of Information Practices

U Memo 26-03
August 29, 2025
Airport Shuttle Contract Records

Requester had previously contracted with the Department of Transportation, Airports Division (DOT) to run the Honolulu Airport’s Wiki Wiki shuttle bus (Wiki Wiki).  Requester bid on the next two-year Wiki Wiki contract, but it was awarded to another company, and DOT also entered into an emergency contract with that company for the period between the end of Requester’s contract and the beginning of the new two-year contract.  Requester made two requests to DOT for records concerning both the two-year and the emergency Wiki Wiki contract.  Requester appealed DOT’s partial denial of both requests to OIP.

OIP found that with some exceptions, DOT’s correspondence withheld to protect the attorney-client privilege was confidential and was for the purpose of facilitating the rendition of professional legal services to the client, and OIP therefore concluded that DOT properly withheld the majority of the records for which it claimed attorney-client privilege, based on that privilege as recognized under section 92F-13(3), HRS, and other UIPA exceptions.

OIP concluded that disclosure of a full federal employee identification number (FEIN) would not frustrate one of DOT’s legitimate functions by causing it to violate Rule 5.2, Federal Rules of Civil Procedure.  OIP also found that disclosure of a business’s full FEIN would not impair the competitive position of that business or impair the government’s ability to get FEINs in the future, so OIP concluded that DOT could not redact any part of the FEINs based on the UIPA’s frustration exception.  OIP concluded that DOT must likewise disclose full unemployment insurance policy numbers.

Regarding the permit decal numbers for vehicles authorized to drive on the runways and in other aircraft-focused portions of an airport, OIP found that DOT had not showed how disclosure of the decal number of an authorized vehicle would be likely to allow circumvention airport security measures and thus fall under the UIPA’s frustration exception, and  concluded that the decal numbers must be disclosed.

DOT redacted several home addresses from certifications of two individuals’ registered mechanic status.  Although the UIPA’s privacy exception typically authorizes withholding an individual’s home address, OIP has previously concluded that when an individual’s home address is used as that individual’s business address as the holder of a license or permit from a government agency, the home address must be disclosed because it is expressly made public by section 92F-12(a)(13), HRS.  OIP concluded that the addresses were made public by section 92F-12(a)(13), HRS, and must therefore be disclosed.

Finally, OIP found based on DOT’s representations that DOT (1) searched the email accounts of the employees involved in the relevant contracts and negotiations, and other record locations that were reasonably calculated to uncover all relevant documents, using keywords drawn from the subject matter of the requests; (2) used methods that could be reasonably expected to produce the information requested; and (3) did in fact identify of more than 5000 pages of responsive records for the two requests.  OIP therefore concluded that DOT made a reasonable search for records responsive to the requests, and met its UIPA obligations in that respect.