September 7, 2004
Rodney Haraga, Director of Transportation
State Of Hawaii
Department of Transportation, Harbors Division
79 South Nimitz Highway
Honolulu, Hawaii 96813
SUBJECT: OFFICIAL COMMENTS ON DRAFT ENVIRONMENTAL ASSESSMENT
FOR KAHULUI COMMERCIAL HARBOR IMPROVEMENTS
Thank you for the opportunity to review and comment on the Draft Environmental Assessment for proposed Kahului Commercial Harbor Improvements. I have the following comments:
COMPLIANCE WITH ENVIRONMENTAL REVIEW
I believe the environmental review process for issuing the Draft EA, and particularly for preconsultation, was insufficient. According to state law, the agency preparing a Draft EA or EIS must consult with community groups and individuals early in the process:
"§11-200-09 (a) (1) Seek, at the earliest practicable time, the advice and input of the county agency responsible for implementing the county's general plan for each county in which the proposed action is to occur, and consult with other agencies having jurisdiction or expertise as well as those citizen groups and individuals which the proposing agency reasonably believes to be affected;"
Section 8.0 of the Draft EA lists the agencies and organizations contacted in pre-consultation. The list of private agencies contacted is primarily those with economic interests, while those agencies with environmental interests were overlooked. Maui Tomorrow, Sierra Club-Maui Group, Kahea, and Hui Alanui O Makena are respected organizations which work to implement responsible planning strategies, environmental and cultural protection, and to teach and promote sustainable growth policies. Certainly they should have been pre-consulted, or at a minimum, been mailed a copy of the DEA.
Likewise, these County agencies were overlooked: Mayor's Office (especially relevant with the Mayor's Cruise Ship Task Force having met twice a month since January, 2004); Maui County Department of Transportation (also involved in discussions regard-ing the super ferry); Maui Fire Department; Maui Police Department; and the Cultural Resources Commission.
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None of the following State, Federal, and local agencies was contacted regarding alien
pest species introduction, prevention and rapid response: State of Hawaii Department of Agriculture and Department of Health; United States Department of Agriculture, Department of Homeland Security, Environmental Protection Agency (Clean Water Act regulator for cruise ships), Coast Guard, and Department of the Interior (Haleakala National Park); Maui Invasive Species Committee MISC); East Maui Watershed Partnership; West Maui Mountain Watershed Partnership. Increased harbor traffic, including cruise ships and the super ferry, represent real threats to Hawaii's native eco-systems and endangered species, as well as to agricultural viability, through increased probabilities of introduction of alien pest species or diseases.
There is no indication that a public pre-consultation meeting was held, no list of public libraries where the Draft EA was distributed, no detailed design plans, and no disclosure of amount of government funds involved. Finally, there is no explanation of
why projects identified in the DOT 2025 Kahului Harbor Master plan are not related to projects proposed in this Draft EA, and should not, therefore, be recognized as segmentation of the environmental review process.
It is recommended that these numerous omissions be corrected in preparing a Draft Environmental Impact Statement, as it is likely that the proposed improvements will result in significant impacts, as will be discussed in the "Conclusions" section.
OVERVIEW: TRAFFIC; ALIEN SPECIES, ENVIRONMENTAL CONCERNS
The most glaring omission to this DEA is any inclusion of an independently prepared traffic analysis, such as a Traffic Impact Analysis Report. The projected impacts to Maui's roadway transportation system would be greatly impacted by daily visits by the super ferry and cruise ship three days each week.
Hawaii Superferry, Inc. is proposing to bring 345-foot vessels that can carry 900 passengers and up to 280 vehicles. There is virtually no discussion in the DEA of parking facility or security needs, or of the logistics of bringing this additional traffic into the heart of congested Kahului. The Wailuku-Kahului Community plan, signed into law in 2002, states, (Transportation, Objectives and Policies, page 35);
"8. The Department of Transportation should be strongly encouraged to mitigate its traffic impacts prior to or in conjunction with the Harbor expansion, including, but not limited to the following:
a. improve the intersections between Ka`ahumanu Avenue and Wharf Street and
Hobron Street
b. provide alternative and bypass routes for vehicular traffic, possibly including a
Direct route to Kahului Airport
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c. provide safe (possibly underpass) routes for pedestrian traffic
d. acquire pockets of land for more efficient facility location within Kahului Harbor, and
e. work with the community to plan a second commercial harbor."
There is no indication that any of these points are addressed in the Draft EA.
The DEA also fails to sufficiently address the increased probability of introduced alien pest species of animals, aquatic species, plants, insects, as well as plant and human pathogens. There is no discussion of increasing current mitigation efforts, which already are recognized as being insufficient. The super ferry puts Hawaii's environment and agricultural economy at great risk, with easy transport of insects (e.g. Nettle caterpillar,
glassy-winged sharpshooter, red imported fire ants); plant diseases (banana bunchy top virus, papaya ringspot virus); aquatic nuisance species (gracilaria salicornia algae, and
various species from hull fouling); and introduction of plants or seeds from the state Noxious Weed List.
Cruise ships heighten the possibility of introduction of human borne diseases, with 500,000 additional visitors expected each year via Norwegian Cruise Lines' projection of three ships by 2007. There is limited discussion of how the Harbor expansion plans would accommodate the 853-foot length of the cruise ships, or the 2000+ passengers three times each week, with another 700-800 crew members.
Additionally, interisland transport of passenger vehicles seems likely to instigate a variety of illegal activities, such as drug transporting, vehicle theft, and shipping of stolen goods. Yet, there appears to be no master plan for increasing security measures to match the huge influx of harbor activities.
The cruise ship industry has signed a Memorandum of Understanding (MOU) with the State of Hawaii (page 35). However, this MOU does not have the force and effect of law, and as such, fails to represent bona fide environmental protection from the large
discharges associated with the industry.
The super ferry is expected to travel at speeds up to 35 knots. Yet, mitigation for possible collisions with the endangered Humpback Whale are not discussed, nor are other noise pollution issues for this sensitive winter resident of our ocean waters.
CONCLUSION
The Draft Environmental Assessment for the Kahului Commercial Harbor Expansion
fails to meet basic criteria pursuant to HRS Chapter 343. Further, there is insufficient data and evidence to support the conclusion that the document should constitute a
Finding of No Significant Impact (FONSI). To the contrary, there are likely to be greatly
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significant impacts, including, but not limited to the following:
Significance Criteria
(2) Curtails the range of beneficial uses of the environment.
Harbor expansion as proposed would reduce the ability of recreational pursuits by canoe clubs and individuals who train in the harbor (page 43).
(3) Conflicts with the state's long-term environmental policies or goals...
Large consumption of water and energy resources would be necessary to fuel cruise ships and the super ferry. `Iao aquifer is a designated water management area, as it is being pumped beyond its sustainable yield. Large influx of traffic and tourists to the Kahului area do not appear to meet the "enhancement of quality of life" goal.
(5) Substantially affects public health.
There are strong possibilities of human borne diseases spreading more easily.
(6) Involves secondary impacts....
The ground transportation network would certainly be greatly impacted.
(8) Is individually limited but cumulatively has considerable effect upon the environment
or involves a commitment to larger actions.
There is no adequate explanation to support the statement that the "proposed action is not related to the future long-term actions represented in the 2025 Kahului Commercial Harbor Master Plan." One of the main reasons for environmental review is to adequately address such cumulative impacts, and not to separate component parts of a related long-range plan.
(9) Substantially affects a rare, threatened, or endangered species, or its habitat.
Failure to adequately address this criteria held the Kahului Airport expansion plan in litigation for years. Hawaii leads the nation in number of threatened and endangered endemic species. There must be a good faith effort made to mitigate introduction of new alien pest species into the State and particularly on Maui. Greatly increased harbor activities multiply the risks to our precious, unique native ecosystems, even those miles away from the harbor. Agency comments from the aforementioned groups are vital.
Any job worth doing is worth doing well, and this is no exception. Fast track efforts are often destined to be inferior, as we all are familiar with the adage that, "Haste makes
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waste." It is my hope that there will be diligent efforts to protect Maui's environment and quality of life through dedicated preparation of a Draft EIS. Without such efforts, Maui's
community is not adequately protected from the wide-ranging impacts likely to result from the proposed actions for Kahului Commercial Harbor Expansion.
Sincerely,
Robert W. Parsons
Executive Assistant for Environmental Concerns
Office of the Mayor
cc: Mayor Alan M. Arakawa
Kivette Caigoy, Dept. of Planning
Genevieve Salmonson, OEQC
Teya Penniman, MISC