MYTH: Haiku Wells are part of a management plan to meet needs of future growth countywide that conforms to all Community Plans.
FACT: The Ha’iku-Paia Community Plan (p. 11) specifically states that water developed in Ha’iku should be used to meet Ha’iku’s needs first…not sent to South or Central Maui. Ha’iku Wells are not planned to supply water to Ha’iku and the County is discounting other potential water sources ormanagement strategies for South-Central Maui needs.
MYTH: County well plan consultants claim that removing millions of gallons of fresh water that would otherwise reach nearshore waters will have NO effect on marine life or ocean water quality in Ha’iku.
FACT: Studies in other areas of the state show a very strong correlation between sufficient fresh/salt water mix and increase in healthy nearshore marine life populations.
MYTH: Ha’iku streams are supplied by a separate layer of water, completely unconnected to the deeper aquifer from which proposed wells will pump.
FACT: No12/18/05mpletely unconnected. Heavy pumping can cause “coning”- water withdrawals that spread into adjoining areas. Ten years ago, consultants were certain Nahiku stream waters were separate from a deeper aquifer. This has since beeen proven untrue. More information is needed.
MYTH: Ha’iku has plenty of water, taking 10-15mgd (mil gal/day) more will have no effect.
FACT: Ha’iku streams already have 3 to 5 levels of EMI ditch systems removing millions of gallons a day and a County pipeline extracting 1.9 mgd at Awalau stream. Groundwater pumping from private and public wells currently runs 1.5mgd. Another 2 mgd more in withdrawals is proposed by new private wells. HC&S wells in Ha’iku may withdraw up to 4mgd. Small farmers rely on coastal springs, which will be affected by pumping. Who’s doing the math?
MYTH: Ha’iku wells are the most cost effective water supply for Maui’s future needs.
FACT: The pipeline and wells have an estimated construction cost of over $48 million. Annual operating costs estimates range from $2 million to nearly $8 million, depending if water is contaminated with carcinogens DBCP, EDP or TCP. There is no guarantee that wells will consistently yield the hoped for 1.5 to 1.75 mgd each.
MYTH: No other practical water sources are available for Maui’s future growth.
FACT: Over 40 mgd of water flows through the Central Maui ditch system controlled by Wailuku Agribiz & HC&S. The County has an unused five year old water treatment plant in ‘Iao valley near the ditch, capable of producing 1.5mgd of clean water a day. The treatment plant is already hooked into the County’s water line system for South Maui. The County is proposing to spend millions on Ha’iku wells and millions more negotiating to buy rights to use ‘Iao ditch water.
MYTH: Ha’iku is very rainy and has extra water to share.
FACT: Haiku has 80-100 inches of rain a year. ‘Iao rainfall is over 200 inches/year. Upper watershed above Ha’iku wells is non-native, reforested areas whose potential is less than optimum. No one knows if the watershed will support sustained 10mgd pumping. Sustainable yield of an aquifer is not based on how much rain it receives, but on how much can be absorbed and retained by the watershed.
The Maui Inland Sand Resource Quantification Study prepared for the County of Maui Department of Public Works and Environmental Management is now posted on the County of Maui website athttp://www.mauicounty.gov under “New Additions.”
“The information contained in the study verifies what we have long believed,” said Mayor Alan Arakawa, “that our sand resources are finite and that perhaps we should consider a moratorium on sand exports to preserve this resource a long as possible for the people of Maui County to whom the resource belongs.
According to a report prepared for the county, local sources of sand — the key ingredient in concrete — may run out within five to seven years.
About 5.5 million tons of sand have been mined on Maui between 1986 and 2006, according to the report prepared by consultant Howard Hanzawa for the county Department of Public Works and Environmental Management.
The sand is a precious commodity used in Honolulu’s booming construction industry — more than 70 percent of the 318,000 tons mined annually (2006 number) is shipped to Honolulu. The sand is also the only material now available for local beach restoration projects.
Mayor Arakawa asked the council to review “the option of declaring a moratorium on export of sand mined in Maui County to be explored in order to extend the life of Maui’s remaining sand resources for Maui’s people.” Council Member Michelle Anderson supported the moritorium saying, “Why should we be exporting sand to Oahu for more development, when we’re going to need that sand to replenish our beaches?”
Ameron Hawaii, is the company mining and exporting sand.
New Plan — Same Problems
A&B’s original Spreckelsville Mauka plan called for 400 golf estate houses on 93 acres with a 95 acre golf course and a 5 acre park. Their new, “smart growth” Spreckelsville Village plan puts 380 units of “mixed housing” on 115 acres with a 90 acre golf course/open space, a 5 acre park and 2 acres of community facilities and commercial shops. Does “smart growth” mean building another “town” of 600-1,000 residents 1/2 mile from Pa’ia?
380 new homes on former ag lands will not recreate the plantation village of yesteryear for local Maui residents. It will place more demands on overburdened water, sewer and school systems, police and public facilities. If Spreckelsville’s current ownership patterns prevail, the majority of Spreckelsville Village units will be sold to nonresidents, many of whom will use their houses as lucrative vacation rentals.
Myth vs. Reality
Spreckelsville had 380 families living in 8 “camps” during plantation days. Villagers worked in nearby fields and had few private cars. Their homes had simple water. electric and plumbing systems. Their children walked to nearby schools, stores, fishing spots and the movie theater. Families had small vegetable plots alongside cane fields.
The new Spreckelsville Village will center around a large golf course and expensive golf course homes. No specific prices are listed for its “mixed” housing. Neighborhood children will be bused or driven to schools in Kahului. Residents or tenants will drive to access work, shopping, medical facilities or recreation sites. “Community gardens” will serve as a buffer between the cane fields and their herbicide laced dust and residents houses.
A&B will need nearly a quarter million gallons a day of water from proposed Ha’iku wells for domestic use in Spreckelsville village. Brackish well water will be pumped for golf course irrigation.
A one way “bypass” from the Pa’ia parking lot on Hana Hwy to the Pa’ia post office on Baldwin Ave. is promised to soften the impact of another 700 cars trying to access crowded North shore roads. After 200 of the 380 units are occupied, a “Traffic Impact Assessment” will be done to determine if additional traffic “mitigations” are needed.
Translation: North shore residents wait in traffic lines while “experts” do
more studies to figure out why.
A&B OFFERS TO TRADE AFFORDABLE HOUSING FOR GOLF COURSE VILLAGE
A&B promises if Spreckelsville Village is approved, they will not develop their Paia School Project District- trading promised affordable housing approved by local citizens for a golf course “village:”
Pa’ia School Project District
(Approved in the current Ha’iku/Pa’ia Community Plan)
330 housing units on 71 acres including “affordable housing for all income levels “and a section of “self help” lots for low income families to build homes, 7 acres of park and greenbelt along Baldwin Ave. and 2 acres of neighborhood commercial. Adjacent to Paia School (only elementary school in Maui with capacity for more students).
“Spreckelsville Village” Project District
(Proposed for inclusion in Wailuku/Kahului Community Plan)
380 units on 115 acres, (defined as “mixed housing” with no price range specified, with upscale lots lining proposed golf course), 90 acre golf course and ag buffer zones, 5 acre park, 1 acre parking lot and 2 acre community and neighborhood commercial. Students will attend Kahului schools.
Who Should Plan Spreckelsville’s Future?
Spreckelsville was included in the Pa’ia Community Planning District for the 1980 Community Plan. In 1990, it was moved into the Wailuku/Kahului Community Plan. Community Associations and citizen groups in Ha’iku, Spreckelsville, and Pa’ia have all asked to have Spreckelsville restored to the Pa’ia/Ha’iku Planning area so local residents can have a say in the planning process.
Sierra Club Maui Group June 30, 2001
Po Box 791180
Paia, Hi 96779
Attn: Tom Schnell, AICP
1001 Bishop Street, Suite 650
Honolulu, Hawaii 96813
RE: DRAFT EIS for proposed Honnua’ula/Wailea 670 Project
Mahalo for this opportunity to offer comments on the Draft EIS for this project on behalf of the six hundred members of Sierra Club Maui Group. Sierra Club has offered input to this project since its expansion to 670 acres in the late 1980’s. We have long felt that the sensitive characteristics of this site and the amount of modification proposed for golf course and housing warranted an updated EIS process. We appreciate the applicant’s response to our request to extend the deadline for comments.
We are disappointed that the so-called EA issued in conjunction with this project, contained so little specific information about what was planned. This lack of two levels of review for a complex project, compressed the public’s opportunity to provide meaningful comments into a very short time frame. While this DEIS is lengthy, it has many sections which appear to be cut and paste from previous sections, with no additional information being offered.
We also believe that this document does not meet the requirements set forth in
HAR 11-200-17(E) which requires proposed actions to provide the information necessary to permit an evaluation of potential environmental impacts in their EIS.
Segmentation of Associated Actions
There are a number of actions associated with this project which are necessary precedents for the larger project and, to be in compliance with HAR 11-200-7 (B), these must be included in the DEIS to avoid segmentation of environmental review. A famous case here on Maui involving Kahana Sunset condominiums established this as an important legal precedent.
The Supreme Court opinion stated: “the Commission is the agency receiving the request for approval of the action, and it is therefore the agency responsible for preparation of the environmental assessment.” In so holding, we recognized that “[i]solating only that particular component of the development for environmental assessment would be improper segmentation of the project.”
This appears to be what is happening with a number of actions connected to the Honua’ula project. Widening of Piilani Hwy from Kilohana to Wailea Ike St. is a required condition of rezoning, as are improvements to Wailea Ike and other intersections. Environmental review for these actions has been done separately and is not included in any meaningful way in the project’s DEIS.
Off-Site Affordable Housing
Likewise there is no discussion, evaluation or mitigation of the impacts of the proposed 250 affordable units in North Kihei (except a plan to reduce traffic impacts required by conditions of rezoning). These are part of the Honua’ula project, although they are located elsewhere.
Major offsite Infrastructure
Offsite wells, transmission lines and storage tanks for potable and non-potable water supplies and wastewater transmission lines are located on private land and will have no environmental review if they are not evaluated in the DEIS. Only the wastewater line has any discussion of botanical review, but no report or survey maps are included.
MECO Power Station Expansion
Basic information about the proposed MECO expansion should be included in the DEIS, since the expansion area adjoins a reservoir area to store brackish water for Wailea resort.
Do transformers contain toxic substances? Is there a minimum distance recommended between electrical equipment and homes, shops or public spaces? The DEIS should present as much information as available, whether MECO decides to expand or not.
While it is mentioned that the present overhead high voltage power lines that transect the property will be relocated underground, it is not mentioned if lines from the proposed Auwahi wind farm would likely be located above ground or below ground? Will specific archaeological review be done along the corridor where the high voltage lines are buried?
When will information be obtained from MECO to meet condition 18 of rezoning, since this information is part of Project District Phase II approval?
Wastewater Treatment Facility
The DEIS does not appear to have the Sewage Disposal Analysis reviewed and commented upon by state and county agencies, as required by condition of rezoning No. 16 prior to Phase II approval. . Instead, it states that;
“For a more detailed analysis Honua‘ula Partners, LLC has engaged Brown and Caldwell Engineers to prepare a Draft Honua‘ula Sewage Disposal Analysis. In accordance with this condition, the Analysis will be submitted to the State DOH and DLNR and the County DEM and DWS for review and comment before Project District Phase II approval. The Analysis, along with reviews and comments, will then be submitted to the Maui County Council for review. “
Since the Planning Commission is responsible for granting the project’s Phase II approval, and the Analysis must be submitted to various agencies for review before Phase II approval, this DEIS should already include the Sewage Disposal Analysis and related comments to provide adequate opportunity for meaningful review and comments by the public and the Planning Commission,
Especially important would be a discussion of comparative wastewater fees for residents. Since affordable homes are guaranteed parity with public facility rates, would Makena Resort’s wastewater system be able to operate with half the customer base at lower fees? Policymakers should have access to this information as early in the process as possible.
Based upon the large volume of critically needed information lacking either any inclusion or review in this DEIS document, Sierra Club would request the accepting authorities to find the document incomplete and premature and request that the DEIS be resubmitted when the missing information can be included. To not take this action is to segment the project, in direct violation of HRS 343 and its applicable rules.
3.6 Biological Resources
The proposed 22 biological preservation area is wholly inadequate, and ultimately neither sound conservation planning nor wise resource utilization. The 143 acres of fragmented preservation areas proposed around the golf course holes in the southern portion of the site does not offer the best strategy for successful management.
Dr. Jonathan Price, an expert in Hawaiian dryland forest preservation commented on the Honua’ula plan:
“the smaller the area preserved, the more intensive the management will need to be. A site of a few acres for example, particularly if divided into scattered smaller units, will require costly, intensive management, in order to maintain even a modicum of ecosystem integrity. On the other hand, setting aside an area of more than 100 acres would require some degree of management, albeit far less intensive than the former scenario.”
The DEIS should analyze a Project Design layout in the Alternatives Section that includes a 130 acre botanical cultural preserve, to be in compliance with condition no 27 of rezoning.
4.1 Cultural Resources
The project’s AIS is based upon methodologies that involve minimal testing (only six of 40 sites, most with one 1ft by 1 ft test unit), inadequate mapping and incomplete fieldwork.
The AIS does not specify how many field sessions involving how many personnel, for how many days have taken place at the project site, nor does it elaborate on the transect areas covered. These are all standard disclosures in archaeological reviews. It is still unclear if actual transects have been completed of the northern 480 acres.
It is clear that when citizens reported during public testimony that numerous additional cultural sites were on the land, they were correct. Twelve new sites with nearly twenty features have been recorded since the last draft AIS in 2001. Citizens continue to submit pictures and locations of additional sites. It is clear that the AIS is far from being complete.
Site evaluation at Honua’ula project does not appear to actually be based upon the State Historic Preservation law process. Especially lacking is a clear assignment of significance Criterion E as specified by 13-284-6(b) 1-5 HAR, which this AIS and DEIS must comply with.
Criterion E is defined in the AIS as: “ applies to sites or places perceived by the contemporary community as having traditional cultural value.”
The AIS version of criteria E omits the following underscored language;
(5). Criterion ‘e’ Have an important value to the Native Hawaiian people, or to another ethnic group of the state due to associations with cultural practices once carried out, or still carried out, at the property or due to associations with traditional beliefs, events or oral accounts – these associations being important to the groups history and cultural identity.
Only the three recorded stepping stone trail sites have been evaluated as significant under criteria E”. One segment of stepping stone trail recorded earlier, placed on a crude map and not assigned a number has seemed to disappear from the inventory survey. It is not explained whether this segment was not relocated, combined with another segment and assigned the same site number or has simply been forgotten. Cultural practitioners have shown photos of several additional unrecorded segments of stepping stone trails on the project site. Some of these trails appear to lead to planting areas. Some make connect with trail segments found on the Wailea golf course or in Palauea preserve further west. No accurate maps have been provided showing relationship of the trail sections. It is unclear whether all are being preserved in their original cultural setting.
Preliminary Engineering Report relies on declaratory statements about the adequacy of the project’s water systems without supporting technical studies to substantiate its claims. There is not enough quantitative data on water systems to permit any impact analysis. There are no independent hydrology reports. The USGS study referred to that purportedly supports higher available flows for Kamaole aquifer, only mentioned the aquifer as one entry in an aquifer chart. The USGS report offered no analysis of the aquifer’s potential SY. The 1988 hydrology report for the project cautioned that Wailea 670’s wells could impact downslope wells in Wailea and comments from Wailea Resort management made the same statement. The DEIS must analyze the proposed use of the Kamaole aquifer for the project’s demand by researching and evaluating the entire range of existing users and the relative pumpage and salinity of their wells. Water fees for residents must also be discussed to comply with rezoning conditions.
Drainage plans appear to be elaborate, but there is little quantative data to provide assurance that the assumptions they are based upon will prove to be sufficient to mitigate impacts. For example, one of the larger areas of drainage flow impact, basins 1 through 5 at the north of the project site have a high concentration of high-density urban environment proposed, the lowest percentage of golf course lands to absorb run off, and drainage basin systems not scheduled to be completed until Phase II (2018) or Phase III (2022) of the project. The existing offsite drainage impacts to this area during a 100 yr / 24 storm are huge: over 2,100 cfs (1300 mgd). Currently two 10ft or more diameter culverts are installed to carry water from this sector of the project area under Piilani highway and eventually to the ocean. Options, such as a larger natural buffer area between, Maui Meadows and Honua’ula should be discussed as viable alternatives to mitigate overflows in this high impact area. Currently, less than 4 acres is proposed for this buffer.
To give a blanket statement, that the project’s theoretical system of drainage basins, and absorption by golf courses and open space will mitigate large storm event flows, seems highly speculative. No examples of similar successful designs were included in the DEIS discussion for comparison. Tit also seems risky to assume that pre-existing and off site flows will not need additional containment measures in order not to overwhelm facilities designed for only post development flows. If coastal impacts result from the project, what mitigations will be available to restore the health of public trust resources?
There is no plan for all-important maintenance of the retention basins in the “Master Drainage Plan.”
One of the project’s 3 private neighborhood parks is located along the makai boundary of the property in a natural gulch area currently subject to high velocity flows during storm events. A park location on either side of the natural gulch would be more practical.
Sierra Club Maui requests that the accepting authorities find this DEIS incomplete and premature. Without including the omitted studies and evaluation information in the DEIS, the project is not in compliance with the environmental review laws of the State of Hawaii. We appreciate this opportunity to share our remarks.
Sierra Club Maui Group,
Lucienne de Naie