Prologue — Maneja v. Waialua Agricultural Co.

Supreme Court brief1955

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Supreme Court of the United States

OCTOBER TERM, 1954

No. 357

CIRACO MANEJA, ANTONE VIERRA, TADAO

WATANABE, ET AL., PETITIONERS,

vs.

AIALUA AGRICULTURAL COMPANY, LIMITED

es No. 358

AIALUA AGRICULTURAL COMPANY, LIMITED

PETITIONER,

vs.

CIRACO MANEJA, ET AL.

N WRITS OF CERTIORARI TO THE UNITED STATES COURT OF

APPEALS FOR THE NiNTH CIRCUIT

_No. 13114 _

———————————————————

United States

Court of Appeals

for the Linth Circuit.

WAIALUA AGRICULTURAL COMPANY,

LIMITED, a Corporation,

Appellant.

vs.

CIRACO MANEJA, et al.,

Appellees.

Cranscript of Record

In Two Volumes

Volume I

(Pages 1 to 402)

Appeal from the United States District Court

for the District of Hawaii.

——— —— = = — — = — a

Priinps G@ Vor Orden Lo. 870 Brannan Street San Francisco Colt

INDEX

[Clerk’s Note: When deemed likely to be of an important nature,

errors of Gobtful roatters appearing in the original certified record

are printed literally in italic; and, likewise, cancelled matter appear-

ing in the original certified record is printed and cancelled herein

accordingly. When possible, an omission from the text is indicated by

= : italic the twe words between which the omission seems

0 occur.

PAGE

Additional Findings of Fact................. 308

SII HI i ooo co ck bio ont a ew sv.ob Wa 6

ME Ae INE c o'¢s;- S cee sb OR Ne Bs 15

Amendment to Amended Complaint........... 18]

Amendment to Answer to Amended Complaint,

and Counter-Claim, Cross-Claim, and Cross-

DONE So ORG ia ae ae oy is anon 24

Amendment to Stipulation. .................. 179

Answer to Amended Complaint, and Counter-

Claim, Cross-Claim and Cross-Complaint.... 16

Re re Se ee 670

Declaratory Judgment and Judgment Awarding

Defendants Overtime Compensation, Liqui-

dated Damages, Costs and Attorney's Fees... 321

Exhibit, Defendants’:

No. 2—Plantation Organizations.... .... 639

Exhibits, Plaintiff's:

A—Waialua Agric. Co., Ltd., Daily Time

Sheets for Machine Shop. ...0..0..... 661

B—Waialua Agn. Co., Ltd... Emplovee’s

en ls oe ee et GH7-A

C-——Waialua Agric. Co. Ltd., Employee's

Time Reeord.....

il Watalua Agricultural Co., eve.

INDEX PAGE

Motion as to Non-Printing of Defendants’ Ex-

bibits Mos. SA ONE SB... 2 ccc ccctcccccess 711

ee eee ee rer rere er 712

Motion as to Non-Printing of Parts of Original

ee eee er eee 713

ee ee I oa crane aevee ede cus ees 719

Motion to Reopen Record................... 184

Order Reopening Record.............. . 185

Names and Addresses of Attorneys........... |

OO a EOP oe fee ore ee ere ere re 339

Opinion and Decision of Court............... 190

a ee ee ee 190

Order to Drop Certain Parties Defendant... .. 4

Order to Drop Certain Parties Defendant and

to Eliminate Class Representation Aspects... 4

Order Granting Motion for Additional Find-

EES ERIE D SB TR OPI ET TO 307

Order Setting Aside Prior Order Granting

Separate Trial of Certain Issnes........... d

Reply and Answer to Counter-Claim, Cross-

Claim, and Cross-Complaint.......0....0.... 20

Second Amendment to Stipulation... .... a<

Statement of Points on Which Appellant) In-

FR ean AN fe rer ene ae Oy.

vs. Ctraco Mane ja, et al. iil

INDEX PAGE

Stipulation Filed August 30, 1950.00.00... .. 27

ee 129

G—Date Schedule of the Off Seasons for

All Plantations in the Territory From

eC 177

H- Charge Which is Made to Labor, Ma-

terials, Sundries and Departmental

Services to All Direct Operating

OMEN sot ctsye eo ee! 178

S‘ipulation as te Original Papers in File to Be

Transmitted to Appellate Court.......... 340

Transcript of Proceedings................... 343

Witnesses, Defendants’:

Clannan, Damaso

ES ves 645555 Lae ce HOG

Crisostomo, Roque

ewido re have ba) 5O4

Cumlat, Simeon

SS a HH]

Kzawa, Masaru

ee oo

Faria, Barney

ed hae is ae eee 3. 6800

Fujiwara, Margaret

se eee — 403

SE 1+ 44:64 58 ob oe ka wou ak _ 416

-redirect ........ eae Cree 416)

WUE 6c ts tbe cee ene Se

iv Waialua Agricultural Co., ete.

INDEX PAGE

Witnesses, Defendants’ —(Continued) :

Hayashi, Tsuruo

TE ga a Pee ares a er Soe 445

Eee SRS at el Baa Pee AO ya pr a ee) ee 451

N90 en a a 456

Holm erg, Peter

Sl RE PP era 433

EN, etre eb Cort ea a te a 44?

oil ct OS se che ap Te ar 444

Kashiwabara, Tosnio

SE cc v'enwhaskcceeeuneaeeees 421

ME a docs peat AON aes 428

ee eee ere 430

WII oon cG as «ste ee es cree? 4353

Kibota, Haru

DS RR EL So APE 465

Sen. «i. ws ose wea ee eee CEE WES 474

Lorenzo, Augustine

a ee rae a re ae 458

Maneja, Ciraco

ee ee ree ae 481

ME oe a ee ok eee Ute 489

vs. Ctraco Maneja, et al.

INDEX

Witnesses, Defendants’—( Continued) :

Mori, Edwin

WD Siw wes xo ve C'ieb wk seueveey,

Oato, Masaiki

cc ae EE eee

Pacheco, Louis

ie gh, OEE OPE Oe Be Re

I Ah th'y o's 6 + pa otha db oe he kek

Reyher, Alfred

WOE 65.9 0 vole vp baie oe Sain Oe tas

Robello, Seraphine

It 9.5550 G4 dots ovine head oak:

Takata, Hirosaku

a, a oS es me

Tanaka, Toshio

eae eee

Watanabe, Tadao

PE OS ane ious < 0-6 dec

Yamada, Yoshiji

i

————— se eee

Vv

PAGE

vi Waialua Agricultural Co., etc.

INDEX PAGE

Witness, Plaintiff's:

O'Donnell, Raymond John

PE 6s coe kW ee bw Wed kee es

NO occas wae c a Kaen eu Eee 6s 377,

NE 55 ok cane bh eedes ts 652,

a ceekbadeheeriaranets

Kixhibits Attached to Stipulation of Facts:

Ex. A—-Map of Plantation

D-—Map of Transportation System

F—Plantation Building and Yard Area Show-

ing Mill, Shops, Warehouses, ete.

I—Non Plantation Buildings Watalna Aert-

cultural Co., Ltd.

Proceedings in the United States Court of Appeals for

the Ninth Cirenit

Opinion, Fee, J.

Judgment

(pinion, fee, Jd. of petition for rehearing

Order denying petition for rehearing

Opinion, Metzger, J. of the United States District

Conrt for the District of Tlawati

( pinion, ee, J.

Order extending tine to file petition for writ of cert

Orders granting certiorari

6253

659

656

shi

NAMES AND ADDRESSES OF

ATTORNEYS OF RECORD

For the Plaintiff, Waialua Agricul’urai Company,

Limited,

RUFUS G. POOLE, ESQ..

1625 K Street, N. W.,

Washington 6, D.C.

LIVINGSTON JENKS, ESQ..

ANDERSON, WRENN & JENKS,

Bank of Hawaii Building,

Honolulu, Hawaii.

ERNEST C. MOORE, J R., SSQ.,

PRATT, TAVARES & CASSIDY,

Alexander & Baldwin Buiiding,

Honolulu, Hawaii.

MILTON ©. DENBO, ESQ.,

1625 K Street, N. W.

Washington 6, D. C.

For the Defendants, Ciraco Maneja, et al.,

RICHARD GLADSTEIN, ESQ..

GLADSTEIN, ANDERSEN & LEONARD,

240 Montgomery Street,

San Franeisee, California.

In the District Court of the United States

for the District of Hawaii

Civil No. 737

WALALUA AGRICULTURAL COMPANY,

LIMITED,

Piaistiff,

Vs.

CIRACO MANEJA, ANTONE VIERA, At

GUSTINE LORENZO, HARU KIBOTA,

TADAO WATANABE, KOLCTIL OKOUCHE,

TSURUO HAYASHI, CORNELIO| ASUN-

CION, ROQUE CRISOSTOMO, PETER

HOLMBERG, HATSUSUKE SERA, TA.

KUMI OKOUCHI, PEDRO DUMLAO.

BERNABE HERNANDEZ, DOMINGO GUI

GUI, USHINOSUKE KONDO, TERUTLCHI

KUBO. MASAIKI OATO, SIMON CUM

LAT, APOLONTO. LAZO, GILCHILT HAMA

MOTO, DIONTOTO CARRIT, SERAPHINGE

ROBELLO, TOSHLO TANAKA, BARNEY

FARTA, FUMIO SUNATIARA, HIROSAKU

TAKATA, ALFRED REYHER. MASARU

EZAWA, DAMASO CLAUNAN, ANTONE

ROBELLO, YOSHIJT YAMADA. EDWIN

MORI, GENITRO THIRONAKA, JTRO

SAKAI, MARGARET FUJIWARA, LOUIS

PACHECO, YUKISHIGE TSUTSUL YAcK

CHUN LER. FIKO SAKAGUCHI, MOSES

FERNANDEZ, AND TOSHIO KASHIWA-

BARA,

Defendants.

4 Waralea Agricultural Co., ete.

ORDER PO DROP CERTAIN PARTLES

DEFENDANT

li pom motion of the plaintiff pursuant to Rule

“to of the Rules of Civil Procedure, Which motion

Was ooblserites te by the deienedants, vund it appear

ing te be just and reasonable co the Court, it ts or

dered that Takeo Mivazaki, Gerth: Lendio, De-

mingwe Menor Kirehi Varnada, Mataiel Danas ane

Keiehi NRamivama be dropped as partios defendant

to this getion,

Dated Honoluin, ‘TP. HL. this 21st day of August.

1990.

s DD. BE. METZGER,

Judge of the United States Distriei Court for the

Destriet of Phawan.

{Rndorsed]: Filed August 21, 1990, [5°]

[Tithe of District Court and Cause.J

ORDER TO DROP CERPAIN PARTIES DE

PENDANT AND TO ELIMINATE CLASS

REPRESENTATION ASPECTS

Upon motion of plaintiff, which motion was con

sented to by the defendant, and it appearmg to be

just and reasonable to the Court—

It Is Ordered that, pursuant to Rule 21 of the

Kederal Rules of Civil Procedure, Loeal 145-7 of

the International Longshoremen’s and Warehouse

~* Page numbering appearing at toot of page of original Reporter's

Transcript of Record.

vs. Ciraco Mane ja, et al. 5

men’s Union, and Jack Hall, Regional Director,

Territory of Hawaii, of the liternational Long-

shoremen’s and Warcehousemen's Union. he dropped

as parties lefendant to this action: [>]

It Is Further Ordered that all class representa

Hien aspects of this aetion he elimunated and that

the presently retnaling partios defendant In this

action be sued in their individual capacities only

wind mot as representatives of othe. einiplovees of

plainvifi whe are stmitlarly situated,

Dated Honolulu, T. H.. this 2Ist day of Angust,

1950).

s/ ID. ELM ETZGER,

Judeo of the United States Distriet Court for the

District of Hawaii.

[Endorsed]: Filed August 21, 1950, [6]

[Title of Distriet Court and ¢ ‘ause, }

ORDER SETTING ASIDE PRIOR ORDER

GRANTING SEPARATE TRIAL OF CER-

TAIN ISSUES

The order of this Court tiled March 22, 1948, di-

recting a separate trial of certain issues in this ae-

tion is hereby vacated and set aside.

It is further ordered that all Claims and issues

presented in this action shall be heard and tried

Jointly.

6 Waialua Agricultural Co., ete.

Dated Honolulu. T. H.. this 21st day of August,

1950.

/s/ D. E. METZGER,

Judge of the United States District Court for the

Distriet of Hawaii.

[Endorsed]: Filed August 21, 1950. [8]

ae ne

[Title of District Court and Cause. ]

AMENDED COMPLAINT

I.

Autlegations of Jurisdiction

The Complaint filed in this action on April 9,

1947, and as subsequently amended on July 18, 1947,

is hereby amended to read as follows:

1. This action arises under the Fair Labor

Standards Act of 1938 (the Act of June 25, 1938,

92 Stat. 1060, 29 U.S.C. Sections 201 et seq.) here-

inafter sometimes called the ‘‘Act,’’ which is a law

regulating commerce, and is brought to secure a

declaratory judgment. This court has jurisdiction

pursuant to Section 24 of the Judicial Code ag

amended, 28 U.S.C. Section 1337 and pursuant to

Section 274d of the Judicial Code, 28 U.S.C. See-

tion 2201. [10]

II.

Parties and Nature of Action

2. Plaintiff is a corporation duly organized and

existing under and by virtue of the laws of the Ter-

vs. Ctraco Mane ja, et al. T

ritory of Hawaii, with its head office located in the

City and County of Honolulu, Territory of Hawaii,

and with a plantation, where it produces sugar cane,

processes it into raw sugar and conducts related

operations, located in the District of Waialua, City

and County of Honolulu, Teritory of Hawaii.

3. All defendants are employees of Plaintiff who

Were engaged in performing work on or about the

Plaintiff’s plantation during the period of time

from November 20, 1946, to September 14. 1947,

both dates inclusive.

ITI.

Plaintiff's Operations and Duties of Defendants

4. Since the incorporation of Plaintiff iy 1898,

it has been engaged almost exc.usively in the grow-

ing, cultivating and harvesting of sugar cane on

land owned or leased by it, and the processing of

such sugar cane into raw sugar and molasses on the

plantation where produced. Luring the period of

time from November 20, 1946, to September 14,

1947, the Plaintiff has not processed any cane ex-

cept that grown by itself on its plantation, nor has

it engaged in any sugar refining operations. Sub-

stantially all of the land (9663 acres) devoted to

Sugar cane production during said period of time

has been owned or leased and used by Plaintiff for

this purpose since 1910.

». On its plantation during the period from No-

vember 20, 1946, to September 14, 1947, Plaintiff

prepared and plowed the fields for the planting of

8 Waalua Agricultural Co.,, ele.

sugar eane; planted sugar eane; [11] ratesned the

fields; cultivated sugar cane; applied fertilizer to

the cane fields; irrigated cane fields by a network

of irrigation ditches and water storage reservoirs;

harvested sugar cane; maintained a network of field

roads (which criss-erossed the cane-growing land )

for the transportation by truck of labor, field sup-

plies and equipment throughout the plantation; and

transported sugar cane by a narrow-guage railroad

(which also criss-crossed the cane growing land)

from the fields where grown to the Plaintiff’s mill.

6. The Plaintiff's mill was located on its plan-

tation. At the mill during the period from Novem-

ber 20, 1946, to September 14, 1947, the Plaintiff

ground the sugar eane into raw sugar and molasses

and loaded bagged raw sugar and molasses for ship-

ment to the continental United States. The loading

of the bagged raw sugar and of the molasses into

the railroad cars of an independently owned and

operated carrier at the site of the mill and the push-

ing of such cars from such site onto a nearby spur

of the carrier, completed the operations of the

Plaintiff and the work of its employees relative

thereto.

7. During the period from November 20, 1946,

to September 14, 1947, Plaintiff had equipped and

maintained complete service shops for prompt

minor repairs and emergency work and major over-

haul of agricultural and processing machinery,

equipment and facilities indispensable to its grow-

ing. harvesting and processing operations. ‘These

us. Ciraco Mane ja, et al. i)

service repair shops were located in an area extend-

ing not more than 300 fee from the mill building

proper,

8. During the period from November 20, 1946, to

September 14, 1947, Plaintiff owned and Inamtained

820 dwelling houses, all [12] of which were located

on the plantation; various facilities and services

were provided the occupants of such dwelling

houses. During said period these dwelling houses

Were occupied by 3373 persons, of whom 2952 were

employees and pensioners of the Plaintiff and their

families. The remaining 421 persons living in such

heuses were persons and their families who were

not employed by the Plaintiff and who either

worked off the planiation or who owned, operated

or were employed by independently controlled busi-

nesses within it. No employee, including each of

the defendants herein, was required during said

period of time or at any other time as a condition

of employment to live on the plantation or in plan-

tation dwelling houses or to use any service or faeil-

ity which the plantation furnished or rendered its

employees. The relationship which existed between

the Plaintiff and its employees by virtue of the ov-

cupancy of such houses, including each and every

employee Defendant herein, during the period of

time involved in this suit, was that of landlord and

tenant.

9. During each and every workweek of the pe-

riod involved herein, namely from November 20,

1946, to September 14, 1947. both dates inclusive,

10 Waialua Agricultural Co., ete.

the Defendants were engaged on Plaintiff's plan-

tation in growing, cultivating, harvesting and proc-

essing sugar cane and in performing various opera-

tions incidental and functionally necessary and in-

dispensable thereto and in repairing and maintain-

ing dwelling honses of the Plaintiff that were lo-

cated op the plantation and in furnishing related

facilities and services to the occupants of such

dwelling houses. During each and every workweek

of the said period of time, each and every Defend-

ant generally worked in excess of forty hours. [13]

During said period Plaintiff generally did not pay

any Defendant overtime compensation in accord-

ance with the standards of Section 7(a) of the Act

in that Plaintiff generally did not pay any Defend-

ant overtime compensation for all hours worked by

him in excess of 40 per workweek. In such instances

where during said period Plaintiff did pay any of

said Defendants overtime compensation for all hours

worked by him in excess of 40 per workweek there

is a controversy between the parties as to whether

the Act required such payment.

IV.

Statement of Controversy

10. The controversy between the parties hereto

relates to the judicial construction of Sections 3(b),

3(f), 3(j), 6, 7(a), T(«) and 13(a) (6) of the Act,

and the application of those sections of the Act to

the work performed by the Defendants during the

period of time from November 20, 1946, to Septem-

ber 14, 1947, both dates inclusive. The meaning and

vs. Ciraco Mane ja, et al. 11

scope of these provisions have been the subject of

a serious dispute for inany years between the Plain-

tiff and the Defendants.

Il. Plaintiff contends:

(a) That during each and every workweek from

November 20, 1946. to September 14, 1947, both

dates inclusive, each and every Defendant was an

employee, ‘employed in agriculture’ as the term

‘agriculture’? was defined in Section 3(f) of the

Act and that, therefore, each said Defendant was

exempt during each workweek of said period from

the overtime provisions of the Act. l.e., Section 7(a),

as provided by Section 13(a) (6) of the Act;

(b) That during each and every workweek of

said period of time each and every Defendant, when

engaged in the hauling [14] of sugar cane from

the fields to the mill, the processing of sugar

cane into raw sugar and in their incidental and

functionally necessary and indispensable operations,

was also exempt from the overtime provisions of the

Act, i.e., Section 7(a), as provided by Section 7(c¢)

of the Act; and

(c) That during each and every workweek of

said period of time each and every Defendant, when

engaged in work in connection with the repair and

maintenance of Plaintiff’s dwelling houses and the

furnishing of related facilities and services to

Plaintiff's employees and others vecupying such

houses under a landlord-tenant relationship with

Plaintiff, was not “engaged in commerce or in the

production of goods for commerce” as the terms

12 Waialua Agricultural Co., ete.

*commerce’’ and ** produced” were defined in See-

tions 3(b) and 3(j) of the Act and that, therefore

none of the overtime provisions of the Act applied

to any said Defendant when he was so engaged dur

ing said period; and that even if any Defendant

was “engaged in commerce or in the production of

goods for commerce,”’ as the terms * commerce” and

‘“produced’’ were defined in the Act, during any

workweek of said period of time, he was exempt

from the overtime provisions of the Act by virtue

of Section 13(a) (6) or 7(¢).

12. The Defendants deny each and every con-

tention and allegation of the Plaintiff as set forth

in Paragraph 11 of this Amended Complaint.

V.

Necessity for Relief of Declaratory Judgment

13. The meaning of the agriculture and agricul-

tural processing exemptions in the Act and the scope

of its coverage have long been a subject of contro-

versy between Plaintiff and its [15] employees in-

cluding each and every Defendant herein. The

Plaintiff is in need of relief of declaratory judg-

ment in order to avoid:

(a) A multiplicity of suits under Section 16(b)

of said Act with consequent vexation, cost and ex-

pense of defending said suits;

(b) Suits brought under Section 16(b) of the

Act in different jurisdictions—in the United States

District Court or Territorial Courts—and the de

“ie

vs. Ciraco Mane ja, et al. 13

lays incident to final determination and the chances

of different adjudications by different jurisdictions:

(©) Delays in settlement of the controversy if

final determination of the legal questions is left to

adjudication in various suits brought under Seetion

l6(b): and

(d) Great expense in paying overtime compen-

sation in accordance with the standards of Section

7(a) of the Act and the Defendants’ contentions.

VI.

Prayer

Wherefore, Plaintiff respectfully prays that it

may be declared, ordered, adjudged and decreed as

follows:

(a) That during each and every workweek of

the period involved herein each and every Defend-

ant was an employee “employed in agriculture’ as

the term “‘agriculture’’ was defined in Section 3(f)

of the Act and that, therefore, each said Defendant

was exempt during each workweek of said period

from the overtime provisions of the Act pursuant to

the provisions of Section l5(a) (6);

(b) That during each and every workweek of

the period involved herein, each and every Defend-

ant, when engaged in the (16] hauling of sugar cane

from the fields to the mill, the processing of sugar

cane into raw sugar, and in their incidental and

functionally necessary and indispensable operations,

was also exempt from the overtime provisions of the

Act by virtue of Section Te) thereof: and

14 Waialua Agriculturai Co., cte.

(©) That during each and every workweek of

the period involved herein each of the Defendants,

when engaged in work in connection with the repair

and maintenance of Plaintiff's dwelling houses and

the furnishing of related facilities and services to

Plaintiff's employees and others occupying sue.

dwelling houses under a landlord-tenant relationship

with Plaintiff, was not ‘‘engaged in commerce or in

the production of goods for commerce” as the terms

‘‘commerce’’ and ‘**produced’’ were defined in See-

tions 3(b) and 3(j) of the Act; and that even if any

Defendant was ‘‘engaged in ecommerce or in the

production of goods for commerce”’ during any

workweek of said period of time, he was exempt

from the overtime provisions of the Act by virtue

of Section 13(a) (6) or 7(¢).

Plaintiff further prays for such other relief as to

the Court may seem just and proper.

Dated at Honolulu, T. H., this 21st day of August,

1950.

/s/ RUFUS G. POOLE,

/s/ LIVINGSTON JENKS,

ANDERSON, WRENN &

JENKS, |

/s/ ERNEST C. MOORE, JR.,

PRATT, TAVARES &

CASSIDY,

Attorneys for Plaintiff.

1 eonsent to the filing of the above-Amended

Complaint.

/s/ RICHARD GLADSTEIN,

Attorney for the Defendants.

vs. Ctraco Vane ja, et al. 15

(Title of District Court and ¢ ‘ause.]

UNITED STATES MARSHALS RETURN

The within Amended Complaint was received by

me on the 21st day of August, A.D. 1950. and the

same is returned duly executed by me this 22nd day

of August, A.D 1950, upon Richard Giladstein, At-

torney for the Defendants, by handing to and leay-

ing with Myer C. Symonds, Attorney, Merchant

Street, Honolulu, T. H., at the request of Richard

Gladstein, Attorney for the Defendants, a certified

copy of the original Amended Complaint, at 9:20

a.m,

Dated at Honolulu, T. H., this 22nq day of Au-

gust, A.D. 1950.

OTTO F. HEINE,

U. S. Marshal, District of

Hawaii.

By /s/ EMMANUEL U. MOSES, JR.,

Deputy.

[Endorsed]: Filed August 21, 1950. [18]

16 Waialua Agricultural Co., ete.

[Title of Distriet Court and Cause. ]

ANSWER TO AMENDED COMPLAINT, AND

COUNTER-CLAIM, CROSS-CLAIM AND

CROSS-COMPLAINT

Come now the defendants above named, and an-

swering the Amended Complaint on file herein, and

further by way of and as a Counter-Claim, Cross-

Claim and Cross-Complaint against the plaintiff

named above, deny, admit and allege as follows:

I.

Admit the allegations contained in Paragraphs 1,

2, 3, 4 (except as hereinafter denied), 5, 6 (except

as hereinafter denied), 7, 8 (except as hereinafter

denied), 10, 11, 12 and 13 of the Amended Com-

plaint. [20]

LT.

In reference to Paragraph 6 of the Amended

Complaint, defendants allege that during the period

covered by this action the plaintiff company, to-

gether with thirty other sugar plantation companies

operating in the Territory of Hawaii, and compris-

ing the vast majority of such companies in said Ter-

ritory, and producing in excess of seventy-five per

cent of the total sugar produced in said Territory,

were members and in control of the California and

Hawaiian Sugar Refining Corporation, Limited, a

California cooperation, which had been and was

qualified as a eooperative marketing association

under the Federal Capper-Volstead Act and under

the lews of California; that the members of said

vs. Crraco Mane ja, et al. 17

cooperative, including plaintiff company, were dur-

ing all of said period of time under contract to de-

liver and did deliver all of the raw sugar produced

by them to said cooperative; that said deliveries,

insofar as plaintiff Company Was concerned, were

made as referred to in said Paragraph 6 of the

Amended Complaint, being placed into the railroad

cars there referred to, and said deliveries continued

thereafter by rail, by ship, and by subsequent trans-

port on the Mainland of the United State s, to and in-

to a certain refinery located in Crockett, California,

Which retinery was owned, controlled and maintained

by the said cooperative; that the greater part of said

raw sugar so delivered was then and there refined at

Crockett, California; that. thereaftey such refined

sugar, and the portions of raw sugar not refined,

were sold by the said cooperative: that all proceeds

of the sale of such refined sugar and raw sugar

Were after the deduction of expenses, distributed to

or [21] held for the account of the uember planta-

tions of said cooperative in direct proportion to,

and in accordance with. the sugar furnished to said

cooperative by said plantations. including the plain-

tiff company.

IIT.

In reference to Paragraphs 4 and 8 of the

Amended Complaint, these defendants have no in-

formation or belief sufficient to enable them to an-

swer the allegations contained therein, and basing

themselves on said ground deny each and every, all

and singular, generally and specifically, the allega-

tions contained therein.

18 Waialua Agricultural Co., ete.

IV.

In reference to Paragraph 9 of the Amended

Complaint, the allegations contained in the first

sentence thereof are denied, and in this connection

the defendants allege that they have performed

work, tasks and duties for plaintiff company during

various workweeks contained within the period of

time involved in said action, and in many instances

in excess of forty hours per workweek, without re-

ceiving overtime compensation for hours per work-

week in excess oi forty up to forty-eight, and which

said work, tasks and duties constituted production

for commerce as defined by the said Fair Labor

Standards Act.

V.

The said work, tasks and duties performed by de-

fendants for plaintiff were and are within the eov-

erage and protéction of said fair Labor Standards

Act, and not within [22] any exemptions contained

therein, and by reason thereof the said plaintiff be-

came and was obligated te pay to defendants, for

hours worked in excess of forty per workweek, com-

pensation at the rate of one and one-half times the

regular rate of pay of defendants; that during var-

ious workweeks covered in this action, the defend-

ants did in fact work hours in excess of forty per

workweek, and by reason thereof were entitled to

receive overtime compensation as aforesaid, as re-

quired by said Fair Labor Standards Act; that

plaintiff failed and refused to pay such overtime

compensation ; that defendants have made elaim and

demand of plaintiff that payment of such unpaid

vs. Ciraco Mane ja, ef al. 19

compensation be made, and plaintiff has refused and

neglected to comply with said claims and demands ;

that there is due and owing from plaintiff to the de

fendants certain sums of money for such unpaid

overtime compensation, and Judgment against plain

tiff and in favor of defendants sheuld be rendered

in the amounts so due and owing, as established by

evidence which defendants are miepared to and will

produce in the trial of this action.

Wherefore, defendants pray for judgment against

plaintiff for unpaid overtime compensation, liqui-

dated damages in amounts equal to such compensa-

tion, costs and attorney's fees, and for such other

rehef as may be just and proper.

Dated Honolulu, T. H., this 23rd day of August,

1950.

KICHARD GLADSTEIN.

GLADSTEIN, ANDERSEN.

RESNER & LEONARD,

By /s/ RICHARD GLADSTEIN.,

Attorneys for Defendants.

[Endorsed]: Filed August 23rd. 1950. [23]

Ja Waialua Agricultural Co., ete.

[Title of Distriet Court and Cause.]

REPLY AND ANSWER TO COUNTER-CLAIM,

CROSS-CLAIM, AND CRESS-COMPLAINT

Comes now the Plaintiff above named, by its at-

torneys, Ii!uius G. Poole, Livingston Jenks and

Errvest C. Moore, Jr. and for reply and answer to

the Counter-Claim, Cross-Claim and Cross-Com-

plaint appearing in Paragraph V of Defendant's

Answer to Amended Complaint, and Counter:

Claim, Cross-Claim and Cross-Complaint, admits,

denies, and alleges as follows:

1. Plaintiff denies each and every allegation con-

tained in Paragraph V of the Defendants’ Answer

to Amended Complaint, and Counter-Claim, Cross

Claim and Cross-Complaint, except that it admits

a. That during each and every workweek from

November 20, 1946, to September L4, 1847, both

dates inelusive (the period of time involved in this

action), each and every Defendant generally worked

in excess of forty hours;

hb. That during said period Plaintiff generally

did net pay any Defendant overtime compensation

in accordance with [25] the standards of Section

Tia) of the Fair Labor Standards Act of 1958

hereinafter ealled the Aet) in that Plaintiff gener

ally did net pay any Defendant overtime compen-

sation for all hours worked by him in excess «of

forty per workweek ; and

vs. Ciraco Mane ja, et al. 21

e. That Defendants have demanded that Plain-

tiff pay them overtime compensation in accordance

with the standards of Section i(a) of the Act as

aforesaid for the period covered by this action but

that Plaintiff has refused to comply with such de-

mand and claim.

In connection with Plaintiff's refusal to ray De-

fendant such overtime compensation it alleges that

each and every Defendant during each and every

workweek covered by the Complaint, namely trom

November 20, 1946, to September 14, 1947. either

Was not engaged in commerce or in the production

of goods for commerce within the meaning of the

Act or was exempt frou the overtime provisions of

the Act—

a. As provided in Section 13(a) (6) of the Aet

because he was “‘emploved in agriculture’ as the

term “agriculture”” is detined in Section 3(f) of the

Act, or

bh. As provided in Section 7(¢) of the Act be-

cause he was empleved by the Plaintiff where the

Plaintiff was engaged in the “processing of * * *

sugar cane * * * into sugar (but not refined sugar)

or inte svrup.”* or

c. As provided in Section 13(a) (2) of the Net

heeause he was an “employee engaged in any retail

er service establishment the greater part of whose

selling or servicing is not intrastate commerce.”

in view of the foregoing, the Plaintiff was hot re-

22 Waialua Agricultural Co., etc.

quired by the Act to pay the Defendants any over-

time compensation. [26]

2. For the period November 20, 1946, to May

13, 1947, inclusive, the act or omission, if any, of

Plaintiff to pay the Defendants in accordance with

the claims of Defendants as set forth in paragraph

V of the Defendants’ Answer to Amended Com-

plaint, and Counter-Claim, Cross-Claim and Cross-

Complaint, was in good faith in conformity with

and in reliance on administrative regulations, or-

ders, rulings, approvals, and interpretations of

agencies of the United States and in good faith in

conformity with and in reliance on adn.imistrative

practices and enforcement policies of agencies of

the United States with respect to the class of em-

ployers to which Plaintiff belonged. Pursuant to

Section 9 of the Portal-toPorta! Act of 1947, there-

fore, Plaintiff is not liable to the Defendants or

any of them for any act or omission during the

period November 20, 1946, to May 13, 1947, inclu-

sive, complained of by Defendants.

3, For the period May 14, 1947, to September

14, 1947, inclusive, the act or ommission, if any, of

Plaintiff to pay the Defendants in aceordance with

the claims of Defendants as set forth in paragraph

V of the Defendants’ Answer to Amended Com-

plaint, and Counter-Claim, Cross-Claim and Cross-

Complaint, was in good faith in conformity with

and in reliance on written administrative regula-

tions. orders, rulings, approvals, and interpreta-

us. Ctraco Mane ja, et al. 23

tions of the Administrator of the Wage and Hour

Division, U. 8. Department of Labor, and in good

faith in conformity with and ir reliance on admin-

istrative practices and enforcement policies of the

said Administrator with respect to the class of em-

ployers to which Plaintiff belonged. Pursuant to

Section 10 of the Portal-to-Portal Act of 1947,

therefore, Plaintiff is not liable to the Defendants

or any of them for [27] any act or omission during

the period May 14, 1947, to September i4, 1947, in-

clusive, complained of by Defendants.

4. During all periods of time referred to in

paragraph V of the Defendants’ Answer to

Amended Complaint, and Counter-Claim, Cross-

Claim and Cross-Complaint, the act or omission, if

any, of Plaintiff to pay the Defendants in accord-

ance with the claims of Defendants as set forth in

said paragraph, was in good faith and Plaintiff had

reasonable grounds for believing that such act or

omission was not a violation of the Act. The court

therefore, pursuant to Section 11 of the Portal-to-

Portal Act of 1947, should in the exercise of its

discretion award no liquidated damages to Defend-

ants.

Wherefore Plaintiff prays that Defendants take

nothing by their Counter-Claim, Cross-Claim and

Cross-Complaint, that the Counter-Claim, Cross-

Claim and Cross-Complaint herein be dismissed

and that Plaintiff have such other and further

relief as may be proper in the premises.

24 Waialua Agricultural Co., ete.

Dated Honolulu, T. H., this 25th day of August,

1950.

/s/ RUFUS G. POOLE,

/s/ LIVINGSTON JENKS,

ANDERSON, WRENN &

J ENKS,

/s/ ERNEST C. MCORE, JR.,

PRATT, TAVARES &

CASSIDY,

Attorneys for Plaintiff.

Receipt of copy acknowledged.

[Endorsed]: Filed August 2, 1950. [28]

[Title of District Court and Cause. }

AMENDMENT TO ANSWER TO AMENDED

COMPLAINT, AND COUNTER-CLAIM,

CROSS-CLAIM, AND CROSS-COMPLAINT

Come now the defendants, counter-claimants,

eross-claimants and eross-complainants above

named, and upon consent of plaintiff, and with

leave of Court first had and obtained, do file the

within Amendment to that certain pleading hereto-

fore filed and designated as ‘‘Answer to Amended

Complaint, and Counter-Claim, Cross-Claim, and

Cross-Complaint,”” and for such Amendment do al-

lege as follows:

1. In reference to the allegations contained in

Paragraph V of said Answer to Amended Com-

vs. Ciraco Mane ja, et al. 25

plaint, and Counter-Claim, [29] Cross-Claim, and

Cross-Complaint, and by way of further allegation

in respect of the same, it is hereby alleged that the

work, tasks and duties performed for plaintiff by

the defendants, as referred to in said Paragraph V,

were compensable by the express provisions of then

existing, applicable and effective written collective

bargaining contracts entered into and carried out by

plaintiff and by the collective bargaining repre-

sentative of defendants; that said work, tasks and

duties, and all activities connected therewith, were

further compensable br reason of custom and prac-

tice, then and there in effect during all of the time

said activities were performed, and particularly dur-

ing all of the time ecvered by the Complaint on file

herein, at and within the establishments and places

where these defendants were employed, and that

said customs and practices did vover said activities,

and were not in anywise inconsistent with any writ-

ten or non-written contracts in effect at the time of

the performance of such activities; that the work,

tasks, duties and activities performed by defend-

ants for plaintiff, referred to and described in said

Paragraph V, consisted of and were the main and

principal work and duties for which defendants

were employed by plaintiff, and were the main and

principal duties and functions actually performed

by defendants; that all such work and activities

were engaged in and performed by defendants dur-

ing the portions of the days with respect to which

the same were made compensable as aforesaid: that

26 Waialua Agricultural Co., etc.

a!l such work, tasks, duties and activities were in

fact intended to be, and were, paid for aml com-

pensated by plaintiff, ana no dispute exists between

the partics as to whether such activities should have

been paid for, but on the contrary the [30] dispute

between the parties is as to whether the amounts

paid by plaintiff have been sufficient to discharge

its obligations under the said Fair Labor Standards

Act for overtime compensation.

Wherefore, defendants pray for judgment as re-

quested in the said Answer to Amended Complaint,

and Counter-Claim, Cross-Claim, and Cross-Com-

plaint.

Dated Honolulu, T. H., this 29th day of August,

1950.

RICHARD GLADSTEIN,

GLADSTEIN, ANDERSEN,

RESNER & LEONARD,

By /s/ RICHARD GLADSTEIN,

Attorneys for Defendants.

We consent to the filing of the above Amendment.

/s/ RUFUS G. POOLE,

/s/ LIVINGSTON JENKS,

/s/ ERNEST C. MOORE, JR.,

Attorneys for Plaintiff.

[Endorsed]: Filed August 30, 1950. [31]

vs. Ciraco Mane ja, et al. 27

[Title of District Court and Cause. ]

STIPULATION

Index

Part |]

Pages

Description of the Plantation and Its Opera-

inte EE EEE PRG abe piel ERR! pec 50

1, Name and Location of Company........ 30

“. The Business of the Plantation........._. 3]

3. Relative Position of Plantation in Terri-

vias? EE LE ENE Ne UE att y Oy: 32

4. Sugar Cane Not an Article of Interstate

RUIN ph aie ree rie eo 33

9. Some General Facts About the Plantation 33

6. Location of Buildings and Facilities on

PN occu Pe eg ee oe 38

7. Preparation of Land for Planting. ...... 39

a Medecine, CPE oT OCOD Se Aeon ree 40

ot ee DEA A el ekemee Ue tet 42

pers cra SE EEO OI ele 42

se hh che tcprica., OEP OEL OPO OPE SRE es oe 44

sec Berens PEI E PR a emnee Lie 45

Ma ME ahem 52

14. Railroad Transportation ..........000 02. 59

Waialua Agricultural Co., etc.

Pages

Field Road and Public Road Transporta-

Se ae SG sy sigh bets Uae 69% BO es b+

es eae dviee en ee es 68 66

Chopping and Crushing Cane............ 72

Clarifying and Crystallizing............. 76

Sugar Bagging and Shipping............ 82

Work Schedules of Mill Employees...... 82

Week End Repaiv of Mill.............-. 53

No Non-Plantation Cane Processed by Mill 84

ee ee re S4

Fire Room and Power Production... ..... 8

Generation and Distribution of Electric

GOR: NS alee Oe Mere ie aed eae nR pare 89

ee ee ee re eee ee er ee ee 94

Laboratory Tests and Sampling.......... 103

Concrete Products Plant................ 105

Storage of Plantation Supplies.......... 106

Main Administration Office.............. 108

I Roe ei vie oud aba Wank es kes 109

Ne eae haK ew eer Nes 109

Mill Repairs During the Off Season...... 111

Mechanization and Improved Management 114

vs. Ciraco Mane ja, et al. 29

Pages

39. Relationship of Cane Production to Cane

Processing in ‘Terms of Direct Operating

Expenses and Hours Worked............ 117

36. Plantation Villages ................. -. oa

Part II

Description of the Work and Duties of Defend-

ants as Employees of Plantation........._ 123

* * *

en Sy gs 2 ees Ey 124

% *

48. Peter MI Ge oli ants 125

Sy ee OO cs 125

¥ * *

Part II]

Additional Data Relating to Work and Duties

We I 55 iid as we st 127

SMI 05 dseineksdh dois kes vcs. 128

MS hacen sce. ued. fre ese 128

30 Waialua Agricultural Co., etc.

It Is Hereby Stipulated by and between Waialua

Agricultural Company, Limited, Plaintiff herein,

by and through Rufus G. Poole, Livingston Jenks,

and Ernest C. Moore, Jr., it Attorneys, and Ciraco

Maneja, Antone Vierra, Augustine Lorenzo, Haru

Kibota, Tadao Watanabe, Koichi Okouchi, Tsuruo

Hayashi, Cornelio Asuncion, Roque Crisostomo,

Peter Holmberg, Hatsusuke Sera, Takumi Okouchi,

Pedro Dumlao, Bernabe Hernandez, Domingo

Guigui, Ushinosuke Kondo, Teruichi Kubo, Masaiki

Oato, Simon Cumlat, Apolonio Lazo, Giichi Hama-

moto, Dionicio Carrit, Seraphine Robello, Toshio

Tanaka, Barney Faria, Fumio Sunahara, Hirosaku

Takata, Alfred Reyher, Masaru Ezawa, Damaso

Claunan, Antone Robello, Yoshiji Yamada, Edwin

Mori, Genjiro Hironaka, Jiro Sakai, Margaret

Fujiwara, Louis Pacheco, Yukishige Tsutsui, Yack

Chun Lee, Eiko Sakaguchi, Moses Fernandez and

Toshio Kashiwabara, Defendants herein, by and

through their Attorney, Richard Gladstein, in Civil

Action No. 787, that the following are true and

accurate facts: [36]

Part I.

Description of the Plantation and Its Operations

A

Name and Location of Company

Waialua Agricultural Company, Limited, herein-

after sometimes referred to as the ‘* Plantation,’

———

IThe term ‘‘ Plantation”’ is also used in this stipu-

lation to mean the geographical area or which the

Waialua Agricultural Company, Limited, is pro-

us. Ciraco Mane ja, et al. 31

is a corporation duly organized and existing under

and by virtue of the laws of the Territory of

Hawaii, having been organized in IS98, with its

head office located in Honolulu, City and County of

Honolulu, Territory of Hawaii, and its plantation

located in the District of Waialua, City and County

of Honolulu, Territory of Hawaii.

»

The Business of the Plantation

Since the original incorporation of the Company

in 1898, the business of the Plantation has been and

continues to be the growing, cultivating and har-

vesting of sugar cane on lands owned or leased by

the Plantation; the processing of such sugar cane

into raw sugar and molasses; the bagging, loading

and shipping of the raw sugar to refineries situated

in the continental United States; and the loading

and shipping of molasses in bulk to continental

United States, ail of which is hereinafter deseribed.

The loading of the bagged rw sugar and of the

molasses into railroad box and tank cars of the

Oahu Railway & Land Company, an independently

owned and operated carrier (hereinafter referred to

as the [387] ““O. R. & 1.’’), at the site of the mill?

ducing sugar cane, processing it into raw sugar and

conducting related operations.

“The term ‘mill’? as used herein means the

building and equipment of the plantation used in

the actual processing of sugar cane into raw sugar,

including eane carrier, cane cleaning plant and

scales, crushing plant, boiling house, fire rovum,

power plant, sugar warehouse and molasses tanks,

and all equipment therein.

32 Waialua Agricultural Co., ete.

and the pushing of such cars from such site onto a

nearby spur of the O. R. & L., complete the oper-

ations of the Plantation and the work of its em-

ployees relative thereto. The Plantation does not

engage in any sugar refining operation.

3.

Relative Position of Plantation in Territory

The Waialua Agricultural Company, Limited, 1s

one of thirty-four (54) sugar plantations located,

operating and doing business in the Territory of

Hawaii (hereinafter referred to as the ‘*Term-

tory’’). The total raw sugar produced by these

thirty-four plantations in 1945 was 821,216 tons.

Of this amount the Waialua Agricultural Company,

Limited, produced 56,193 tons or slightly less than

7%, and as such it ranked as the third largest pro-

ducer of raw sugar in the Territory in 1945. The

total number of employees of the thirty-four planta-

tions as of September 1, 1946, was 29,517 and was

approximately 28% of the total number of persons

privately employed in the Territory. The raising

of sugar eane and the processing of it into raw

sugar constitutes the principal industry in the

Territory in terms of the number of persons pri-

vately employed, invested capital and the value of

the product produced. Between the years 194] and

1945, the Territory produced between 13.30% and

10.76% of all sugar, both beet and cane, distributed

for consumption in the continental United [38]

States.

ae

=~

*-

=~

vs. Ciraco Mane ja, et al.

4,

Sugar Cane Not an Article of

Interstate Commerce

Sugar cane is highly perishable, as will be here-

inafter described, and starts to deteriorate immedi-

ately after harvesting. To avoid serious losses it

must be processed into sugar, syrup or molasses

within a few hours after it has been burned? or

severed from the ground. For this reason and be-

cause of the great weight and bulkiness of cane as

compared with raw sugar, it must be processed

within a few miles of where it is grown. Sugar

cane never moves into interstate commerce in its

natural state. Except for small amounts which are

used as seed cane, it is grown exclusively for the

purpose of producing sugar, syrup or molasses and

it is these end products, which are the result of the

processing of cane, which becomes articles of inter-

state commerce,

D

Some General Facts About the Plantation

At the present time the Plantation grows and

produces sugar cane on 9,663 acres of land owned

or leased by it. Substantially all of the land now

devoted to sugar cane production has been owned

or leased by the Plantation and used by it for this

purpose since 1910. The table set forth in para-

graph 34 of this stipulation will show that the num-

’The references herein to the “burning”* of sugar

‘ane are to the burning of the leaves and rubbish

in the cane field as part of the harvesting operation.

In such burning the eane stalks are undamaged,

JA Waialua Agricultural Co., etc.

ber of acres under cane cultivation since 1910 flue-

tuated above and below the present cane acreage

by approximately 10%. [39] The acreage reduction

shown for 1935 was due to the establishment of

quotas by the Federal Government under the author-

ity of the Agricultural Adjustment Act of 1935,

7 USCA § GOL et seq., but the acreage eliminated

from cultivation at that time was eliminated on a

temporary basis only, and continued as a part of the

plantation and was subsequently replanted. In 1915

and 1920 the acreage excceded present acreage by

some 10%. This was due to the fact that the Planta-

tion was at that time attempting to produce cane

on certain of its marginal areas, the use of which

for such purpose was later abandoned. The cane

growing land of the Plantation, its buildings and

yard area, and other lands owned or leased by the

Plantation, but unsuited for cane growing, includ-

ing a wooded area from which firewood is cut for

use as fuel by plantation employees living in the

plantation villages hereinafter described, form a

contiguous and compact area as shown by Exhibit

‘A’ which is attached hereto and made a_ part

hereof, except that an area of 470.42 acres of cane

growing land located on the lowlands at the west

end of the Plantation is connected with the prin-

cipal area of the Plantation only by a strip of land

40 feet wide and 1,150 feet long over which the

Plantation has a perpetual easement for rights-of-

way for the moving of its agricultural equipment

supplies and sugar cane.

Sugar cane is grown in fields which in one area

us. Ciraco Mane ja, et al. i)

of the plantation are cut by deep guiches and waste

land unsuited for cane production, while in other

areas the fields are separated only by plantation

roads or publie highways. Cane erowing land is

criss-crossed with a network of plantation field roads

and a narrow gauge plantation-owned railroad. [40]

Planting, cultivating and harvesting Supp lbes, min.

terials and equipment are transported over these

field roads. The railroad is used te transport cane

from the fields to the mill and te transport some

agricultural supplies and harvesting equipment he-

tween the plantation buildings and yard area and

the fields. There is also a network of irrigation

ditches throughout the plantation and a number of

water storage reservoirs, since all eane Crown ot

the plantation must be irrigated.

All the lands devoted te the growing of suear

eane are managed and operated by the Plantation

as an integrated farming unit and single enterprise

with identical croppimg, eultivation and harvesting

practices, and with the same labor and cou pment,

Employees work in the fields moving from one area

to another depending upon the program of plowing,

planting, irrigating, fertilizing, applying herbicides

and insecticides, weeding and harvesting. The cane

lands are in various stages of production or prepa.

ration. Some acreage is being plowed and furrowed

for new planting, some is being *“‘ratooned”’ (a

process hereinafter described), some acreage is in

young growth, some in old growth nearing ma-

turity and other acreage is being harvested, The

growing, harvesting and processing of the cane and

36 Waialua Agricultural Co., ete.

the marketing of the :aw sugar constitute one con-

tinneus and vear around operation except that an-

nually harvesting and processing of cane are

suspended for approximately three (3) months for

the purpose reconditioning the mill and equipme t,

as hereinafter described. [41] |

As of September 1, 1946, the Plantation had a

total of 1.144 emplovees. The Plantation consid. v's

this number of iovees sufficient for its oper-

ations as conducted at the present time. [ts labor

requirements are substantially the same throughe it

the vear.

The Plantation has ten (10) job classifications fr

its rank and file or nen supervisery employees, W. 0

numbered 959 as of November 19, 1946. The hourly

wage rates for such ten (10) classifications ranve

from a minimum of Se te a maximum of $1.08.

The Plantation, however, employs 12 handicapped,

superannuated and part-time workers who receive

a minimum hourly wage of 74c. The weighted aver-

eee hourly wage rate for all non-supervisory em-

ployees of the Plantation is 90.8¢. The existing col-

leetive Dargaining agreement dated November 19,

1946, between the Plantation and the International

Longshoremen’s and Warehousemen’s Union, Loeal

145-7. as collective bargaining agent for most of

the non-supervisory emplovees, which contract sets

forth the wages, hours and working conditions of

the employees herein involved, is attached hereto

as Exhibit Band made a part hereof.

Prior to March 1, 1940, the Plantation paid no

overtime compensation but since that date it has

vs. Ciraco Mane ja, et al. 37

paid time and one-half for all hours worked in

exeess of eight in one day and forty-eight in one

work week, Work performed on New Year's Day,

Dadependence Day, Labor Day, Thanksgiving Day

and Christmas Day have also been compensated at

the rate of time and one-half. since March 1, 1940,

On July 12, 1943, most of the oftice staff and most

of the warehouse employees were placed on a 40-

hour work week schedule and have continued since

that date on such schedules [42] with time and one-

half being paid for all hours worked In excess of

forty per week,

Since October 4, 1943. employees in the mill and

in the allied service shops have been paid time and

one-half during the off season for all hours worked

in excess of forty per week,

It is the contention of the plaintiff that the pro-

Visions of the Fair Labor Standards Act do not

require it to pay any of. its emplovees overtime

compensation, Conversely, it is the contention of

the defendants that sneh Aet requires the plaintiff

to pey all of its employees time and one-half for

wl hours worked in excess of forty per week,

All Plantation operations and activities are under

the over-all direction and control of the Plantation

manager, Under him as immediate assistants are

the assistant manager and three staff assistants, the

field and mill coordinator, and the personnel train-

ing and development director.

The various plantation operations described here-

Inafter are each under the supervision of a man-

aver or superintendent as follows: Field operations,

38 Waialua Agricultural Co., etc.

the field swperintendent; mill and allied shop oper-

ations, the cane processing superintendent; ware-

house, the warehouse superintendent ; construction,

the construction superintendent ; accounting, the

office manager; and civil engineering, the civil engi-

neer. All of these superintendents are responsible

to the plantation manager.

6.

Loeation of Buildings and Facilities

on Plantation

The plantation buildings, including the mill, which

processes the cane into raw sugar, a number of

buildings housing [43] repair shops for the main-

tenance of field, transportation and mill equipment,

warehouses for plantation supplies, and other build-

a

ings having functional relation to the entire planta-

tion operations, are centrally lo sated on the lowlands

of the plantation in a small, compact and con-

tiguous area. The administration offices of the

Plantation are located on the plantation within a

distance of not more than one-fourth (14) of a mile

from the other buildings. Surrounding such planta-

tion buildings and administration office area are

plantation-owned houses in which employees work-

ing in both field and mill live with their families.

Community service establishments and recreational

facilities are also located here. Public highways

and an independently owned narrow gauge railroad

cut across this area. Other company-owned facilities

include a hospital and a general merchandise retail

store which sells to both plantation employees and

vs. Ciraco Mane ja, et al. 39

the general public. Located along the public high-

Ways running through the plantation are non-plan-

tation-owned stores, shops, theatres, automotive

service stations, barber shops, churches, a bank and

other facilities which are normally a part of any

typical small community in a farming area. See

Exhibit **A’’ which illustrates the general deserip-

tion given above of the location of the cultivated

areas, gulches, waste lands, buildings, plantation and

private communities and highways.

7.

Preparation of Land for Planting

Sugar cane is a giant bunch-grass_ producing

clumps or stools of solid strongly jointed stalks or

sticks measuring from 1 inch to 24% inches in

diameter, well developed stalks [44] reaching on an

average 10 feet to 15 feet in height. The sugar cane

grown on the plantation requires generally 22 to

24 months to mature after planting or ‘ratooning.””

Three or four crops can be obtained from each

planting, Jelds being replanted each six to eight

years. Between these times of planting a field. is

“ratoorea”’ at the end of each harvest. Seed used

for planting is actually 24-inch to 30-inch young

‘ane cuttings. These cuttings of cane have nodes

every 5 inches to 8 inches apart. At every node

there is a bud which forms a new stool. Planting

seed is obtained from cane that is cight to twelve

months old,

Plowing of the field for the planting of new crops

commences soon after the harvesting operations on

40 Waialua Agricultural Co., ete.

the previous crop are completed. The plowing is

performed with 110-horsepower diesel powered trac-

ters with rooter type subsoil attachment. The sub-

1 is broken up to « depth of 18 inches to 24

nehes. Two or mer —~”’ soil plowings of each field

are carried out, the second plowing being performed

at right angles to the first. After the field has been

subsoil plowed twice, a dise plow (eight 28-inch

discs) is drawn by a tractor over the field, breaking

up large cane stools and lumps and turning over

the soil. When this operation is completed, the sub-

soil tractor subsoils the field onee again and the final

plowing is completed with the dise plow. This leaves

the field well broken up and ready for the planting

operation. Each type of plow used in the above

operation is manned by a tractor operator and

helper. Tractors may be operated in two shifts

or one shift may work longer than the customary

eight hours depending upon the urgency of com-

pletion of the plowing operation. [45]

After the field is plowed, a crew of six men in-

eluding a tractor operator using a tractor with a

‘*stone boat’’ attachment, clears the field of obstrue-

tions, such as stenes. This same crew and tractor

are also used to move concrete irrigation flumes and

pipes to the proper location, if the locations are to

he changed.

8,

Planting

Planting is done by a planter machine mounted

on a 75-horsepower diescl powered tractor manned

by a crew of cight men including the tractor oper-

vs. Ctraco Mane ja, et al. 41

ator, This planter consists of : nlatform which will

hold sixty to seventy-five bags of seed weighing

sixty-five to ninety pounds each. The bagged roud

is spotted in the field prior to planting and is loaded

onto the planter by the planting machine erew. A

fertilizer hopper is also mounted on the tractor, and

fertilizer is distributed concurrently with the plant-

ing. The planter progresses across the field and twe

mold boards attached to the tractor drawbar make

two “V" shaped furrows from fourteen to eighteen

inches deep. The seed is guided by chutes from the

platform of the planter to the furrows; fertilizer

is distributed in the furrows from. the fertilizer

hopper. The planting machine plants about one

acre per load. After the planter drops the seed and

fertilizer, a gang consisting of ten to fifteen men

with hoes follows the planter spacing the seed and

covering it with an inch or two of soil. A’ flume

laying gang, consisting of fifteen men under the

supervision of a flume laying foreman, then pro-

ceeds to install concrete flumes. These flumes are

spotted throughout the field having been brought

up by truck from the plantation concrete products

plant where they are made. Sections [48] of con-

crete flumes are from 30 inches te 36 inches long

and are approximately 1514 inches wide at the top.

A small crew of eight men construct necessary head-

Ings, which are special wood or conerete thume

headings or gates required at the point at which

water is brought into the field. Field irrigation

lines are carefully plotted out according to pre-

arranged plan and method which will be deseribed

42 Waialua Agricultural Co., etc.

hereafter. As soon as possible after the seed is

planted, irrigation water is applied.

Approximately six weeks after the planting has

been completed and the crop has commenced to

grow, further planting is performed to the extent

of filling in any blank spots where the cane seed

has failed to germinate. The seed is hauled by truck

to the edge of the fields and then spotted throughout

the field by pack mules. This work is done by a

pack mule man, with a helper. Holes are dug by

hand hoe, and seed pieces; are then laid in these

holes by hand and covered to a depth of two inches.

A gang of approximately twenty-four employees

perform this work.

9,

Ratooning

As previously stated, fields are replanted each

six or eight years. Between these times of planting

a field is ‘‘ratooned’’ at the end of each harvest.

*Ratooning”’ is a term referring to the operations

performed after a field is harvested to prepare the

field for the growing of another crop. In- such

preparation the old cane stools or stubble are left im

place and the ground is refurrowed into rows.

The undamaged cane stools or stubble will then send

up new [47] shoots upon application of water and

fertilizer to the field. New seed is added to fill in

blank spots or to replace damaged stools or stubble.

10.

Cultivation

To eontrol weeds, herbicides are applied. The

us. Ciraco Mane ja, et al. 43

first application is performed within one week after

planting in order to destroy the first germination

of the weeds. Thereafter herbicides are applied at

intervals varying from fifteen to twenty days de-

pending on the weather and the condition of the

field. The last application is performed when the

‘ane is approximately six months old. Thereafter

spraying of herbicides is limited to the spraying

of irrigation flume areas, for a distance of ten to

fifieen feet on either side of the Hume, and also

spraying of the area along the main ditches and the

level ditches within such particular field area.

Herbicide gangs are composed of thirteen to nine-

teen men. Each man in the gang is equipped with

a knapsack sprayer: that is, a sprayer which is

strapped to the backs of the men, the herbicide be-

ing applied by means of a nozzle at the end of a

hose which is directed by hand as the gang members

walk along the areas being treated.

After two or three applications of the herbicides,

a weeding gang composed of fifteen to twenty-five

men remove the remaining weeds with the use of

hoes. A gasoline driven tractor equipped with two

revolving discs at either side of the cane stool is

sometimes used. The tractor cuts the weeds and

throws them to the top of the banks between the

rows of planted cane. [48]

Truck sprayers of herbicides are employed to

control weed growth on plantation field roads and

along storm ditches and main irrigation ditches.

This operation utilizes a truck which ‘arries a tank

of 1,000-gallon capacity and a special spray pump

44 Waialua Agricultural Co., ete.

which pumps the herbicide through a hose pipe

equipped with a spray nozzle. One man then guides

the nozzle along the road sides and ditches.

Although insecticides are occasionally called for,

their application is infrequent. When performed,

the method used is a similar knapsack spraying,

applying the insecticides to the top of the cane.

Herbicide gangs perform this operation also.

A total of approximately forty men is engaged

in herbicide operations.

11.

Fertilizing

After planting there are two or three additional

applications of fertilizer before the cane reaches the

age of seven months. The fertilizer is hauled by

truck to the edge of the field or nearest point of

distribution and then reloaded on pack mules, which

place bags alongside the irrigation flumes or levei

ditches according to the number of pounds to be

applied per acre. Each man in the fertilizer gang,

numbering twelve men, is equipped with a bag which

he fills with fertilizer and then proceeds along the

cane rows applying the same by hand near the base

of the cane stools.

Irrigation water is also used to apply fertilizer

to the field after the cane is too high to permit hand

application. Normally, two applications of fertilizer

are applied by water.

Fertilizer applied for the year 1945 totaled 2,855

tons. [49]

vs. Ctraco Mancja, et al. 45

12.

[rrigation

Intensive irrigation throughout the vear is re-

quired for the entire plantation acreage devoted to

sugar cane production. Although the normal annual

rainfail is about thirty inches, precipitation is un-

evenly distributed throughout the year, thereby re-

quiring supplemental irrigation at all times.

An extensive and comprehensive system of water

supply from surface and artesian sources has been

developed by the Plantation since it was incor-

porated in 1898. The primary source of surface

water is the Wahiawa Reservoir, constructed and

developed in 1904-06 and operated by another com-

pany. This reservoir has a storage capacity of 2,540

million gallons, obtained from a mountain water-

shed. Water from this reservoir is conveyed through

four miles of tunnel and open ditch to the 750-foot

contour of the Plantation where it. is conveyed

through a major eanal forming in general the upper

boundary of the cultivated area.

Surface water is diverted by small dams at the

headwaters of the streams running down the gulehes

indicated as wasteland on the map marked Exhibit

“C” which is attached hereto and made a part

hereof. Flow from the streams in these gulches is

sporadic and reservoir capacity to store freshet

peaks is limited.

In addition to the above sources of water, a

system of deep well pumps has been developed

vradually on the Plantation since 1898 to tap the

artesian slopes from the two mountain ranees Iving

46 Waialua Agricultural Co., etc.

on either side of the Plantation. The present pump

system comprises twenty-two pumping stations with

a rated capacity of 11.36 million gallons per 24-hour

day. [50] Three of these units are powered by

steam; the remainder are operated by push-button

controlled electric power units.

In addition to supplying irrigation water for

sugar cane production, the artesian system supplies

the mill and the domestic water needs of the planta-

tion villages. Occasionally, water from artesian

wells is also supplied to home gardens of plantation

employees and to small farmers, all of whose prod-

uce is consumed locally. Artesian water may also

be used for fire protection purposes. Surface flow

water may be used, however, for home gardens, as

well as for fire protection needs.

The following table summarizes the amount of

water received from various sources during the

years 1941-1945, and reflects the amounts of these

totals which have been required for irrigation pur-

poses: [51]

1940

Steam Pumps ........ 4,186.93

Electric Pumps ....12,183.16

Total Pump Water..16,370.09

Wahiawa Res. ......... 9,835.10

Helemano Stream.. 1,874.82

Opaeula Stream...... 1,926.33

Kamananui Stream 1,235.88

——

Total Surtace

ee ee 14,945.83

Total Water

Received ..............31,615.92

Total Water Used

for Cane

Irrigation ............ 30,547.71

1941

0,082.49

12,347.43

17,900.47

7,908.97

1,710.95

2,138.21

1,140.51

ee

12,541.40

SO 441.87

29,895.84

(In millions of gallons)

1942

3,059.50

7,747.88

10,807.38

8,835.71

2,306.17

1,979.71

1,852.34

15,069.35

95,876.73

24,665.12

1943

4,250.56

8,445.01

12,695.57

9,366.64

1,698.47

1,855.05

1,193.41

14,182.48

26,878.05

26,002.83

1944

9,842.23

12,601.78

18,444.01

8,000.40

1,820.14

1,590.53

067.35

12,028 95

30,472.96

29,658.02

1945

6,495.03

11,979.92

18,474.95

6,539.75

1,023.05

1,014.43

229.58

8,806.81

‘)0 a “wlaunyy oonsrg “sa

Lb

48 Waialua Agricultural Co., etc.

A flexible system of earth, conerete and stone-

lined eanals, steel inverted siphons, and concrete

pipes and flumes distributes water to the cane fields

of the Plantation. Approximately 50 per cent of the

cultivated land of the plantation is irrigated solely

by surface water; approximately 5 per cent is irri-

gated solely by artesian water; and the balance is

irrigated by both surface and artes.an water.

The plantation is traversed by three main supply

‘canals. The Wahiawa Ditch at the upper boundary

of the cultivated area follows approximately the

750-foot contour and delivers gravity water from

the Wahiawa Reservoir, supplemented by flows

from the other stream diversions. A group of canals

at approximately the 300-foot contour receive and

distribute water from high-lift pump units, and a

third group of canals along the 100-foot contour

deliver low-lift pump water. A few low-lift pumps

supply artesian water directly to certain areas

through separate ditch systems.

In practically all cases, water is delivered from

each source to several areas of the plantation across

deep ravines and rugged topography which necessi-

tate the use of long inverted steel siphons of 24 to

54-inch diameter or of high flumes. Lateral distri-

bution from each canal is provided by ‘‘straight

ditches,’ usually lined with stone or concrete to

prevent erosion, through which water is delivered

to the fields or to the next Jower canal in the system.

Distribution reservoirs, of whieh 30 ranging in

‘capacity from 1.0 to 50, million gallons, have been

vs. Ciraco Mane ja, et al. 49

constructed by the Plantation, provide night. stor-

age and equalize water flows.

One of two methods of irrigation is emploved

depending upon the topography. On tlat lands with

a slope of two feet [53] or less te each hundred

feet, the field is in furrows runnine down the slope.

Low level ditches extend across the fields at right

angles te the furrows. Water flows from the field

supply ditches into the level ditehes which are

spaced approximately 200 to 300° feet down the

slope, and the irrigator diverts water into the cane

furrows, either by cutting through the banks of

the level ditehes with a hoe or by using contrelled

gates on permanent pipes connecting with each

furrow. The method described is referred to as the

“Long Line’ method.

Another method used is the ‘* Herringbone”

method. If the field slope is in exeess of two fee

per one hundred fect, the concrete tlhimes previously

mentioned are laid along the ridges or highlands.

The field slope may be as high as 10 or 12 feet per

one hundred feet. Openings cast in the sides of the

walls at the time of making are spaced so that

these openings are opposite the head of each furrow.

The furrows run across the field at 2 moderate

grade. The irrigator adjust. the flow of water

through the holes in the conerete flume with the

use of a metal scoop placed in the flume. These

Scoops are made in the plantation tinsmith shop

for this purpose.

Four water supply ditchmen are responsible for

50 Waialua Agricultural Co., ete.

the inspection, maintenance and control of the upper

reservoirs and intake dams. Twelve water distribu-

tion ditehmen are responsible for reeciving the

irrigation water at the main canals and distrib-

uf ng it to the field irrigators. During periods

When irrigation is suspended, both the water supply

ditechmen and the water distribution ditchmen are

engaged In maintenance, cleaning and minor repairs

to the ditch and reservoir systems. At present, 105

emplovees are engaged [54] in field irrigation and

incidental cultivation of specific fields. These field

inrigators receive water from the field supply ditch

or one of the main canals and distribute it according

te one or the other of the two methods described

above,

The entire irrigation system of the Plantation is

located on lands owned or leased by the Plantation

and constituting a part of the integrated farming

unit. The location of the principal plantation irri-

gation channels, canals, reservoirs and pumps. is

shown on Exhibit "CL"

The frequency of irrigation applications varies

slightly during the year, depending greatly on

natural rainfall received and to a lesser extent on

the temperature and amount of sunlight. The domi-

nant factor in determining the frequeney of irriga-

tion is the age of cane and the consequent spread

of the root system and the exposed leaf mass. The

mass of stalks and leaves offer great resistance to

the thaw of Irrigation Water at the base of the plant,

thereby requiring heave applications af Water, A

vs. Ciraco Mane ja, et al. dl

gencral schedule of irrigation frequency, for periods

without rainfall in excess of 0.50 inch, at the Plan-

tation is:

Cane from 0 to 1 month old: Irrigate every 7

to 10 days,

Cane from 1 to 6 months old: Irrigate every 12

days.

Cane from 6 to 12 months old: Irrigate every

15 days.

Cane from 12 to 18 months old: Trrigate every

18 days.

Cane from 18 months to maturity: Irrigate every

20-25 days.

Cease irrigation from one to three months before

harvest. [55]

Irrigation frequency at the Plantation is guided

by soil moisture samples collected weekly from each

field of the Plantation. The field eapacity of each

soil type has Ween determined by standards de-

veloped by the U.S. Department. of Agriculture,

and the soil moisture available to the plant is re-

ported for each locality in terms of acre inches

of water available and the number of days interval

required to replenish the supply.

For the crop years 1933-1945 inclusive. the ratio

of sugar produced to million gallons of water used

for irrigation at the Plantation was as follows:

32 Waialua Agricultural Co., etc.

Crop Tons Sugar Million Gallons Tons Sugar

Year Produced Water Applied Per M.G. Water

AE 55,473 29,588 1.87

EE Snunddinennobtnciins 55,669 31,454 1.77

I a 50,520 25,554 1.98

IEE accuiladoneaad ceesecnerss OOOO 29,068 1.85

SSE FY 29,085 1.82

Se ee 46,853 29,478 1.59

ATES Eee eee 53,879 30,509 1.77

URES 58,212 30,548 1.90

See 58,410 29,896 1.95

TIE Sincecelsiet ciel cie i 52,967 24,665 2.15

| ENS 51,875 26,003 1.99

ASS 54,684 29,658 1.84

UE teiichhlidnhdeataaee i 56,193 26,507 2.12

From 1899 to 1941, inclusive, tons sugar are

commercial; from 1942, tons sugar are 96° U. S.

Department of Agriculture.

13.

Harvesting

Harvesting is programmed at least one or two

years in advance and the order of harvesting the

various fields determined. In order to assure a con-

tinuous and balanced flow of cane to the mill, har-

vesting schedules must be properly balaneed with

planting and ratooning of succeeding erops, [56]

irrigation water distribution and the capacity of

transportation facilities. In this way the harvest-

ing, planting, ratooning, irrigating, transporting and

milling operations can be evenly coordinated. Har-

vesting operations are conducted throughout the

vear except during the so-called ‘off-season?’ —a

period of approximately three months when the

mill is closed down for repairs as will hereinafter

he described. Before any harvesting operations com-

menee, field maps are prepared and the entire har-

vesting operation is planned out in every detail.

vs. Ctraco Mane ja, et al. 53

Sugar cane fields ready for harvesting are first

burned over. Experience has shown that burning

of the sugar cane results in insignificant losses in

sugar content while efficiency in harvesting is

greatly increased not only in removing the eane

from the fields, but also throngh reduction of the

amount of trash carried to the mill. Efficiency in

operation of the transportation system as well as

in the operation and maintenance of the mill is

thereby effected. Trash percentage may run as high

as 50 to 60 per cent in harvesting unburned cane,

but in harvesting burned eane, trash percentage

averages only 13 to 20 per cent. Trash is the term

applied to anything other than millable cane, and

includes dead cane, soil, foliage, cane stools. stones,

tramp iron or any other foreign matter gathered up

and sent to the mill in the course of harvesting

operations.

An average of 10 to 15 acres of cane is burned at

one time. Firebreaks approximately 15 feet wide

are cut through the unburned cane by a moditied

(-horsepower tractor bulldozer referred to as a

bulldozer rake. This machine has a series of nine

heavy steel teeth extending out in front of [57]

the machine and tears the cane stalks from the

stools and pushes the cane off to the side inte the

upright cane. It requires one operator. A) eround

erew of four men work with the rake cutting cane

stalks missed by the rake and alse removing ob-

structions in the preparation of firebreaks. They

also clear aveas around telephone and power line

poles, fenees and pump houses for proper fire pro-

fection during cane burning. This crew alse mids

o4 Waialua Agricultural Co., etc.

the rake operator in making minor repairs on the

machine.

After the firebreaks are completed, a crew of six

men proceeds under the field supervisor to set fires

aleng the firebreaks. Backfire is a common prac-

tice as a safety measure. Burning of the cane may

be performed at any time during the day, including

early mornings or late evenings depending upon the

winds and weather conditions. The six-man crew

performing this work is commonly referred to as

the “‘burn eane crew.’’ Four of the men in this

crew make up the rake crew referred to above.

After the cane is burned, this rake and the four

ground crewmen open up lines through the burned

cane for the laying of portable track over which

empty cane cars can be hauled from the main line

of the Plantation railroad on a siding thereof into

the field for loading and full cars can be hauled out

of the field, to the main line for transportation to

mill. A portable track plow or leveler then follows

through the lines opened in the burned areas by the

rake to make proper beds for the portable track.

This equipment consists of two rails welded to-

gether to a point, then spreading out into a large

trowel-shaped attachement mounted on the front of

a 30-horsepower caterpillar tractor. A rail [58]

drag consisting of a number of rails welded to-

gether in a rectangular form 9 feet by 6 feet and

attached by a chain to the rear of a tractor is pulled

along the track lines for further leveling. The plow

is used to break up the packed soil while the drag

is used to fill or drag out excess soil. Ditehes and

vs. Ctraco Mane ja, et al. 55

manned by one tractor operator. When the tractor

is not required, the tractor operator leaves his ma-

chine and performs work, as required, with the

portable track crew.

When the portable track beds have been prepared,

rail cars loaded with sections of portable track are

then drawn into the field by tractors. The portable

track lifting machines lift the track sections from

the loaded cars and place them in approximate po-

sition on the track bed. A crew of three men fol-

lows, and, with the aid of a pinch bar, draw the

sections together, placing shoes on the connecting

joints, flush end to end.

After the portable track line has been laid from

the main line into the field, empty cars are hauled

into position for loading. The number of cars

needed for each portabie track line is determined

by the estimated tonnages of cane on the ground. It

the cane tonnage is light, or cane is being picked up

after the first loading, the cars are spaced to carry

an average weight. If the tonnage is heavy, the ears

are left coupled up the full length of sueh track

line,

Where the main line passes through the field or

is adjacent to the field the main line is utilized as a

field track, harvested cane being loaded directly into

rane cars spotted on the main line track. [59]

The cane is loaded on the cars by caneloading

machines. These machines are caterpillar cranes

Weighing approximately 23 tons equipped with a

1G-foot boom and a finger-like grab which pulls or

grabs the cane loose from its growing position and

loads it direetly into rail ears. The machine is

56 Waialua Agricultural Co., ete.

operated by a 65-horsepower diesel engine. The

cane grab operated by heavy steel cables consists of

a number of tines capable of lifting approximately

one to two tons of eane at one time. The machine

moves on its eaterpillar treads parallel with the

portable track lines on which the cane cars have

been placed. The Plantation owns nine of these

caneloading machines. Four caneloading machines

are normally assigned to each harvesting operation,

there usually being two harvesting operations being

performed on the plantation simultaneously; the

remaining machine acts as a spare. Each machine

has one operator and four ground erewmen for each

of two 8-hour operating shifts per day. The four

ground crewmen for each ecaneloading machine cut

cane stubble and stack up loose eane falling from

the grab. They give guiding signals to the operator,

remove obstructions from the path of the machines

and assist in minor repairs to the machine itself.

The loading machine is sometimes called upon to

assist in placing wrecked ears back on the field or

main line tracks, and in such eases the ground crew

constitutes the wrecking crew working with the op-

erator. A service unit of one operator and a helper

service all equipment each day. Lunch periods of

the loading machine crews are staggered to permit

servicing by the service unit without delaying the

operation. Cane which is located in field corners,

along fenees, under transmission lines or which is

otherwise [60] diffienlt or impossible to reach with

the eaneloading machine, is bulldozed into reach-

able piles by the rake and subsequently loaded into

ears by the caneloading machine.

us. Ciraco Mane ja, et al. 57

The caneloading machines are equipped with gen-

erator units supplying power for the operation of

Hoodlights on the boom and the eab. The entire

machine and the ground surface around the ma-

chine have sufficient light so that the efficiency of

the night loading operations is equivalent to that of

day loading.

During the interim period between the termina-

tion of the day shift work and the beginning of the

night shift, service and repair men complete neces-

sary repairs. During this time also the haul cane

men, hereafter described, are able to remove the

balance of the loaded cane cars out of the field,

thereby permitting the locomotives to clear the side

tracks and bring up empty cars for the night load-

ing operations.

After cars are loaded by + eaneloading machine,

they are hauled from the field to the main line of

the railroad (at the edge of the field) by tractors.

Employees handling this operation are called. the

haul cane crew, Preparatory to the movement of

the loaded cane cars, one man or more of the haul

cane crew using a eane knife cuts off some over-

lapping or protruding cane. Two haul cane trae-

tors then move into position. One tractor is coupled

directly to the rear car, enabling the operator to

push or hold back the entire string of cars as re-

quired oy the gradient of the track. The seeand

tractor couples up alorgside the cars in the front

half of the string by means of a cable and is also

in position to push or to hold back the cars. The

sround erow then mans the brakes o. the cars, re-

08 Waialua Agricultural Co., ete.

leasing them to start loaded cars rolling, and there-

after releasing and applying brakes [61] as_re-

quired to eliminate full load weights on the tractors.

Carloads average 4.75 tons per car gross cane.

Cane trains may consist of as many as eighty to

ninety cars, depending upon the grade or the steep-

ness of the field. Cane trains average sixty cars.

Movement of field loads are supervised by the haul

cane supervisor and the supervisor in charge of the

field, one taking charge of the front and the other

the rear portion or half of the train load. They

signal the hand brake operators and the tractor

operators. The steady crew for this operation eon-

sists of the haul cane supervisor, two tractor oper-

ators and three brakemen on the day shift, with one

tractor operator and two brakemen on the night

shift. Tractors equipped with lights move empty

cars into position for the night loading with the

assistance of the brakemen.

A pickup crew consisting of two sunervisors, two

tractor operators, and twelve to sixteen ground crew-

men pick up all cane pieces along the track, throw-

ing the cane into carts drawn by tractors. Full

earts are dumped near the loading machines The

erew also handeuts and loads cane from such parts

of the field as the loading machine and bulldozer do

not reach. When field) pickup is completed they

serve as ground erew men for a small diesel loco-

motive which tows empty cane cars along the main

line from the field te the mill, picking up fallen

eane. After the loading machines leave the har-

vested field, this crew cleans up remaining cane

us. Ciraco Mane ja, et al. 29

loading it into e¢ane cars pulled by a tractor. The

erew also serves as a general utility gang acting as

replacements for the other gangs or crews. [62]

14.

Railroad Transportation

From the time the Plantation was organized, and

continuing to the present, the Plantation has owned

and operated a narrow gauge railroad system. This

railroad system is constructed, located and operated

exclusively on the plantation. It hauls no cane or

freight for anyone other than the Plantation. It

is used predominantly by the Plantation fer the

purpose of hauling sugar cane from the fields of

the plantation to the plantation mill. (Cane burned

by accidental fires is sometimes hauled to the mill

by truck if the tonnage is small.) It is also used

to a much lesser extent to haul portable rails and

other agricultural supplies and equipment from the

plantation warehouses and shop yards to and from

the fields. However, most of this latter type of

hauling is handled by the plantation trucks operat-

ing over plantation field reads and also public

roads,

The plantation railroad is also used for one other

purpose at the present time. The Plantation has

a spur track of approximately 3.000 feet in length

running from its mill and warchouses and connect-

ing with the railroad line of the O. R. & L. This

spur track is used by the Plantation to deliver box

and tank cars loaded with sugar and molasses to

the O. R. & L. and to receive incoming plantation

60 Waialua Agricultural Co., etc.

supplies delivered to the Plantation by the O. R. &

L. The O. R. & L. discontinued its operations at

the end of the year 1947. Since that time the out-

going and incoming freight of the Plantation has

been handled by an independently owned and op-

erated trucking company. [63]

Attached hereto and made a part hereof is a map

marked Exhibit ‘‘D’’ showing the location of the

railroad lines composing the railroad network ex-

tending over the plantation. This railroad network

consists of fifty-six miles of main line track and

nine and thirty-four hundredths miles of portable

track. Portable track laid in the fields is not shovm

on the map since it is installed only during the

harvesting period and is then removed when har-

vesting is completed. Also omitted is a total of

approximately twelve and one-half miles of line

which is not permanent inasmuch as it is laid either

biannually or annually on plantation roads.

Portable track laid in the field) for harvesting

operations lacks proper roadbed for the econ.

tives. The primary reason for the use of the port-

able track for harvesting is that permanent track

cannot be laid in the field because of interference

Which would otherwise result in planting and eul-

tivating operations. During the short periods when

such track in the fields is in use it is an integral

part of the railroad system over whieh eane cars

Move directly from the fields to the mill.

The plantation railroad equipment is as follows:

Six 25-ton steam locomotives, one 17-ton steam

locomotive, one T2-ton steam locomotive. one 12-ton

us. Ciraco Mane ja, et al. 61

gasoline locomotive and one 14-ton diesel locomo-

tive; two hundred steel cane cars. measuring ap-

proximately 11 feet by 6 feet by 5 feet, and five

hundred and twelve wooden cane cars measuring

approximately 10 feet by 6 feet by 5 feet.

Main line switches to portable track, a few of

Which are permanent, are installed at predeter-

mined locations [64] along the main line for mox e-

ment of empty cane cars into the fields to be

harvested and return of the loaded cars. The num-

ber of switches used per field depends on the

proximity of the field to the main line, its size,

shape and terrain.

Empty cane cars are moved into the harvesting

fields as much as possible at night with the night

shifts of railroad crews. This allows the night har-

vesting field crews to spot empties for night and

day loading operations free from interferences of

outgoing traffic. Empty cane cars are moved into

the harvesting fields during the daylight hours only

as ame and traffie permit or te meet a field exigeney

or to meet demands of the mild for additional cane.

Loaded cane cars are haul Prom the field to a

main line track by tractors and thence to the mill

by steam or diesel locomotives during daylight

hours only, On the return from the mill available

eipty cars are moved to some poimt near the har-

vesting field. In this manner flow of traffic in and

outoof the harvesting fields ts primarily one-way

traftic.

Krpty cane ears are often pushed by the loer-

totives direethy onto the portahle track. Loeome

62 Waialua Agricultural Co., etc.

tives do not go onto the portable track, only to the

field switch.

Loaded cane ears are moved part way onto the

main line. The cars may be stationary or may be

moving at the time connection to the locomotive is

made. At places «vhere a siding is convenient, the

loaded cars may be moved onto the siding by field

tractors.

Movement of trains to and from the mill is ae-

complished with a train crew of four men consisting

of an engine driver, fireman, front and rear brake-

men. Six to nine crews, with an average of seven,

depending upon harvesting field locations, [65] are

required daily to handle cane and incoming and

outgoing freight. The yard engine, which operates

during the day only, handles the incoming and

outgoing freight, and assists with spotting and

segregating Incoming cane cars. Maintenance of

a steady flow of cane ears to the mill is also the

responsibility of a vard crew.

A crew of a diesel engine locomotive driver and

one man sprays the railroad rights-of-way with a

herbicide approximately every two weeks. The op-

eration requires four days.

Employees known as section men maintain the

main line trackage and keep it in good repair.

Picking up of cane spilled along the railroad

rights-of-way requires two to three days per week

with one locomotive and an average of twenty cars.

The piekup crew consists of locomotive driver and

one brakeman (diesel locomotive is used) together

vs. Ciraco Mane ja, et al. 65

with a crew of pickup men from the field of between

six and twelve men.

One hostler and one engine wiper wash the loeo-

motives and steam boilers, oil and grease the loeo-

motives, fire the steam locomotives preparatory to

the day's operations and assist in minor repairs to

locomotives. This service Work is performed in the

plantation roundhouse.

Ten crossing watchmen are used to protect the

public at government read crossings. Between the

hours of 10:00 p.m. and 6:00 a.m., train erews are

responsible for flageing all government road cross

ings. One man is used to dry and maintain a sup-

ply of dry sand for use by the locomotives. Another

man is employed to keep the mill yard rights-of-

way clean.

During the off season when cane is net being

harvested, the section men are used in the repair

and maintenance of [66] main line trackage sup

plemented by approximately twelve brakemen and

five firemen. Watchmen are used for cleaning and

weeding the rights-of-way. Usually one engine

driver, two firemen and three brakemen are as-

signed to assist the electricians on mill work

primarily. One firem: » and two brakemen are ven-

erally assigned to the welding shop for assisting in

off season factory repairs and installation of new

equipment. Two more brakemen are sometimes as-

signed to boiling house repair work. One vard

engine erew is maintained during the off season. The

crew consists of engine driver and brakemen for

the diesel locomotive. Engine drivers. not otherwise

used, assist im locomotive repairs,

64 Waialua Agriculturcl Co., ete.

1é.

Field Road and Public Road Transportation

The size of the plantation has necessitated the

construction and maintenance by the Plantation of

a network of field roads for the transportation of

labor, field supplies and equipment throughout the

plantation. |

This network of roads is shown on the transporta-

tion map marked Exlibit **D."” The main roads,

as shown on this Exhibit, are publicly owned roads,

paved and maintained by the City ana County of

Honolulu, or by the Territory of Hawaii.

Most Plantation-owned roads are dirt surface

roads, maintained by the Plantation with its own

diese] powered grader. A few roads have a_ top

dressing of either sand, coral ov crushed rock. Some

Plantation-owned roads are paved.

These roads are used to transport plantation

labor from the main plantation village situated

around the plantation buildings and yard area out

to the fields; some plantation [67] labor, however,

is hauled from outlying villages to various fields.

All this labor is hauled by truck.

Kield supplies, such as concrete irrigation fiumes,

irrigation flume putty, fertilizer, cement, ete., are

hauled from the plantation warehouses and yard

area out to the various fields by 114-ton to 714-ton

gasoline driven trucks. At times the plantation rail-

road may be used to haul some of the above sup-

plies, especially when certain parts of the fields are

more easily reached by railroad. Most of the time

the fertilizer is loaded by hand directly from O. R.

vs. Crraco Mane ja, et al. 5)

& LL. box ears onto trueks and then hauled to the

fields. Cement and other supplies are loaded from

warehouses by hand onto trucks. Conerete prod-

ucts, such as irrigation flumes, pipes, ete. are

loaded from the plantation-owned and operated con-

erete products vard onto trucks by hand.

Herbicides are hauled in their original containers

from a Plantation warehouse to nearby mixing sta-

tion by trucks. After the herbieide is mixed, it is

put into 2-gallon containers and trucked out to the

fields in a one-ton truck, Tank trucks haul mixed

diluted herbicide solution out and spray this on

weeds located along roadsides, ditehes, ete.

Cane seed is trucked on 2!.-ton to 715-ton trucks

from the field in which the seed is cut into the

fields where it is to be planted. This seed is bagged

and loaded by hand.

All field mechanical equipment is hauled from

field to field or to the shops on rubber-tired trailers

drawn by trucks or a rubber-tired tractor. Heavy

equipment, such as harvesting machines, plow trae-

tors, cane rakes, bulldozers, ete., is hauled on a

large 25-ton, 6-wheeled trailer drawn [68] by a

98-hersepower rubber-tired tractor. Light equip-

ment, such as ratooning tractors and other light

tractors, is hauled on a 2-wheel trailer drawn by a

214-ton truck.

Fuel and servicing equipment for field power

operated equipment, such as harvesting machines,

tractors, air compressors, ete., is hauled out in tank

trucks. Fuel for the two steam irrigation pumps is

hauled in O. R. & L. tank ears from the O. R. & LL.

66 Waialua Agricultural Co., ete.

siding to the pumps by Plantation locomotives on

the Plantation railroad.

Sand is hauled from a Plantation-owned sand

area in Waimea Bay to various parts of the planta-

tion in 214- to 714-ton trucks. The sand is loaded

mainly by crane and clamshell bucket, but is some-

times loaded by hand.

At times when there is 2 shortage of certain sup-

plies at the plantation, trucks may go to Honolulu

or any other part of the island to obtain them.

16.

Cleaning Cane

Locomotives deliver the loaded cane cars to the

mill yard to be moved up to the cane cleaning plant

where the cane is washed in preparation for con-

veyance into the mill. Locomotives bringing in cane

ears may move the cars directly into position for

unloading into the cane cleaning plant, if all cane

ears delivered to the mill on the preceding day

have been emptied during the might operations of

the mill. One of the mill vard track lines leads

directly into the cane cleaning plant and accom-

modates approximately one hundred loaded ears.

An adjacent traek line receives empty cars from

the cane cleaning plant and accommodates about

sixty cars. [69] During the night, loaded cars are

moved up from the track sidings by a mill yard

engine, since additional toaded cane cars are not

delivered to the mill from the field during the night.

Time elapsing between the loading of the ears in

the tield and the unloading into the eane cleaning

us. Ciraco Mane ja, et al. 67

plant may vary from four te sixteen hours. Time

elapsing between the arrival of cane from the field

to the mill vard and the unloading into the cane

cleaning plant may vary from a few minutes to an

hour during the morning. Cane delivered to the

mill yard in the afterncon may not be unloaded

until the following morning.

Cane once cut or burned undergoes an inversion

process involving a chemical reaction of the

sucrose, the sugar content of the cane, which trans-

forms it mto undesirable compounds. This reac-

tion, commencing with burning and_ harvesting,

continues with increased acceleration until the juice

is chemically treated or concentrated in the form of

syrup. Hold over of cane in cars in the mill yard

will result in a substantial inversion factor. For

this reason, harvesting activities and mill activities

are closely coordinated to reduce to a minimum any

hold over of the cane before crushing. Ideal condi-

tions are those in which there is a complete eon-

tinuity of movement of the cut cane, permitting

direct and immediate delivery from the harvest

field to the cane cleaning plant for cleaning pre-

paratory to crushing.

The following table shows the progressive rate

of deterioration of burned cane, whether standing

or cut, when not milled and the resulting percent-

ages of sugar losses: [70]

Davs since burning or cutting 1 2 3 4 5

Burned, left standing... 3.05 609 914 12.18 15.93

Burned, cut at once... ... 284+ 569 8.53 11.388 14.22

Days since burning or cutting 6 7 8 9 10

Bumed, left standing................... 18.03 20.83 23.63 26.43 29.23

Burned, cut at once......................-. 17.43 20.64 23.84 27.05 30.26

68 Waialua Agricultural Co., etc.

The purpose of the cane cleaning plant is to

remove as much trash as is mechanically possible.

Tramp iron and rocks passing into the mill rollers

result in serious damage to the rollers and equip-

ment, requiring shut downs for repairs.

Loaded cane cars are pulled into the cane clean-

ing plant by means of a heavy steel ferk that en-

gages the end car and the car line is pulled forwaru

one car length at a time by means of an electric

gear motor, sprocket and chain. As the string of

loaded ears is hauled into the eane cleaning plant,

each car is uncoupled as it goes onto a small rail-

road scale. Each loaded cane ear is supplied with

a ticket in a small metal pocket on the end of the

ear, the ticket having been placed there in the field

at the time of loading. These tickets have the car

numbers marked on them, together with informa-

tion as to the field, the time and date the cane was

burned, the date of loading and the cane variety.

The scale man removes the ticket from each car and

enters the weight while the car is on the seale. These

tickets are collected and totaied hourly and are

an important step im mill control. No washing or

trash removal takes place prior to weighing the

ears of cane.

After sealing a loaded car, the car is pushed

onto the car dumper by the next car entering the

scale. When it has come to a stop in the center of

the dumper table with the front ear axle against

a stop, the cane cleaning plant operator clamps if

down to the dumper table by means of [71] elee-

us. Cr, aco Maneja, et al. G9

trically operated clamps which engage the car. The

operator then unhooks the car side chains that hold

the cane in the car. The electrically operated

dumper table is tilted to an angle of sixty degrees

and the cane slides out of the side of the car and

into the tumbling conveyor, after which the op-

erator lowers the dumper. The empty car on the

dumper table is displaced by the next loaded car

coming off the scale and rolls onto an electrically

operated transfer car which carries it across to the

empty car line. It is then pushed onto the empty

line by a motor operated pusher and is manually

coupled to the end car in the empty string, the car

couplers being of the link and pin type.

The loaded car line is replenished at about two-

hour intervals and empty cars are hauled away at

one- to two-hour intervals.

The cleaning process is divided into three parts

and starts in a tumbling conveyor. First, the cane

bundle is tumbled on a steep carrier sixteen feet

wide and about fifty feet long, consisting of pipes

attached to a conveyor chain with one-half inch

spaces between the pipes. Cleats are attached to the

pipes to facilitate carrying the cane up the steep

incline of this carrier. Stationary side plates pre-

vent the cane from falling off the sides. of the con-

veyor. The conveyor moves at a maximum rate of

180 feet per minute, but may be operated at any

speed below this since it Is driven by a variable

speed motor. The cane comes off the cars in a

tangled mass and the tumbling conveyor breaks up

70 Waialua Agricultural Co., ete.

the mass so that the cane is carried up the steep in-

eline in a thin layer. Considerable amounts of dirt

and fine trash fall through the earrier onto a drag

conveyor below. When rocxs are present [72] in

the cane, the carrier is stopped after they have been

shaken out of the cane mass and are rolled by hand

off the lower end into a rock conveyor below. A

gate at the lower end of the carrier is raised by

means of an electric hoist during this operation.

As the eane leaves the upper end of the tumbling

conveyor, it is dropped onto the lower end of a

wash carrier. This wash carrier is sixteen feet wide

and twenty-five feet long. Water is sprayed on the

eane at the rate of about 2,000 gallons per minute

as it is earried under three sets of nozzles placed

over the upper portion of the carrier, This water

washes the cane directly under the nozzles and

eascades down through the cane approaching the

nozzles. In this way, most of the mud and dirt is

removed from the cane. This carrier is driven by

the tumbling conveyor motor.

When the washed cane leaves the wash carrier,

it is skidded down steel] plates to leave stripping

rolls. There are twenty-four pairs of these rolls

which are in contact and turn toward each other.

They are driven by six electric 25-horsepower gear

motors and remove most of the leaves and trash

from the cane as the cane slides over thein. Very

little cane is pulled through. Leaves and trash thus

removed fal] into a flume underneath the rolls, and

this material is flumed away.

us. Ctraco Mane ja, et al. 71

After leaving the leaf stripping rolls, the cane

falls into the mill carrier, which transports it to

the crushing plant. When rocky fields are being

harvested, rocks tind their way into this carrier

and a watchman is kept at this station to watch for

and remove them. The lower end of the mill ear-

rer is in a cement lined pit six feet wide. [73]

During bad weather when the cane is unusually

dirty, water is sprayed on the cane in the lower

portion of the carrier and the dirty water is

pumped out of the pit.

Most of the mud and dirt from the eane is flumed

with the wash water to low fields near the mill.

Leaves and trash, removed by the stripping rolls,

are flumed to a nearby motor driven three-roll mil]

where the material is ground fine and then dumped

into the wash water flume for disposal.

Seven men per shift are required in the cane

cleaning plant. One man uncouples the loaded ears

as they come onto the cane scale. Another scales the

cars. A third operates the electrical control board

that activates the car haul, the car dumper, the

empty car pusher, the rock and ditt carriers, the

tumbiing conveyor and the wash earrier. A fourth

couples up empty cars. The uncouple man, the

seale man and the eouple-up man assist in removing

any cane left on the cars after they have been

dumped and in removing stones and foreign ma-

terial from the tumbling conveyor. A fifth man is

stationed at the wash carrier to see that no cane

jams occur and to remove pieces of cane from the

small drag carrier that sereens the dirty wash

72 Weinlua Agricultural Co., ete.

water. A sixth man serves as rock watchman on the

mill earrier. The seventh man drivi> a rock and

dirt disposal truck.

In addition to the seven men per shift in the

cleaning plant, two men are required to work, on

the day shift only, in the disposal fields, spreading

the flumed ground trash anc mud. [74]

17.

Chopping and Crushing Cane

Extraction of juice from the cane stalks is pos-

sible only when the cane cells and tissues are rup-

tured. This rupturing action can be advanced by

shredding or chopping the cane with knives, and

thereafter completing the extraction process by

corapression exercised between grinding rollers.

After the cane has passed through the cane clean-

ing plant, it is carried on a six-foot wide c.rrier

to the crushing plant. Before entering the crusher

room, the cane passes under a set of sixty-eight

revolving knives bolted to dises on a shaft set

across the carrier. The shaft is driven by a 125-

horsepower motor. These knives serve to level the

blanket of cane as it is carried up to the crusher.

A similar set of knives is located at the top of the

carrier. These knives chop up the cane as it leaves

the carrier. From the mill carrier the chopped cane

is dropped down a chute into the crusher rolls.

The crushing operation consists of a cane crusher

and five mills arranged in tandem and extended

about 136 feet.

The erusher consists of two rolls, 78 inches wide

~”"y

vs. Crraco Maneja, et al. ie

and 39 inches in diameter. The five mills consist

of three rolls each which are also 78 inches wide

and have a diameter slightly less than the diameter

of the rolls in the crusher. The three rolls in each

mill are arranged horizontally with two rolls below

and one voll fitting down on top. (The term ‘*mill”’

is here used to refer to each of the five units of

three rolis. As so used, the term should not be eon-

fused with its common usage in referring to the

buiiding in which the entire processing [75] op-

eration is conducted. The term ‘*erusher’’ is used

to refer to the unit of two rolls which crush the

‘ane and pass it on to the mills.)

The purpose of the rolls is to press the fibre and

remoye the juice contained therein. The fibre pass-

ing through fhe rolis is referred to as bagasse. One

hundred per cent extraction of tue juice is impos-

sible due ip part to the eapillarity of the bagasse.

Normally, 40 to 60 per cent extraction is achieved

in the crusher rolls. The purpose of the sueceeding

five mills is to extract the remaining juices.

The erusher rolls are set horizontally with a 1”

opening between the rolls. Bearings on the top

rol] are so arranged as to permit the top roll to

rise slightly as the cane goes through. At the same

time, hydraulic jacks are set in such a manner as

to deliver the desired pressure on the crushed cane

as it goes through. Flow of cane to the crusher is

controlled by regulating the speed of the mill ear-

rier. Juice squeezed out of the cane is collected

in a sloped copper ,2ice pan set below the crusher

and the first mill rolls. This juice flows through a

74 Watalua Agricultural Co., etc.

sereen and is flumed to a juice tank from whieh it

is pumped to the boiling room.

The crushed cane passing between the crusher

rolls is discharged directly into the first mill. Clear-

ance between the front or leading bettom roll and

the top roll in this mill is three-eighths of an inch,

Clearance between the top roil and the back or

discharge roll is one-fourth of an inch. Juice ex-

tracted in the first mill is collected in the same

pan that receives the crusher juice. Approximately

70 per cent of the normal juice in the eane is ex-

tracted in the erusher and the first mill. [76]

The sueceeding four mills are similar to the first

mill, except that the rolls are set slightly closer

together.

The erushed or ground cane is conveyed from

one mill to the succeeding mills by means of an

inclined closed chute. Before ente ‘ing the last mill,

hot water is applied to the ground cane. This re-

sulting solution is squeezed out in the last mill and

is collected in a conical copper pan under the mill,

from which it is pumped to juice spreaders between

the previous mills where it is spread on the crushed

‘ane and again passes throug! the other mills,

ultimately being collected in the one juice tank from

which it is then pumped to the boiling house.

Approximately 96 to 97 per cent of the sucrose

in the cane is removed in the milling process.

Moisture content of the bagasse averages 45 per

cent. Fuel value is roughly equivalent to sawdust.

All of the bagasse is burned under the boilers to

generate steam for the processing of the eane and

us. Ciraco Mane ja, et al. TO

to produce power for the various integrated opera-

tions of the Plantation as wiil be hereinafter ex-

plained. The bagasse is carried by an inclined drag

carrier from the No. 5 mill to an overhead dis-

tributing conveyor in the fire room.

The mill and crusher retis are driver by three

steam engines totaling 1,400 horsepower. Since the

erusher rolls turn at a different speed from the

mill rolis while engines operate at a higher speed,

a system of heavy gears supplies the proper reduc-

tions in power.

Right motor driven centrifugal juice pumps are

installed to pump the juices through the crushing

and milling process and also to pump the mixed

juice to the boiling room. [77]

Seven men per shift work in the crushing plant.

Three engine tenders operate the three engines pro-

viding power for the crusher and the mills. By

regulating the speed of the engines, the engine

tenders can maintain an even feed through the

crusher and mills in coordination with the feeding

of the cane from the cane cleaning plant. One

engine tender is in charge of the crusher and the

mills and regulates the rate of operation. The sec-

ond engine tender is responsible for repairs in the

eane cleaning plant. The third tender is responsible

for lubrication of the mill gear system. The fourth

man in the ¢rew acts as mill feeder, regulating the

flow of cane to the crusher. The fifth man is the

mill oiler, responsible for the oiling and greasing

of the erusher and mill mechanisms, and also per-

fornis the oiling and greasing of the cane cleaning

76 Watalua Agricultural Co., ele.

plant. A sixth man is responsible for maintaming

the pressures exerted upon the top mill rolls. Ile

also watches the juice pans under the mill to pre-

vent trash clogging and operates the Juice pumps.

The seventh man is a utility man, taking assign-

ments as directed by the shift engineer.

In case of equipment failures, the engine tenders,

assisted vy other crew members, perform repair

work under the direction of the shift engineers.

Employees in the wetding shop, tia hine shop and

blacksmith shop, however, are called upon to do

most of the repair work requiring welding or

machining. All repair work required during proc-

essing operations to restart equipment must be

handled immediately to avoid serious sugar losses in

burned and harvested cane and in cane and eane

juices being processed and to avoid costly mill

cleaning operations. [78]

18.

Clarifying and Crystallizing

Clarifying of the juices extracted from the eane

in the erusher and mills and the crystallizing into

the raw sugar crystals are performed in the boiling

house.

The raw eane juice from the crusher and mills

is discharged from a flume into juice seales and ts

there weighed.

The juice is emptied from the seaies into a re-

ceiving tank underneath the seales. Milk of lime

solution is introduced into the juice and reacts

upon the phosphoric acid to form a precipitate

vs. Ciraco Mane ja, et al. 4

which permits the removal of the foreign matter

not in solution.

The mixture of juice and nuilk of linie is pumped

from the receiving tank through a set of four hori-

zontal tuoular heaters which function in sets of

two each.

The limed, heated juice is piped to the elaritier.

This consists of @ series of five trays, one above the

other, ino ai closed tank. Scraper arms revolve

slowly in this clarifier and the precipitated **mud”’

settles in the trays and is scraped to the side to flow

to the bottom of the elaritier tank. The clean juice

is drawn off through a pipe froin each compartment

formed by the series of trays. The clavitier, with its

five trays, measures 28 feet in diameter and 30 feet

in height.

The “mud” in the bottom of the clarifier is

treated in a side process since it contains cousider-

able sucrose and must be filtered to enable recovery.

It is therefore pumped to a filter station. There it

is first passed through a mixing tank where fine

bagasse, pneumatically conveved from the tire

room, is added to the “mud” as a filter aid. [79]

Three filters, consisting of rotating drums and aet-

ing on the vacuum principle, retate in the solution

of ‘mud’ and bagasse, picking up 2% so-called

“mud"’* cake on the surface of the drum which is

then carried through several hot water sprays that

wash out a large amount of sucrose, leaving a

waste residue which is disposed of by means of a

conveyor operating to a flume where it is washed

out to a aml waste disposal vard. Washings from

78 Waalua Agricultural C'o., ete.

the filter, although not elear enough to be added

to the clarified juiee, are pumped to the mixed

juice tank for reprocessing as a part of the initial

stage desermbed above.

After passing through the clarifier, the elean

juice flows to a supply tank from which it ts

pumped te the evaporator station. By evaporating

out the water which holds the snerose in solution,

the juice of the eane is concentrated. This permits

erystallization of the sucrese i the ferm of raw

sugar. This coneentration, performed after the

elimination of as many impurities as possible in

the clarifier, is begun in the evaporators, where the

tiajer water content is removed. The second stage,

that which takes place in the vacuum pans, is the

ervstallization stage preper.

In the evaperation stage, the juice is) pumped

first to the pre-evaporator where low pressure steam

is introduced in copper tubes jutting up into the

liquid juiee contained in the pre-evaporator. This

causes the juiee to beil and steam vapor is pro-

duced, collecting in the top of the pre-evaporator

from which it is withdrawn fer heating the vacuum

pans (the secondary stage referred to above). The

juice remaining in the pre-evaporator flows down

to the bottom and then moves [80] into the first cell

of the quintuple series of the evaporator, where the

same process is repeated, and so on through the

remaining four cells of the unit, the reneated proc-

ess in each cell resulting in further evaporation.

Rach of the quintuple cells of the evaporator is

vs. Ctraco Mane ja, et al. 79

heated by the vapors withdrawn from the preceding

cell,

After passing through the evaporator, the juice,

now reduced to a syrup, is pumped to supply tanks

at the vacuum pan station. Here the formation of

sugar crystals occurs. There are five vacuum pans,

each operated as an individual unit. They measure

10 to 14 feet in diameter and 15 feet in height.

Each pan is capable of making thirty-five tons of

raw sugar at a time. The vacuum pans are heated

either by the hot vapors from the pre-evaporator

or by low-pressure steam from the fire room, Re-

moval of vapors in the process is accomplished by

a central vacuum pump which also supplies the

evaporators.

High grade and low grade raw sugar are pro-

duced. High grade raw sugar is always the final

product while the low grade raw sugar is reproc-

essed to make high grade suger.

Low grade raw sugar is drawn into one of the

vacuum pans, inte which the sugar syrap is then

fed until the pan is full. This process requires

approximately 20g to 3l4 hours. During this time

the mixture of low grade raw sugar and syrup is

boiling and the density is maintained at an opti-

min pomt whieh will allow the original sugar

crystal to grow in size but not form any additional

crystals. This condition is determined by the op-

crater Whe retioves and inspects small samples

‘rom time te time. After 10 te 12 hours, the com-

pleted bateh, consisting of sugar ervstals and

Molasses, is [si] dropped from the pan ite a mix-

80 Waialua Agricultural Co., etc.

ing tank from which it is fed into centrifugal ma-

chines that separate the sugar from the moiasses.

The molasses is then pumped back into the

vacuum pans where it is mixed with svrup. The

same process described above is then performed

with this mixture to produce another grade of raw

sugar, which is also elassed as high grade, but not

as high as the grade above described. The molasses

resulting in this operation is lower in sucrose con-

tent. This molasses is the supply for obtaining low

grade raw sugar.

Formation of low grade raw sugar is accom-

plished by the same boiling process, differing only

from the making of high grade raw sugar in that

no sugar ervstals are introduced as a foundation

but the molasses is concentrated to the point where

spontaneous erystallization oceurs. The process is

then checked, and additional molasses is gradually

fed into the pan at a eontrolled rate which will

result in the growth of the crystals formed rather

than formation of additional erystals. This feeding

process continues for six to ten hours. This mixture,

is then dropped into an open evlindrical tank hav-

ing a capacity of 850 cubie feet. These tanks ave

called crystallizers. There are sixteen in use. After

two to three days in process the material is pumped

into a mixing tank from which it is fed into low

grade centrifugals.

The centrifugal station consists of nineteen low

grade and seven high grade centrifugal machines.

These machines consist of rotary baskets suspended

on a spindle and lined with perforated eopper

vs. Ciraco Maneja, et al. 8}

screen. They revolve at a high rate [82] of speed

by a direct connected electric motor, and the een-

trifugal force throws out the liquid material into

a curb from which it is flumed to a storage tank

while the sugar crystals remain on the screen. They

are removed by a mechanical scraper moving ver-

tically along the surface of the sereen. The low

grade centrifugal machine operates for a period

from 45 to 75 minutes, depending upon the quality

and amounts of material on hand. It is. then

stopped, the sugar removed, and the eycle repeated.

Since no further extraction of sugar is possible,

the low grade molasses remaining is an end by-

product. During 1946, an average of 460 tons of

molasses a week was obtained which amounted to

about 3.4 per cent of the weight of the net cane

processed or approximately .26 ton of molasses per

gon of raw rugar. This molasses is pumped to a

storage tank with a capacity of 1.300 tons and from

this storage tank it is repumped into railroad tank

ears for shipment to and sale in the continental

United States. A very small percentage is sold

locally for eattle feed. The percentage so sold

averages 500 to 600 tons per vear,

Low grade sugar removed from the centrifugals

is mixed with water and pumped to the vaeuum

pans for use in the process described above.

The high grade sugar eentrifugals are similar

to the low grade machines except that they are

driven by a high pressure water jet and the drying

eyele is only 3 to 4 minutes. The dried sugar is

removed from the centrifueals to an adjoining

82 Waialua Agricultural Co., etc.

sugar bin preliminary to bagging. The boiling

house employs a total personnel of 45, including the

boiling house superintendent and three shift [83]

foremen.

19.

Sugar Bagging and Shipping

The raw sugar flows from the bin through an

automatic scale which weighs out a 100-pound load,

and dumps it into a chute at the neck of which the

operator has attached a hemp bag. The entire op-

eration occurs in timed sequences automatically

upon the clesing of a switch. The released bag of

sugar is carried out by a conveyor through a sew-

ing machine head where the bag opening is sewn,

and the bagged sugar continues on the conveyor to

a railroad car for loading and shipment to the

continental United States or to the sugar warehouse

on the plantation for temporary storage. :

There are two sets of scales, baggers and sewing

machines with one operator each. Each set handles

about seven bags of sugar a minute. At the present

time the bagging station is operated for two 8-hour

shifts: with two operators on one shift and one

operator on the second shift. An average of 275

to 300 tons per day is bagged at this station. This

represents the average daily raw sugar production

of the mill.

20,

Work Schedules of Mill Eimplovees

Production in = the mill operations is keved

basi ‘ally to a six-day week with continuous and

around-the-clock operations, the null stopping the

vs. Crraco Mane ja, et al. 83

grinding of cane at 2:00 pam. on Saturdays and

starting up at 2:00 p.m. on Sundays. The 24-hour

day is divided into three 8-hour shifts running

from 6:00 am. to 2:00 p.m., 2:00 p.m. to 10:00

p-m., 10:00 p.m. to 6:00 a.m. [84]

21.

Week-End Repair of Mill

The weekly 24-hour shutdown period of mill is

necessary to perform cleaning and repair opera-

tions. The filter sereens must be cleaned out with

a traveling steam jet which takes about 45 minutes

per filter and is performed by the regular shift

operator. The juice heaters must be opened up, the

tubes steamed for half an hour, and then brushed

to remove the loose scale. Considerable scale forms

in the tubes of the evaporators and after the last

juice is removed on Saturday afternoon the tubes

are washed out with water and a continuous spray

of caustic soda solution is applied for 5 to 6 hours.

Then muriatic acid is added and. boiled, the cells

cleaned out with water and opened in preparation

for the seraping and brushing operations. The

vacuum pans are also boiled out with a weak acid

solution and the tubes brushed manually whenever

necessary. The oilers and repairmen also do the

necessary work ou the various pieces of equipment

that can only be aecomplished while they are idle.

Over the weck end two shift crews clean up and

make such repairs as are necessary in the erushing

plant and cane cleaning plant. Engine tenders are

responsible for mechanical jobs in sueh plants. They

are assisted by the remaining crusher room men and

84 Waialua Agricultural Co., ete.

the operators and scalemen from the cane cleaning

plant. Mill oilers are occupied in greasing up the

equipment in the cane cleaning plant.

While, in general, repairs are performed during

the week end, every effort is made to anticipate

week-end requirements and the various shops

located near the mill perform as much work as

possible while the mill is in operation. [55]

22.

No Non-Plantation Cane Processed by Mill

All of the cane processed by the Plantation mill

is produced on the Plantation and by the Planta-

tion.

23.

Sugar Warehousing

Under normal operating conditions the bagged

sugar after leaving the mill is loaded directly into

the railroad box cars for shipment. Due to the lim-

ited number of cars and storage space at the port

wharves and oceasional interruptions in ship sched-

ules, the sugar may be stored temporarily from time

to time in the plantation sugar warehouse. but

even this sugar is normally removed within a

month's time and the warehouse is usually empty

at the end of the grinding season. During the last

tive year period there were two years in which no

sugar Was stored in the plantation warehouse. Raw

sugar is never stored at the plantation because of

price, market or other economic considerations. The

most efficient and prefitable operations call for ship

ment to mainland refineries immediately upon pro-

duction.

us. Ciraco Mane ja, et al. BO

When stored in the sugar warehouse. the sugar

bags are carried by a long belt conveyor from the

room in the mill where they are weighed and filled

to one end of the sugar warehouse building. From

here they drop in a chute to a series of portable con-

veyors which carry them to any part of the build-

ing where they are stacked in piles. Additional

help is needed in performing this piling operation

and two men from the field force are temporarily

transferred to assist the regular pilers. To remove

the sugar bags to rail cars [86] for shipment a crew

of six or seven men is obtained from the field as the

regular men are usually occupied in handling the

current production.

In addition to sugar, all of the empty sugar bags,

in bales of one thousand to six hundred bags each,

ure stored in the warehouse. These are charged out

as they are removed to the mill for use. Due to a

shortage of warehouse space, fertilizer is al: 9 stored

in bags in this building from time to time.

24.

Fire Room and Power Production

In extracting the juices from the sugar cane. one

of the by-products is the cane fibre from the cane

stalks, which is referred to as bagasse. When dried.

one ton of bagasse has a fuel value approximately

equivalent to two barrels of fuel oil. As indicated

above, the extraction of the juices from the cane

hibre and the processing of sugar cane inte raw

sugar require large amounts of power for the opera-

Hon of the prime movers, conveyors and purnipes.

86 Waialua Agricultural Co., etc.

It is therefore traditional in sugar cane processing

to utilize the bagasse as an economical source of

fuel for the production of power for use in per-

forming the various processing operations. An

average of approximately three thousand tons of

bagasse is produced each week when the mil! is

operating at full capacity. Fuel is also essential in

the processing operations for the production of

steam for heating and evaporating of the juices

and the erystallization of the sugar. Fuel is also

used to produce steam for the generation of electric

power needed in the various operations of the plan-

tation, as will be hereinafter more fully described.

Tf the hagasse were disposed of [87] as waste, other

fuel would have to be obtained in order to cbtain

steam. If the bagasse were not utilized as fuel, a

difficult disposal problem would be presented be-

cause of its bulkiness and the large volume involved.

Bagasse produced by the plantation has no market-

able value.

The Plantation attempts to save and store enough

bagasse during the week to meet the requirements

for operating the boiler furnaces on the week-ends

when cane is not being ground. Sufficient quantities

of bagasse are not always available to satisfy the

fuel requirements of the mill. This condition occurs

during periods of breakdown of machinery and

during periods of wet weather when harvesting and

processing operations are slowed down by reason

of heavy trash contents. The beiler furnaces are

therefore equipped to burn fuel oi] which is stored

vs. Ctraco Mane ja, et al. ST

in a concrete fuel oil tank located in the mill yard

near the fire room for convenience of supply.

The fire room of the mill is located adjacent to

the crusher room. It houses seven water tube boilers.

Boiler feed pumps and two condensate pumps are

housed at one end of the fire room and are used to

supply water. A condensate tank is located in the

mill yard area adjacent to the fire room. Fuel oil

pumps and a fuel oil heater are also located in the

fire room area for use when fuel oil is being burned.

Furnaces used in burning bagasse are set in front

of the boilers in the fire room. The bagasse is fed

into the furnaces through chutes connecting with

the bagasse conveyor from the crusher room. Fuel

oil burners are installed in the back of the boilers

and the oil is burned directly below the boiler tubes.

Steam is generated at an average rate of ap-

proximately 150,000 pounds per hour when the mill

is operating at a maximum capacity. Steam lines

lead from the fire room to the crusher room where

steam is used to drive the mill engines which in

turn drive the crusher rolls and the mill rolls. Ex-

haust steam from these engines is piped to the

boiling house for direct use in the processing opera-

tions.

Another steam line from the fire room leads to

the power room for generation of electric power by

® turbo-generator and two steam engine driven

Senerators. Steam enters the turbine at a pressure

point of approximately 150 pounds and after con-

version of the initial energy in the steam into elee-

trical energy by the generator, bled steam. now

88 Waialua Agricultural Co., ete.

‘arrying a pressure of approximately 10 pounds,

is piped to the boiling house for use as process

steam supplementing the steam exhausted from the

mill engines. Steam is also exhausted from the

engine driven generators into the process steam line

in an identical manner with the exhaust steam from

the mill engines.

The automatic bleeder valve on the turbo-genera-

tor is the main coutrol point for maintaining the

pressure in the process steam line at a given

amount. A drop in pressure in the process line will

indicate insufficient process steam for the boiling

house requirements, in which case the turbine

bleeder valve opens automatically, thereby increas-

ing the flow of steam to the process line to main-

tain the necessary pressure for boiling house opera-

tions. On the other hand, if the pressure in the

process line increases above normal, the bleeder

valve then closes proportionately, thereby restrict-

ing the flow of steam to the process line and re-

turning the process line pressure to normal re-

quirements. [89]

Another steam line from the fire room supplies

steam to the steam driven auxiliary units in the

boiling house, and still another leads to the boiler

pump room to operate the boiler feed pumps.

Returning condensate from the power room and

boiling house is heated, together with any required

make up water by exhaust steam from the boiler

feed pump engines. If there is an excess supply of

returning condensate, this flows into the boiler feed

water tank outside the fire room.

vs. Ciraco Mane ja, et al. &9

Seven men per shift work in the fire room with

the addition of two boiler cleaners on the day shift.

The water tender is the fire room foreman and is

under the supervision of the shift engineer. He di-

rects the fire room men and also sees that the water

in the boilers is maintained at the proper level at

all times and that the feed water regulators are

working properly. It is his duty to blow down the

boilers at intervals to keep the solids in the boiler

water below safe operating limits. The fire room

oiler assists the water tender, takes care of the

pumps, oils the carriers and bagasse feeders, oper-

ates oil burners if required and assists in shoveling

bagasse when the mill stops. Two firemen reguiate

the flow of bagasse to the fires and regulate draft

with dampers to maintain steam pressure. They

also watch the water columns on the boilers. Three

ash and trash men clean the furnaces, distribute

bagasse in the bagasse storage space as required

and shovel trash from the stock pile into the re-

claiming conveyor when the mill is stopped. Two

boiler cleaners work on the day shift only. Besides

cleaning boilers they take care of minor repair

work in the fire room. Except for a few pumps,

there is no duplicate equipment. Generally three

shifts are used in the fire room for week-end re-

pairs. [90]

25.

Generation and Distribution of Eleetrie Power

As set forth before in connection with the pro-

duction of steam power In the fire room, the electric

power generating equipment of the Plantation is

seated in the mill. It consists of one 6600-volt

90 Waialua Agricultural Co., etc.

generator driven by a steam turbine and two +0-

volt generators driven by reciprocating steam en-

gines.4 The electric power generated by this ma-

chinery is generated from steam produced in the

boilers, which passes through the generating ma-

chinery and is then conveyed through steam lines

for use in the. processing operations in the boiling

room.

Electric power generated is not sufficient to sup-

ply the needs of the Plantation. For the purpose

of supplementing the power generated, electric

power is purchased from the Hawaiian Electric

Company, Limited, an independently owned and

operated public utility, on the Island of Oahu. Dur-

ing the period 1941-1945, inclusive, power generated

in the Plantation system represented 64-6/10 per

cent of the amount consumed. The remaining

35-4/10 per cent was purchased from the Hawaiian

Electric Company. The following table represents

POWER GENERATED AND PURCHASED

(Kilowatt-Hours )

Year Power Generated Net Purehased Total

1941 13,920,751 6.298 32S 20,219,079

1942 12.107,338 $252,311 16,359,649

1945 11,910,190 6,842,133 18,752,323

1944 13,362,393 8 540.695 21,903,088

1945 13,087 887 9 236,272 2»? 394.159

Average

Pereentage

Average

12,877,712

H4.66

7.033 948

3.4%

19,911,659

1H0G

*The Plantation also has a hydro-clectrie plant,

known as the Kemoo Plant, located on the Upper

side of the Plantation. This plant has not) been

operating sinee 1943 and is completely shut down

for an indefinite period,

vs. Ciraco Mane ja, et al. 9]

a breakdown of this power generated and [91] pur-

chased :

The power generated and purchased by the Plan-

tation is distributed to the mill, field irrigation

pumps, repair shops and related buildings, domestic

water pumps, plantation houses and services and

to several small non-plantation users living in the

plantation community who, because of their loca-

tion, cannot be conveniently served from the present

transmission lines of the Hawaiian Electrie Com-

pany. The electric transmisison lines representing

the distribution system of both the Plantation and

the Hawaiian Electric are shown on the map at-

tached hereto as Exhibit **E."’

Mor the years 1941-1945, inclusive, the use of the

electric energy distributed by the Plantation in the

terms of percentages was divided as follows:

For mill, shops and related buildings... 36.3%

For plantation irrigation pumps... ATAG

For plantation domestie water pumps... ... BIGF

For sundry use........... F Snead es

The power distributed for sundry use includes

power distributed to plantation houses for lighting,

electric ranges, water heaters and other electrical

appliances; to streetlighting, club houses, gvmnasi-

ums, playgrounds, bath houses, plantation store and

branches, and a hospital; and to several not-plan-

tation retail stores and service estavlishments,

churches and houses all situated in the general plan-

lation community. The total amount of power used

OY all non-plantation persons was less than %

or the total power distributed by the Plantation

for the years 1941-1945, inclusive. The various per-

92 Waiaiua Agricultural Co., ete.

centages of use set forth for such years are sub-

stantially true today [92] except that the distribu.

tion to non-plantation users in the community is

now approximately 1% of 1% of the total power

distributed by the Plantation because these users

are constantly being absorbed by the Hawaiian

Electric as it extends its transmission lines. None

of the electric power distributed to non-plantation

users by the Plantation is used for or in connection

with the production of goods for interstate com-

merce, nor is it used to operate any instrumentality

of interstate commerce nor is it transmitted into

interstate commerce.

As indicated before, for the purpose of obiaining

additional power from the Hawaiian Electric Com-

pany, the Plantation system is tied Into the former

system throughout the year. As a consequence, on

rare and infrequent occasions the Plantation will

feed back power into the Hawaiian Electric Com

pany lines. The feed back into the Hawaiian Klee-

tric lines oceurs when the electrical load of the

Plantation is small and the steam is great. Under

these conditions the Plantation may generate more

power than it uses. This situation may occur on

week ends when the mill is closed down and the

mill requirements are slight or completely absent

or it may occur at periods when some tield irriga-

tion pumps have shut down, Power is net fed back

to the Hawaiian Electrie lines for the purpose of

selling power but only beeause it is a leeessary,

eonvenient and economical method of disposing of

the excess power. To avoid feeding back power in

the situation described would be costly and imprae-

vs. Crraco Mane ja, et al. 93

tieal as it would either require a complete resetting

of the plantation generators to produce less power

(which would necessitate [93] the closing down of

the power plant) or it would require expensive ma-

chinery which would synchronize the generation re

quirements with the required power load othe

Plantation.

The times of the feed back are infrequent, irre.

lar and unpredictable and the Hawaiian bleetric

has no need for such power in this area.

A chart showing the total amount of power pur-

chased from Hawatian Electric and the total eredit

allowance for “eed back in dellar volume is set forth

for the vears 194i to August SI. 1946. inedusive.

Total Dollar Volume Total Dollar (red

of Power Purchased Allowanees tor Feed

Year from HR. Back from HEE to

194] SHI ILO A ¥ G2 12

144 5D 41 1 Jats

145 4225 23068

144 2.12941 LO St

145 | eee Jas

MWH6 Aug 31 WG16551 ee me

He 27009 SHC Tt

Operation of the mill power plant requires one

operator and one auxiliary tender per shift. Orne

mill maintenance electrician is needed for the shitt

from 2:00 pam. to 10:00 pam. and one for the shift

from 10:00 p.m. te 6:00 aim. Eleetricians from the

electric shop also are on eall for necessary repairs.

During the off season the turbines, steam engines,

venerators, motors and auxiliary equipment in the

nil are overhauled and reconditioned and during

94 Waialua Agricultural Co., ete.

such peried the Plantation generates no electric

power but purchases all of the power which it

needs from the Hawaiian rlectrie Company. [94]

26.

Service Sb .ps

Roth tield and mill operations necessitat. the

equipping and maintaining of complete service

shops fer prompt minor repairs and emergency

work and major overhaul. Machinery breakdowns

in the mill may result in a shutdown of the entire

mill which, in turn, necessitates a discontinuance of

harvesting and transportation operations until mill

repairs are complete, Breakdown of harvesting ma-

chinery or of cane transpertation faciities in turn

may result ina shutdown of the entire mill. Repair

shops are located in an area extending net more

than 30 feet from: the mall burlding. Phe location of

the various service shops is shown on the map at

tached as Exhibit “FF which is attached hereto

and made a part hereef. A list of the shops and the

work which is performed by their personnel is as

follows :

(a) Machine Shop. This shop is staffed by

eight employees working: under the supervision of

ao ormeehine shop foreman. Practically all the ma-

chining work of the Plantation, except heavy work

required by the tall, railroad and shops, is done in

the machine shop. The erinding of crankshafts for

ears, trucks, tractors and cranes and the machining

of emergency parts for such equipment is also per-

formed here, as well as machine work on irrigation

vs. Ciraco Mane ja, et al. 95

pumps. Major locomotive repairs are made by ma-

chine shop personnel working with a heavy crane

in the welding shop.

Approximately 46 per cent of all machine shop

werk is for the mill. Fifty per cent of the annual

machine shop work is for other service departments,

including repairs to steam engine driven irrigation

Pullipes. During the off season, [95] mintil work done

by the machine shop accounts for 85 to 90 per cent

of the total man-hours’ work performed. Work in

this shop is fairly uniform throughout the year with

peaks in ease of emergency mill repairs and during

the mall off season. Locomotive overhaul is carried

out to a limited extent during the grinding season

to relieve machine shop off season work. Steam en-

vine driven water pumps are scheduled for overhaul

after the mall overhaul has been completed and

alter grinding operations are resumed.

A large portion of the work done by the machine

Shop personnel is performed within the shop, utiliz-

ig shop tools. Shop personnel are, however, from

time to time ealled into the mill, on instructions

‘rom the cane processing superintendent, for re-

pairs, regrooving of mill rolls and sueh other work

as cannot be expeditiously handled by mill workers.

The tools ef the machine shop include lathes. hy

draulic press, drill press, planer. boring machine

and crankshaft erinder.

(h) Welding Shop. Five employees work un-

der the welding shop, foreman. Approximately 46

per cent of welding shop work is for the mill. Dur-

Lig the on Season, welding shop work for the mill

96 Wealua Agricultural Co., ete.

represents approximately 90 per eent or more of

the tetal man-hours. Most of the welding repairs

to mill equipment are made in the shop, although

personnel are dispatched to the point of breakdown

on instructions received from the cane processing

superintendent. Steel cane car repairs are made

alongside the shop building by the shop personnel.

The welding shop employees also operate pipe rolls

located in the pipe rolling shed. The pipe which is

rolled is generally irrigation pipe, 18” in diameter

or larger. [96] Welding of this pipe is performed

by the shop welders. In this work the welding shop

employees are assisted by employees from the black-

smith or cane loading machine repair shop.

Welding shop cauipment consists of heavy pipe

rolls, several sets of acetylene and cutting outfits,

acetylene generators, two stationary and portable

welding generators.

(ce) Blacksmith Shop. The blacksmith shop is

located adjacent to the mill building. Personnel

consists of two blacksmiths and two helpers under

the supervision of the Cane Loading Machine Re-

pair Shop foreman. Approximateiy two days each

week are spent by two blacksmiths and two helpers

on mill work, consisting principally of constructing

and reconditioning of eane carrier leveling and

preparation knives. Cane car repair work, such as

straightening of bars and channels, repair of trac-

tors and caneloaders and field implement work oc-

cupy the great percentage of the man-hours in the

shop. Work of this shop is therefore uniform

throughout the year.

vs. Ciraco Mane ja, et al. 97

Equipment of this shop includes two forges, an

electric operated hammer and a variety of small

tools,

(dj Tinsmith Shop. Personnel consists of a tin-

smith journeyman and two employees. In this shop

mill repair work is negligible, although light sheet

steel work, including maintenance and repair of

roof gutters and down pipes, is performed by the

shop personnel. Repairs of auto, truek. tractor and

caneloader radiators are performed by the shop

personnel. Main work of the shop is the making

and reconditioning of tin irrigation scoops. These

Scoops are used in quantity in the field for the pur-

pose of deflecting water from concrete irrigation

Humes to field irrigation lines, [97]

(e) Cane Loading Machine Repair Shops Per-

sonnel consists of twelve employees under the super-

vision of a foreman. This shop performs all major

repairs and overhaul of caneloaders. grabs and mis-

cellancous field equipment. Men from this shop are

occasionally called upon to assist in the emergency

mill repairs. They also go into the field to make

repairs or caneloading machines during the course

of harvesting operations. An important function of

this shop is the construction of auxiliary field equip-

ment, such as subsoilers used in plowing, cane line

reshapers used to maintain irrigation water lines in

the field, and portable track line leveler attachments

used in leveling the lines for laving portable tracks,

On Exhibit “HH some of the work of this shop

Is carried under the title ‘* Mechanical Harvesting

Department.’

98 Waialua Agricultural Co., ete.

Repairs on such auxiliary field equipment are also

made in this shop with the assistance of tractor

repair shop personnel,

During the off season at least eight of the nine

caneloading machines are completely dismantled

and reconditioned. The ninth machine is recondi

tioned after harvesting operations have been re-

sumed. During the off season following the coniple-

tion of harvesting, ten to twelve caneloading ma-

chine operators are brought inte the shop to supple-

ment the regular crew and assist in overhaul. Five

‘ane grabs are overhauled and reconditioned during

the off season and all other cane grabs are repaired.

Three new cane grabs are usually built during the

harvesting season.

Shop equipment includes four portable welding

generators and three portable welding generators

mounted on trucks for field repairs. A hydraulic

press, overhead crane, motor driven grinders and a

variety of small tools complete the shop [98] equip-

ment.

Four welders in this shop take care of welding

repairs in the field and repairs to and building of

new field equipment.

(f) Tractor Repair Shop. Employees in this

shop number seven, supplemented during the off

season by twelve to fifteen tractor operators brought

into the shop from the fields to assist in repairs.

All tractors used in the harvesting field are over

hauled in this shop during the off season. Tractors

used for towing cane line reshapers are also over-

hauled during the off season. Other tractors which

vs. Ciraco Mane ja, et al. 99

cannot be overhauled during the period of off sea-

son are scheduled for overhaul at a later date. This

may mean that six or seven of a total of forty-eight

tractors are left) for operating season overhaul.

Tractor engines are overhauled at regular periods.

Shop men may be dispatched for repairs of trac.

tors in the fields. As indicated above under («)

personnel from this shop also assist in the repair

of field implements in the caneloading machine re-

pair shop.

(g) Garage. Combined garage and field sery-

ice personnel numbers 24. The primary work of the

garage is the maintenance and repair of 98 planta-

tion vehicles divided as follows: 18 passenger vebé-

cles; 48 pickup. trucks up to one ton; 27 heavy

trucks from 114 to 7 tons: one motoreycle; 2 fire

trucks and 2 panel trucks. These vehicles are as-

signed to the various operations as follows:

Passenger Piekup Heavy Motor- Fire

Vehicles Trucks Trucks eveles Trucks Panel

SANE 5 39 20

| ee aR aN 2 3 6 ]

_ ae 1

a I

Re 2

Administration... 7

Fire Trucks 2

Motor Pool 2 6 1

EN 18 4s 2d 1 2 2

(irand Total 98

Overhaul of ears and trucks is scheduled ‘through-

out the year with the exception of pickup trucks

used by the harvesting men which are overhauled

during the off season. Truck drivers are not used

to assist in truck or auto repairs since there js

generally a spare truck to drive when others are

100 Waalua Agricultural Co., ete.

being repaired. Shop equipment consists of 4 over

head cranes, a hoist, valve grinding machine, brake

drum lathe, boring machine, tire tools and a variety

of special tools.

Complete servicing equipment with necessary per

sonnel is also maintained. Seven full-time and one

part-time employees are employed to lubricate and

wash plantation automobile vehicies at stated inter

vals. One employee dispenses gasoline and oil at

the vard service station. Six employees are em-

ployed as helpers to garage mechanics when there

is no service work.

Field service covers the daily lubrication of all

equipment and replenishing of fuel tanks. ‘Tractors,

cancloading machines, portable air compressor, die-

sel and gas locomotives and all field equipment are

serviced daily by a total of 6 men. Two completely

equipped service trucks manned by two men each

service all field equipment except that in the har-

vestin » fields. In the latter case, a two-wheel trailer,

tractor drawn, is kept in each of the two harvesting

fields. Oil, gasoline, diesel oil, greases and water

are carried on the trailer together with power oper-

ated grease guns. One man assigned to each trailer

services the eranes and tractors in the harvesting

fields. In this way service work can be done during

the lunch hour and slack periods without serious

interference to harvesting operations, The field men

in turn are given an opportunity to learn the opera-

tion [100] of loading cranes during their spare time

with an opportunity when a vacancy occurs of mov-

ing up to a crane operator's Job.

Rel

vs. Ciraco Mane ja, et al, 101}

(h) Electrie Shop. A total of 15 emiplovees

Works in this shop. Three of these emplovees are

mil electricians who work two weeks in the mill

and one week in the shop. This shop is respoh sible

for the maintenance of electric purmips and = trans-

mission lines, domestie wiring repairs, including

Wiring of houses, and the building of new electrical

appliances, A small amount of work is done on elec-

tricai machines located in the other shops. In addi-

tion to mill repair work done by the employees

assigned as electricians to the mill. the electric shop

personnel may assist them in case of Inajor clectri-

eal repairs required. Approximately 50 per cent of

the work in this shop is for the mill. During the

off season, approximately 70 per cent of all work

is for the mill.

(1) Carpenter Shop. Employees in this shop

number 25 carpenters under two supervisors. The

‘arpenters perform all carpenter work on the Plan-

tation which includes the construction of mill seaf-

foldings, construction and maintenance of railroad

trestles and wooden gates for flumes, and the con-

struction and maintenance of cane cars. | n addi-

tion, they perform necessary maintenance work on

plantation buildings and houses. The ‘arpenters

also install and maintain steel and concrete pipe-

lines and siphons. Miscellaneous construction, such

as construction of tool lockers, scrapers and strain-

ers, is performed in this shop. Field work. includ-

ing work on the flumes, railroad trestles, siphons,

pipelines, ete., accounts for about 25 per cent of the

Work of the employees. Mill scaffolding and mii]

102 Waialua Agricultural Co., ete.

building repairs, construction of tool [101] lockers,

scrapers and strainers account for about 10) per

eent. Maintenance and repairs of plantation build-

ings and housing account for about 45 per cent.

Approximately twenty per cent of the work per-

formed by these employees is devoted to the con-

struction and repair of cane cars. During the off

season, the work of the employees in this shop is

similar to that in the grinding season. Additional!

men, averaging from 10 to 15, may be brought in

from the fields to assist in cane car everhauling and

general carpentry work during the off season.

(j) Paint Shop. This shop employs five painters

under one supervisor. They perform all painting

work on tne plantation buildings including housing

and also occasionally paint siphons and railroad

trestles. As a general rule, they do not paint for

the mill, this work being done by mill employees.

Almost the entire time of the paint shop crew

is devoted to painting of plantation buildings and

housing throughout the year. During the off sea-

son, an average of two additional employees brought

in from the fields may assist in the work of this

shop.

(k) Plumbing Shop. This shop employs. six

plumbers working under one supervisor. They per-

form all plumbing work on the Plantation, includ-

ing the construction and maintenance of sewer and

water systems and the plumbing for buildings and

housing. Approximately 10 per cent of the time is

devoted to mill plumbing work, 15 per cent to field

work and the remainder to housing. Assignments

rs. Ciraco Mane ja, et al. 103

vary little throughout the year. During the off sea-

son an average of two field employees may be as-

signed to the plumbing shop as helpers, [102]

(1) Roundhouse. Two employees work in this

shop servicing, cleaning and firine the plantation

locomotives, Additiona| emiplovees are vecasionally

assigned to this shop for miner locomotive repairs,

It is located near thi machine shop.

27.

Laboratory Tests and Sampling

Various chemical tests are nade by the laboratory

personnel in the course of all field and mill opera-

tions. This work is performed under the super-

Vision of a chief chemist With the assistance of thip-

teen chemists, testers and samplers. By careful

analyses of various kinds performed relative to the

cane and materials in the course of growing, culti-

vating and harvesting and extraction of the sugar

juices, all operations are controlled pursuant to

scientific methods.

Determinations of the cane fiber in each field. or

Variety of cane, are made during each shift. Fig-

ures obtained are used in calculating bagasse

Weights, field distribution and extraction percent-

ages,

Cane leaf analyses is made from samples of cane

tops brought in each day and analyzed for green

Weight mixture, total sugars, nitrogen, potash and

phosphate,

Tests are made each day to determine field trash

content in harvesting brought to the mill, One ear

104 Waialua Agricultural Co., ete.

is selected each day for each field being harvested,

The car is tagged in the field, placed on side track

and then delivered to the mill area. The car is then

weighed and the clean sound cane is piled in previ

ously weighed empty cars. Then the car of elean

cane and the ear from which the dirty cane was

removed are weighed and the percentage of trash

obtained. Percentage of trash obtained is used in

obtaining the net cane from each [103] field and

also the gross cane ground. A cheek upon cane

field vields is maintained in this manner.

Continuous samples are taken from the feed roller

of the first mill each hour and also at each change

of field harvesting. Records of ratios of cane to

available sugar are obtained from these analyses.

Juices extracted by the milling process and en-

tering the boiling house are sampled every hour.

Samples obtained are the main basis for determin-

ing the sugar in the cane extracted by the milling

process and entering the boiling house.

The juice extracted by the discharge roll of the

last mill is used in caleulating the weight of the

hagasse.

One sample is taken every three hours from the

clarified juice leaving the clarifier. The difference

in purity between this sample and the mixed juice

samples will show the relative amount of solids be-

ing removed by the lime and heat treatment of the

juice.

The purity of the syrup leaving the evaporator

is cheeked with the juice leaving clarifier.

Samples of bagasse are taken every two hours

vs. Ciraco Mane ja, et al. 105

aud ash determinations are alee thade on two sam-

ples prer diy to deterinine the Hdluence of the

different fields on the fire rooney,

Mixtures of Sugar and molasses discharged by the

sdenumM Pans are tested from each full discharge

from the pans. Samples are made daily of low

grade sugar, commercial ray sugar and waste mo-

lasses. The residue removed from the juice during

the clarification proeess is made onee during each

shift. The purpose of this analysis is to determine

the amount of sugar lost in the filter cake,

Test is also made of the mill boiler water. loco-

motive boiler water, steam pumps boiler water and

pump water. Pump [104] water from electric

pumps and well water are sampled onee each

month. Wash water from the Cleaning plant and

condenser water are also analyzed each shift.

28,

Concrete Products Plant

The Plantation operates its own concrete produets

plant which is loeated on Plantation lands adjacent

to the plantation buildings and yard area. At the

present time, six men are at work in this plant

although the number varies from 4 to 10 men. Work

ordinarily is performed on a single shift basis, but

if extra men are working, two shifts may be main-

tained,

This plant. is engaged primarily in producing

conerete irrigation ilimes and water supply pipe.

It also makes some blocks. footings, sidewalk slabs

and other various incidental concrete products re-

106 Waialua Agricultural Co.,, cte.

quired by the Plantation. Crushed rock used in

the manufacturing process is purchased locally.

while 80 to 90 per cent of all cement used is ob-

tained from the mainland. The work consists of

setting up forms, mixing and pouring concrete,

removing che previous day's products and arrang

ing them in storage. Cement used is stored in ears

which are set on the siding near the plant, or the

cement is stored in the cement shed as part of the

inventory of general supplies warehousing. In the

iatter case, unloading of cement is done by the

warehouse personnel. Various activities requiring

the flumes, pipe and other products receive them

direct from the storage aren where the products

are stored.

The operations do not have any off season, Dur-

ing the off season, however, additional personne!

may be brought in from the fields. In 1946, the

plant produced approximately 46,000 — concrete

pieces, including flume sections, pipe and other

products. [105]

29.

Storage of Plantation Supplies

Materials and supplies purchased for plantation

operations are warehoused or stored in several

separate buildings located in the plantation build-

ings and yard area. Value of supplies on hand

averages $500,000. ‘The total value of goods pro-

eured during a year including stock and special

order materials averages slightly over $1,000,000.

Most of the materials received are shipped = ty

vs. Ciraco Mane ja, et al. 107

the Plantation from Honolulu on the OL Ro & IT.

Purchases may be either local or by order and

direct shipment frem continental United States.

Freight received is placed in the proper warehouses

by the warehousing personnel. In almost all eases

railroad sidings permit placement of the O. R. & I.

ears next to the warehouse receiving the materials.

The warehousing personnel is not responsible for,

hor does it engage in, delivering materials to the

various operations or shops.

The principal buildings in which the supplies

and materials of the Plantation are stored are the

general supplies warehouse 2nd the heavy supplies

warehouse. They house electrical goods, building

hardware, paints, window screening, tractor and

eaneloading repair parts, copper tubing, pipe stock,

metal shapes stock, galvanized sheeting, steel sheets,

and many other items.

The oil storage warehouse houses lubricants and

a limited amount of paint.

Gasoline, fuel oil, diesel oil and kerosene are dis-

charged directly from the O. R. & L. tank cars into

storage tanks.

Most of the automotive parts and tractor, ecane-

loading and miscellaneous parts are stored in the

garage. [106]

Cement

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Prologue — Maneja v. Waialua Agricultural Co. · 349 U.S. 254 | Frix