Ms. Lisa Graham, NEPA Program Manager VIA E-MAIL
I include commentary on the EA for the Cantonment Facilities Improvement Program at Pohakuloa Training Area, dated July 2018. Thank you for the opportunity to be able to address issues in the EA.
The environmental assessment failed to address some critical issues related to the upgrading of PTA cantonment area. It is so short on detail that I would call it “EA lite.” There are numerous occasions where a statement is given along the lines of “construction best management practices” will be followed. Frankly, that is not sufficient as it tends to overlook and then fails to address critical issues of significant impact.
I recognize the EA is identified as a draft but even at this stage it could benefit from a thorough review. For example, without detailed search, I noted that the reference Mullineaux, 1987 is listed in the text but not in the references. There appears to be a conundrum from a mantra that alternative scenarios cannot be considered because of financial constraints, e.g., moving the cantonment area. That seems to be incongruous when it is noted that the military annually contributes $12.2 billion or 18 percent to Hawaii’s GDP of $64 billion. This entire project over 8 years is only $220 million.
The commentary restriction of 200 words to discuss issues of the EA at PTA is highly limiting and can easily lend itself to having the issue rejected pro forma because of an excuse that it is not sufficiently explanatory to include it as part of a review. I hope this will not be the case for the comments you receive. Specifically, it is necessary to leave out references but I would hope the review group has enough savvy and familiarity with the EA to be able to recognize the reason for the comments and to place them with the associated text sections with which they should be familiar.
I have six issues to bring to your attention. I limited my commentary of each one to 200 words or less after the identifying header, to meet the criteria for comment. I used Microsoft Word and spaced them so they may be printed as separate pages.
I have made a sincere attempt to help improve the EA as a comprehensive document but conclude that an EIS will be the proper approach for this project. Let me state that if you need more information, including locations in the EA of my concerns, contact me. In fact, I would hope you would consider this cover letter as a separate comment of concern and include it as part of the EA review process.
Michael Reimer, Ph.D.
Commentary by Michael Reimer on the July 2018 EA for the Cantonment Facilities Improvement Program at Pohakuloa Training Area
The U.S. Nuclear Regulatory Commission (NRC) has granted a possession license to the US Army for the residual depleted uranium toxin that was used for training activities in the 1960s. A US Army contractor report on seeking the location of the DU residuals stated that some of the larger DU pieces were removed from the explosive impact ranges and placed in secure storage at PTA. This location must be identified, NRC approval given, a future secured storage area identified, with mandated precautions taken and stated. It is a critical issue of significant impact and requires a full discussion that can only be provided by an Environmental Impact Statement.
In addition, it is imperative that the construction workers be advised of the presence of depleted uranium at PTA and be protected from inhalation of aerosols created by construction and military training activities. Increased health risks are very much higher for inhaled alpha-particle emitting particulates than for whole body exposure.
Depleted uranium may not be the only toxic material present that could expose construction workers, soldiers, contractors, visitors, and staff during construction. A recent court ruling seeking cleanup of contaminated PTA lands acknowledged the migration of toxins from the impact areas.
comments on
Environmental Assessment (EA) and Draft Finding Of No Significant Impact
Cantonment Facilities Improvement Program at Pohakuloa Training Area (PTA), Hawai’i Island, Hawai’i
July 2018
from Cory Harden, Hilo
comments due August 7, 2018–send to usaghi.pao.comrel@us.army.mil
SUMMARY OF COMMENTS
When touting the benefits of the project, the EA focuses on worldwide impacts. It says the cantonment and other PTA facilities are crucially important, and refers to how these facilities will support military actions statewide and worldwide for years to come.
But for negative impacts, the focus narrows to construction only. The EA turns a blind eye to the significant, long-term environmental impacts of military actions, statewide, nationwide, and worldwide, that will be enabled by cantonment improvement.
The EA should describe and evaluate negative impacts from past, present, and future actions at PTA, such as erosion, fires, impacts to native species and native Hawaiian culture, increased human trafficking, higher housing costs, and lost opportunities to use land for agriculture, recreation, housing, and commercial activity.
It is disturbing that no areas quality as traditional cultural properties (TCPs) despite human burials, old trails, over 1,200 archaeological sites, people having “deep cultural attachment to the broad spectrum of natural and cultural resources”, and conclusions by the respected researcher just quoted, Kepa Maly, re. TCPs. It is also disturbing that probably many significant sites in the PTA impact area have been, and will be, destroyed with no mitigation.
The EA should describe and evaluate impacts from numerous former military sites on Hawai’i Island with unexploded ordnance and other hazards. Why is there always money for new projects, but not for cleanup?
The airfield points directly at the cantonment, so planes must take off and land heading away from the cantonment, with tailwinds that increase risk. Improving the cantonment instead of relocating it perpetuates this risk.
With a capacity of 2,300 troops, and a relatively shallow aquifer vulnerable to contamination, the cantonment requires full-scale wastewater treatment, not just septic tanks.
Measures should be proposed to reduce risks from construction trucks, some carrying hazardous materials, on Saddle Road.
SPECIFIC COMMENTS
1 Purpose of and Need for the Proposed Action
1.2 Background and Project Location
As the largest training area in Hawaii, PTA plays a significant role in the training and readiness of U.S. Armed Forces in the Pacific. It offers the largest live‐fire operations training area on U.S. soil in the Pacific, and offers realistic training opportunities not found elsewhere. This capability is critical to maintaining a ready force with global reach. EA p. 1-1
1.3 1 Purpose of and Need for the Proposed Action
The mission of PTA is to provide a quality joint/combined arms facility that provides logistics, public works, airfield support, and environmental and cultural stewardship in support of the U.S. Army Pacific
Command (USARPAC) training strategy, while maintaining an enduring partnership with
Hawaii Island neighbors….the substandard condition of the physical facilities impairs mission readiness, by taking focus and resources away from the training mission. It has also negatively impacted training equipment, and jeopardizes the health and safety of Soldiers. EA p. 1-9
The EA also says
“The deteriorating condition of the cantonment buildings would likely result in the temporary and/or permanent loss of some facility functions and increasing use of trailers and portable structures that would intrude into existing open spaces and thereby reduce operational flexibility.” EA p. 2-18
and
“The proposed investment reflects the Army’s long term commitment to PTA as a national training asset, and makes it less likely that the Army will reduce its presence at, and commitment to PTA.” EA p. 4-11
and the EA lists 20 years of planned projects here
Table 4-1, Past, Present, and Reasonably Foreseeable Future Actions, EA p. 4-3
When touting the benefits of the project, the EA expands the focus to worldwide impacts. It says the cantonment and other PTA facilities are crucially important, and refers to how these facilities will support military actions statewide and worldwide for years to come.
But for negative impacts, the EA turns a blind eye to the significant, long-term environmental impacts of military actions, statewide, nationwide, and worldwide,that will be enabled by cantonment improvement. The focus narrows to immediate construction impacts: “Based on a review of the foreseeable projects, the proposed action will have less than significant cumulative effects on the relevant resource areas…” EA p. 4-11
The Army can’t have it both ways. A full EIS is required to evaluate the cascading impacts of upgrading PTA facilities.
2 Description of the Proposed Action and Alternatives
2.1 Proposed Action
The implementation of the PTA FIP [Facilities Improvement Plan] is estimated to cost $210 million and to occur over an eight-year period (FY16-FY23), subject to funding availability. p. 2-1
Why is there always money for new projects, but not to clean up hazardous former military sites? When I ask military representatives, they complain that Congress fails to allocate the funds. But how many resources does the military commit to lobbying for cleanup funds, versus lobbying for expansion funds?
2.3 Alternatives Carried Forward for Analysis
2.3.2 Facilities Improvement Program (Preferred Alternative)
2.3.2.2. Utility Improvements (Not Part of Proposed Action)
Wastewater
The project area is served by an aging sewer system that is in the process of being replaced by individual wastewater systems (IWSs). The FIP includes seven septic tanks and seven absorption beds…New sewer lines and manholes will be installed within the existing roadways. New sewer laterals will be connected to each building where wastewater is generated. p. 2-8
Much of PTA is lava rock. Is there enough soil for septic systems? How much ground will be disturbed by digging for a sewer system?
Is the project designed to accommodate water from a well in the future? If so, the cumulative impacts of development, at Pohakuloa and nearby, from any well need to be evaluated in greater depth than this EA provides.
I also concur with these comments by Mike Reimer:
“… the cantonment facility is capable of housing 2,300 troops. This is equivalent to a village and merits full-scale waste-water treatment. The aquifer identified by UH studies is relatively shallow and will be subject to receiving leachates of the septic and other drainage-management systems through the porous basalts and possibly toxins carried by the surface drainage control system. Thus, this overlooked issue of significant impact must be addressed properly with the requirement of a full waste-water treatment facility and discussed in a full EIS.” E-mail from Mike Reimer to Cory Harden, July 27, 2018
Electrical Lines The existing secondary power system for the cantonment area consists of overhead poles and wires and pole mounted transformers with a few pad-mounted transformers. The proposed changes will essentially convert it to an underground system…p. 2-11
Much of PTA is lava rock. How difficult will it be, and how much ground will be disturbed, by digging for underground electric?
2.4 Alternatives Considered But Not Carried Forward for Detailed Analysis
2.4.1 Relocate Out of BAAF Accident Potential Zone
One alternative considered was to relocate cantonment activities to the north and south of the area encumbered by the Bradshaw Army Airfield (BAAF) Accident Potential Zone (APZ) and Imaginary Surfaces (but still within project area). The 40:1 Approach Departure surface and 7:1 Transitional surface associated with aircraft operations at BAAF cross through the center of the project area (Figures 1-3 and 2-1) leaving areas to the north and south available for new construction. The project area is also located in Accident Potential Zone (APZ) I (areas at either end of a runway where an aircraft mishap is most likely to occur if one 1 occurs). Most of the buildings and terrain features within the project area penetrate into the imaginary surfaces plane. The cantonment and airfield were constructed prior to adoption of current airfield land use regulations. The land use incompatibility described above is effectively managed by
restricting aircraft operations on the east end of the airfield (i.e., restricting approaches and departures over the project area). The limited size and terrain restrictions of the project area make it very difficult to undertake major new phased construction outside of the APZ without significantly affecting Mission Readiness (Screening Factor 3) and the use of SRM [Sustainment, Restoration and Modernization] funds (not available for new construction) (Screening Factor 1). Moreover, the proposed action (modernization of cantonment facilities and infrastructure) is consistent with 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. pp. 2-16 to 2-17
See comments re. 3.1.1.
3 Affected 1 Environment and Environmental Consequences
3.1 Land Use Compatibility
3.1.1 Affected Environment
To manage potential aircraft accident risks, take offs and landings over the project area are prohibited; all take offs and landings are toward the west, away from the developed area of the cantonment. The proposed action is consistent with a permanent waiver granted by the US Army Aeronautical Services Agency. p. 3-2
The EA fails to clearly describe the danger. This could be remedied by including a map like the one at this website: https://mapcarta.com/24060168
Upgrading the cantonment at the existing site will have the impact, far into the future, of perpetuating problematic flying conditions. It appears pilots will be taking off and landing with tailwinds in the afternoons, on top of coping with the effects of high altitude. See below:
“the prevailing direction of strong winds come from the southeast…”
Environmental Assessment, Construction of an Urban Close Air Support Range and an Aviation Bulls-Eye Range at Pohakuloa Training Area, Hawaii, December 2013, p. 10
https://www.mcbhawaii.marines.mil/Portals/114/WebDocuments/UCAS/UCAS_EA%202013_Dec.pdf, accessed 8-4-18
“A normal takeoff is one in which the airplane is headed into the wind; there are times that a takeoff with a tail wind is necessary. However, the pilot must consult the POH/AFM [Pilot’s Operating Handbook and/or Airplane Flight Manual] to ensure the aircraft is approved for a takeoff with a tail wind and that there is sufficient performance and runway length for the takeoff. Also, the takeoff surfaces are firm and of sufficient length to permit the airplane to gradually accelerate to normal lift-off and climb-out speed, and there are no obstructions along the takeoff path.” https://www.faa.gov/regulations_policies/handbooks_manuals/aviation/airplane_handbook/media/07_afh_ch5.pdf, accessed 8-4-18
“The density of air has significant effects on the aircraft’s performance. As air becomes less dense, it reduces:
• Power, because the engine takes in less air
• Thrust, because the propeller is less efficient in thin air
• Lift, because the thin air exerts less force on the airfoils”
https://www.faa.gov/regulations_policies/handbooks_manuals/aviation/phak/media/13_phak_ch11.pdf, p. 11-2
3.3 Cultural Resources
3.3.1 Affected Environment
3.3.1.4. Traditional Cultural Properties
Consultants for the PCSI [Pacific Consulting Services, Inc.] study reported the presence of human burial from observation and oral traditions, but did not provide exact locations…Human burials have not occurred at PTA during modern times, and active community burial traditions at PTA have not been identified. Cultural informants also reported the continued use of old trails that crossed PTA… Research conducted by Maly (1997; Maly & Maly, 2005) involved interviews that considered Mauna Kea and associated the landscapes and view planes. The researchers surmised that Native Hawaiians may feel a “deep cultural attachment to the broad spectrum of natural and cultural resources” found in and around Mauna Kea (Maly 1999, 3) and recommended that the traditions, sites, practices, and continuing significance of Mauna Kea make it “eligible for nomination as a traditional cultural property under federal law and policies” (Maly 1999, 3 cited in US Army Environmental Command 2013a). As noted above, subsequent work by Pacific Consulting Services, Inc. (PCSI, 2012) concluded that no areas within PTA appear to qualify for consideration as TCPs under U.S. National Park Service (NPS) criteria.
Archaeological resources: To-date, there are over 1,200 recorded archaeological sites at PTA,
including at the KMA. These include prehistoric Native Hawaiian sites… p. 3-8
Why do no areas quality as traditional cultural properties, despite human burials, old trails, over 1,200 archaeological sites, and people having “deep cultural attachment to the broad spectrum of natural and cultural resources”?
Why was PCSI hired for further evaluation of TCP status? Was the Army reluctant to accept Maly’s conclusion that a TCP existed?
Note that destruction of many significant sites in the impact area has probably been going on with no mitigation throughout PTA’s history.
Note also that several people, myself included, were shut out of a recent State Historic Preservation meeting in Hilo where some of the issues above may have been explored.
3.4 Biological Resources
3.4.2 Environmental Consequences
A complete EIS should be done to evaluate severe impacts to biological resources from future actions that will be enabled by cantonment improvements. For example, re. fire risks:
“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
3.8 Water Resources
3.8.1 Affected Environment
In 2015, UH researchers developed a successful test well within the PTA cantonment and encountered an aquifer that began at an elevation of about 4,600 feet above sea level (ibid). UH researchers are drilling additional test wells to establish the extent of the groundwater resource. A developable groundwater resource in the Saddle Area would benefit the Army, which currently spends approximately $0.9 million/year to truck water to PTA from a Hawaii County Department of Water Supply source in Waimea, as well as expanding the range of options available for the DHHL’s Humuula/Piihonua lands to the east of PTA…
See comments re. 2.3.2.2.
3.10 Socioeconomics
3.10.2 Environmental Consequences
There would be no socioeconomic impact in the operational period…p. 3-25
There would be no disproportionately high and adverse impacts on low-income or minority groups from construction and operation of the preferred alternative.pp. 3-25 to 3-26
The EA should analyze impacts from human trafficking and elevated housing costs. See news clips below.
Human trafficking
“…the Hawai‘i State Commission on the Status of Women at the Department of Human Services launched its first anti-trafficking campaign to coincide with RIMPAC. The “She is All Women” campaign aims to bring attention to the outsized demand for prostitution in Hawai‘i — a demand met in part by sex trafficking, and that surges during RIMPAC. Major events such as RIMPAC create a significant risk of commercial sexual exploitation to women and girls in Hawaii. The Commission is especially concerned for runaway youth, Native Hawaiian, immigrant, and LGBTQ persons, who are at an elevated risk of the predictive factors for prostitution and sex trafficking… Places with a large military presence often see higher rates of violence against women as a result of a larger process of normalized violence. According to the Sex Trafficking Intervention and Research at Arizona State University, Hawai`i has one of the worst demand problems in the America and a large number of buyers are on its military bases.”
Hawaii State Commission On The Status Of Women Launches Anti-Trafficking Campaign, July 10, 2018, http://humanservices.hawaii.gov/blog/hawaii-state-commission-on-the-status-of-women-launches-anti-trafficking-campaign/, accessed 8-4-18
Housing costs
“They’re in our communities everyday, the men and women who serve our contry.
They live here in a place where homes are limited and rent keeps rising.
Part of the blame is being put right back on them and the money they get from the government for housing.
“I would say it does impact the cost and right now the demand is high and strong and these individuals who do get that extra allotment each month it is to their advantage,” Sen. Will Espero – (D) Senate Housing Chairperson said…
“In general, the impact of 5-to-10 percent. That’s a significant amount of units in the aggregate,” [Real estate analyst] Cassiday said…
“It’s negative that there’s more competition and potentially pushing people out in certain areas and certain price ranges but the benefits would be they sit here they protect the country they contribute a heck of a lot of money to our economy and therefore there’s a ton of jobs and incomes that are tied to that,” Cassiday said.”
How the military impacts rent prices in Hawaii, Posted: Feb 23, 2017 Updated: Mar 16, 2017,
KITV news, http://www.kitv.com/story/3459177/how-the-military-impacts-rent-prices-in-hawai
3.9 Public Facilities and Infrastructure
3.9.2 Environmental Consequences p. 3-24
The EA should evaluate mitigation measures such as a runway truck ramp to reduce the risk from construction trucks, especially those carrying hazardous materials, on Saddle Road. This high-speed, multi-lane highway ends at a stop sign where several crashes have occurred.
3.12 Toxic and Hazardous Substances
3.12.1 Affected Environment
ACMs [asbestos containing materials] were identified in some of the buildings in cement board, mortars, and joint compounds. LBP [lead based paint] was commonly encountered. P. 3-19
The EA should identify measures to protect the public when hazardous materials are transported on Saddle Road for disposal.
4 Cumulative Impacts
Table 4-1 Past, Present, and Reasonably Foreseeable Future Actions p. 4-3
The EA should describe and evaluate negative impacts from past, present, and future actions at PTA—erosion, fires, impacts to native species and native Hawaiian culture, lost opportunities to use this land for agriculture, recreation, housing, commercial activity, etc. The cantonment project will facilitate future PTA actions for years to come.
The EA should describe and evaluate impacts from numerous former military sites on Hawai’i Island left in hazardous condition for decades. The sites contain unexploded ordnance and other hazards.
APPENDIX B
Section 7, Endangered Species Act Consultation
U.S. Department of the Interior, Fish and Wildlife Service Letter to USAG Pohakuloa
dated September 28, 2016
Subject: Informal Consultation for Pohakuloa Training Area Facilities Improvement Program
PDF p. 167
Was a formal consultation ever done, and is it required?
Many other people have submitted testimonies calling for a full Environmental Impact Statement (EIS) on the military Pohakuloa Training Area (PTA).
