Jim Albertini’s 11 comments sent on the Pohakuloa Environmental Assessment (EA)

Attn: Lisa Graham
usaghi.pao.comrel@us.army.mil
US Army EA Public Works Environmental Division

Pohakuloa EA point #11 fires, endangered species, wasteland

Our organization calls for a Full Environmental Impact Statement (EIS) on the entire actions at PTA not simply the proposed $210 million building project at PTA.  
There are lots of things that need more consideration:

Below are just 2 of many reports of fires on PTA:

Flares released by the UH-1Y and AH-1Z helicopters apparently ignited grass within an environmentally protected area…” Fire sparked during RIMPAC exercises consumes 2,000 acres, West Hawai’i Today, July 19, 2018, http://www.westhawaiitoday.com/2018/07/19/hawaii-news/fire-sparked-during-rimpac-exercises-consumes-2000-acres/, accessed 8-5-18

A range fire that began March 24 within the Pohakuloa Training Area (PTA) on Hawaii island during a combined armed live-fire exercise is contained but still smoldering near Range 3 in the PTA impact area…” Pohakuloa fire not a threat to community, PTA officials say, Hawai’i Independent, April 1, 2016, http://hawaiiindependent.net/story/pohakuloa-fire-not-a-threat-to-community-pta-officials-say, accessed 8-5-18

What was blowing in the wind from these fires?  As far as I am aware –NO air monitoring has ever been done during PTA fires to see what is blowing in the smoke and the wind.  Military Toxins could have very easily contaminated the cantonment area.  The maps of all fires on PTA should be included in a full EIS, including the most recent fire of only a few weeks ago that burned “an environmentally protected area.”  The military sure didn’t do a very good job of protecting the area.  In fact military flares caused the fire that burned the area.   Why was the area “environmentally protected?”  What species were in the area that the military burned?  I propose that the $210 million proposed for the demolition and rebuilding of the PTA cantonment area be used as a down payment for the many billions (likely tens of billions) of dollars that will be needed to clean up PTA of it’s toxic stew.  One example: The former 120,000 acre Waikoloa live-fire area which was used for only 2 years during WWII now is estimated to cost $760 million to clean up.  Only $5-10/yr is being appropriated.  At the present rate that will take 70-150 years to complete and the true cost is likely to mushroom.  Pohakuloa is 133,000-acres and has been used for 75 years of bombing and is contaminated with Radioactive Depleted Uranium oxide particles and a host of other chemicals. 

We don’t need a new cantonment area to protect us.  We as residents of the Big island are like the species in the “environmentally protected area” recently burned.  We need a military EXIT plan, and money to assure clean up.  $450 million was spent to clean up Kahoolawe, and the island and surrounding waters are still a mess.  Just recently Congress passed a $717 billion military budget, but how much of that money is for clean up?  There is always plenty of money for the military to makes mess after mess, but never enough money for clean up. There are at least 57 present or former military sites on this island in need of clean up.  When will these sites be cleaned up.  Do this clean up before you even consider new building for further destruction.

The US military is the greatest polluter on the planet and this madness needs to stop now.  Do a complete EIS on Pohakuloa and include decommissioning and clean up costs.

-- 
Jim Albertini

Attn: Lisa Graham
usaghi.pao.comrel@us.army.mil
US Army EA Public Works Environmental Division
Pohakuloa EA point #10 Traffic

Our organization calls for a Full Environmental Impact Statement (EIS) on the entire actions at PTA not simply the proposed $210 million building project at PTA.  
There are lots of things that need more consideration: EA point #10 traffic
On page 4-11 of the PTA EA it states that traffic is predicted to increase nearly 5 times present levels over the next 20 years.  The cumulative polluting impacts of PTA on people who stop at Mauna Kea park, potential nearby Hawaiian Homes development plans, and the potential of spreading PTA contamination via vehicle traffic as well as the winds to all parts of the island needs to be addressed in a full EIS.
-- 
Jim Albertini

 
Attn: Lisa Graham
usaghi.pao.comrel@us.army.mil
US Army EA Public Works Environmental Division

Pohakuloa EA point #9 Cumulative Impacts

Our organization calls for a Full Environmental Impact Statement (EIS) on the entire actions at PTA not simply the proposed $210 million building project at PTA.  
There are lots of things that need more consideration: EA point #9

It is not disclosed in the present EA how many live-rounds and what kinds are fired annually at PTA.  Also the cumulative total of live rounds and tonage of 
munitions fired at PTA.  And the impact should go beyond live rounds, since technically the Radiation Davy Crockett Depleted uranium rounds were not 
live-fire but designated as "spotting rounds." As part of the Stryker EIS done more than 10 years ago, it was stated that 14.8 million live rounds were 
fired annually at PTA.  A list and quantity of all live and non-live rounds fired should be part of the cumulative impacts becasue such toxins, though not 
actually fired on the proposed site of this EA, could possibly impact the site via wind drift, water, etc.

What kind of weapons have been dropped on PTA by B-52, B-1 and B-2 bombers that have flown non stop from Missouri, Louissana and Guam?  Are these dummy 
nuclear weapons and what is their make up?  Do they or other weapons, besides Davy Crockett spotting rounds, contain DU for ballast?

Nothing listed in the actions considered in the cumulative impacts analysis on page 4-2  gives a comprehensive picture of the quantity and kinds of weapons 
fired on PTA over 75 years.
-- 
Jim Albertini


Attn: Lisa Graham
usaghi.pao.comrel@us.army.mil
US Army EA Public Works Environmental Division
Pohakuloa EA point #8 Ground Water contamination at PTA

Our organization calls for a Full Environmental Impact Statement (EIS) on the proposed $210 million building project at PTA.  
There are lots of things that need more consideration: EA point #8 ground water contamination at PTA
It is a well known fact that the US military is the greatest single polluter on the planet.  In section 3.8 of the EA (page 3-22) it is noted that the University of Hawaii in partnership with the Army developed a successful test water well and encountered a an aquifer at 4,600 fee elevation in the PTA cantonment area, the site of the proposed building project.  Additional wells have also been drilled.  What contaminants were found in the water found, especially the water at shallow depths within the cantonment area?  I would suspect that the known polluter of such water is none other than PTA and its toxic stew that it's been making for 75 years.
-- 
Jim Albertini

Attn: Lisa Graham
usaghi.pao.comrel@us.army.mil
US Army EA Public Works Environmental Division
Pohakuloa EA point #7 toxins

Our organization calls for a Full Environmental Impact Statement (EIS) on the proposed $210 million building project at PTA.  
There are lots of things that need more consideration: EA point #7

On pages xiv -xvi where abbreviations and Acronyms are listed, the only specific toxins listed are LBP  for Lead Based Paint and ACM for Asbestos containing material.
Where are all the other abbreviations and acronyms for toxic substances used on Pohakuloa that could be blowing all over the base and off base.  Things like DUO for 
Depleted uranium oxide particles created when DU metal is burned after being hit with high explosives.  What about all the other chemicals in munitions?  Where are there 
abbreviations and acronyms?  Remember your words-- "WARNING: ALL OF PTA IS CONSIDERED A DUD HAZARD AREA." 
-- 
Jim Albertini

Attn: Lisa Graham
usaghi.pao.comrel@us.army.mil
US Army EA Public Works Environmental Division

Pohakuloa EA point #6 "All of PTA is a Dud Hazard Area"

Our organization calls for a Full Environmental Impact Statement (EIS) on the proposed $210 million building project at PTA.  
There are lots of things that need more consideration:

Our organization believes that PTA is a toxic waste dump after 75 years of bombing and live-fire, with a toxic stew of chemicals used, 
including Depleted Uranium (DU) radiation.  Given this reality it should be assumed there may likely be extensive contamination in the proposed
demolition and construction area.  Afterall, while PTA has a designated "Impact Area" it's maps of PTA say "WARNING: ALL OF PTA IS CONSIDERED A DUD HAZARD AREA."
In simple terms, whatever was used anywhere on the base should be considered in the proposed construction area.  I would go much farther.  
It is likely off the base as well, like Bob Dylan says "blowing in the wind"... at Mauna Kea park in the childrens playground, at the nearby Girl Scout Camp, into 
and on all the vehicles that use the Daniel K. Inouye (Saddle Road) highway and downwind --noth, south, east and west, depending on the wind conditions of the day.

The statement on page vii of the executive summary which says "Employment of personnel qualified to identify and handle hazardous materials if unexpectedly
encountered" shows the disconnect from reality of the approach to this demolition and construction project.  It is NOT "unexpectedly encountered."  It is 
likely encountered.  And we want a more comprehensive look at the matter through a full EIS.
-- 
Jim Albertini

Attn: Lisa Graham
usaghi.pao.comrel@us.army.mil
US Army EA Public Works Environmental Division


Pohakuloa EA point #5 Independent analysis prior to work

Our organization calls for a Full Environmental Impact Statement (EIS) on the proposed $210 million building project at PTA.  
There are lots of things that need more consideration:

     We call for a comprehensive, independent assessment of contaminants in the proposed construction area, NOT DURING CONSTRUCTION 
(as called for in the EA summary environmental analysis section) 
but prior to construction as part of an EIS.  PTA has been subjected to 75 years of bombing and various live-fire by a wide range of weapons,
including radioactive Depleted Uranium (DU), chemical and biological weapons, etc. etc.  It is highly likely that many of these contaminants 
are in the proposed area for demolition and construction.  We want a complete independent assessment prior (not during) demolition that is 
transparent and assures the confidence of the community.  Such an independent assessment should included community oversight representatives. 
-- 
Jim Albertini

Attn: Lisa Graham
usaghi.pao.comrel@us.army.mil
US Army EA Public Works Environmental Division

Pohakuloa EA point #4 Hawaiian Kingdom land not US military land

Our organization calls for a Full Environmental Impact Statement (EIS) on the proposed $210 million building project at PTA.  
There are lots of things that need more consideration:
  
    On the opening page of the EA Draft finding of No significant impact, it is stated at the bottom of the page that "The preferred alternative 
would be located entirely within federally-owned land..."
We challenge that statement.  Show us the title.

    More information in recent years has become available about the US illegal overthrow and continuing illegal occupation of the Hawaiian Kingdom in 1893. 
The Reciprocity treaty of 1875 and amendments to folow in the Bayonet Constitution of 1887 were illegal. No treaty of Annexation of Hawaii exists. 
Therefore, all Presidential and Governor Executive Orders, leases, alledged purchases of land by the U.S. violate article 1, section 8, clause 17 of 
the U.S. constitution.  
-- 
Jim Albertini



Attn: Lisa Graham usaghi.pao.comrel@us.army.mil 

US Army EA Public Works Environmental Division 
Pohakuloa EA point #3 Bradshaw air field 

Our organization calls for a Full Environmental Impact
Statement (EIS) on the proposed $210 million building 
project at PTA. There are lots of things that need more
 consideration: 1. https://mapcarta.com/24060168 shows
 a good map of the proximity of the Bradshaw air field
 at Pohakuloa to the site of the proposed new building
 project. This map should be included in the EA and EIS
. The airfield is in direct line with the housing 
project. The predominant wind is from the east and 
often quite strong which would require aircraft to 
take off toward the east, not the west as falsely 
indicated in your EA. A permanent waiver granted by 
the U.S. Army Aeronautical Services Agency dated 
October 12,2017, so land use incompatibility is no 
longer a factor is hereby challenged on the basis 
of putting troops lives in unnecessary danger. 
EA pp 2-16 to 2-17. Accident Potential Zone (APZ) 

Jim Albertini

Lisa Graham
NEPA Program Manager
U.S. Army Garrison Hawaii
Dear Ms. Graham:

Your email response is again insulting.   
The article in the July 13, 2018 Hawaii Tribune- Herald
, page A-8 did NOT list an Army website link for the EA
 on Pohakuloa.  The article listed this: "The draft EA 
is available on line at http://health.hawaii.gov/oeqc."
  I was not able to find the Pohakuloa EA on that site.
  This is the second time in one year you have insulted
 our community.  On the cultural EA regarding Pohakuloa
 last year, our organization and others requested that
 the Army hold public hearings since Hawaii is more of
 an oral than written culture, and the EA was then 
about cultural impacts.  You and the Army refused to do
 so.  We held community public hearings in Hilo and 
Kona and sent you DVDs of the hearings for the record 
which you refused to make part of the record.  You 
told us to submit a transcript of the DVDs.  How 
insulting can you get?  You and the Army keep 
piecemealing EAs on Pohakuloa saying "NO SIGNIFICANT 
IMPACT.:  Shame on you and your arrogant attitude. a 
FULL COMPREHENSIVE ENVIRONMENTAL IMPACT STATEMENT NEEDS
 TO BE COMPLETED ON POHAKULOA AND IT SHOULD BE DONE 
NOW!.  Meanwhile we again request at least a 2 week 
extension of the public comment period from Aug. 7 to 
Aug. 21 and immediate republication of correct listings
 of how the EA can be read on line published in both 
the West Hawaii Today and the Hawaii Tribune-Herald.  

Jim Albertini

CLASSIFICATION: UNCLASSIFIED

Aloha Mr. Albertini,

This email confirms receipt of your comments on the proposed Cantonment 
Facilities Improvement Program at Pohakuloa Training Area. We greatly 
appreciate you taking time to review the documents and provide your feedback.

The Army's official Notice of Availability of the Environmental Assessment and 
Draft Finding of No Significant Impact was published in the Hawaii 
Tribune-Herald and West Hawaii Today newspapers on July 8, 2018, and included 
the Army's website link for the document, as well as our contact email 
address. In addition the Army provided hard copies of the documents to the 
Hilo, Kailua-Kona, and Waimea public libraries; and issued additional notices 
via an Army press release and the State of Hawaii's Office of Environmental 
Quality Control.  As we have followed guidance in 32CFR651 and feel we have 
provided appropriate time for the public to submit written comment, we are 
declining your request for a two-week extension to the public comment period.

Mahalo,

Lisa Graham
NEPA Program Manager
U.S. Army Garrison Hawaii

-----Original Message-----
From: Jim Albertini [mailto:ja@malu-aina.org]
Sent: Tuesday, July 31, 2018 12:47 PM
To: USARMY Wheeler AAF ID-Pacific List Community Relations 
<usarmy.wheeler.id-pacific.list.community-relations@mail.mil>
Cc: Geoff Shaw <shaw.geoff5@gmail.com>; Danny Li <dlimay7@flex.com>; Donna 
Grabow <meridianwoman@yahoo.com>; Ron Fujiyoshi <ronsan2224@aol.com>; Isaac 
Harp <paka@sandwichisles.net>; Ku Ching <KahiwaL@cs.com>; Mike Reimer 
<geomike5@att.net>; Lorrin Pang <panghi71@gmail.com>; Congresswoman Tulsi 
Gabbard <congresswoman.gabbard@capitolenews.com>; Richard Onishi 
<reponishi@capitol.hawaii.gov>; Russell Ruderman 
<senruderman@capitol.hawaii.gov>; Sen Josh Green 
<sengreen@capitol.hawaii.gov>; Brian Schatz <info@brianschatz.com>
Subject: [Non-DoD Source] extension of comment period for EA on Pohakuloa $210 
construction project

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----

Attn: Lisa Graham
US Army EA Public Works Environmental Division

Our organization requests an extension of the comment period beyond Aug. 7, 
2018 for the EA concerning construction of new buildings at the Pohakuloa 
training Area (PTA). The original publication in the Hawaii tribune-herald on 
July 13, 2018 page A-8 listed a site to view the EA that was not accessible. 
As far as I know there has been no republication of a correct on line site for 
viewing the document.  I had to make numerous phone calls to get a correct 
link to access the site.
In addition an Army site link contains a WARNING to my web browser and others 
that the site is not secure and advises not to go forward.  This is not 
conducive and inviting for public input and should be corrected.

I would suggest at least a 2 week extension of the deadline for public 
comments and a republication in the Big island daily newspapers of an online 
site for accessing the EA if you really want public input.

Mahalo for your consideration.

Aloha,

--
Jim Albertini