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The Kaheawa II Wind Farm and the Fate of the Hawaiian Hoary Bat

Introduction

Kaheawa II is the lower string of wind turbines on the mountain above Maʻalaea. It became operational in July 2012 and provides about 21 MW of power to the grid. A Habitat Conservation Plan (HCP) committed the wind farm to not “taking” (kill, maim, harass) more than 11 Hawaiian Hoary Bats (ʻOpeʻapeʻa) within a 20-year contract period. However, that number has been estimated to already have been taken in seven years; the company has provided a revised Environmental Impact Statement (EIS) and HCP. The new documents propose increasing the take of bats from 11 to 38 adults during the contract period. It also proposes increasing the allowed take of Nēnē from 30 to 44 adults. Both the ʻOpeʻapeʻa and the Nēnē are protected as endangered species.

We still lack information on the total number of bats on Maui, their distribution and their population trend. This is partially due to insufficient research, partly to ineffective detection technology. The most commonly used technology for bat detection is acoustic detection of their echo-location sounds. However, that only works when the bat is echo-locating and the microphone is sufficiently oriented towards the bat. Comparison to thermal imaging has found that only 8% of bats present are detected. Further, there is no way to tell if an acoustic detector is registering a single bat making multiple echo-location sounds or multiple bats.  It is important to invest in increasing our knowledge of the bat population on Maui and what the effects of mitigation efforts on that population have been. For this reason, we support research funding as a partial mitigation. Without knowing what the bat population and trend is, it is difficult to say if the taking of an additional 27 adult bats at Kaheawa II (beyond the current HCP limit of 11) through the current 20-year period ending in 2032 is an existential threat to the endangered species on Maui or to a subgroup of it. The death of an adult bat may lead to the death of its juvenile offspring as well, and it may have ripple effects on genetic diversity and resilience.

Quantifying the Loss

The Kaheawa II plan “includes searches of roads and graded pads that occur within a 70-meter (m) radius from each turbine every 7 days. Searches are primarily conducted by a canine search team, with visual searchers conducting about 14% of searches per year.

That means that far from all casualties are detected. Scavengers may remove bats after an event but before the weekly search. A bat may be slung beyond 70 meters. A statistical model attempts to compensate for the missed casualties by extrapolating from the number found. Given how far off the original estimates of bat fatalities were, how inefficient the bat detection technology is and how limited our knowledge is of island-wide and local bat populations, Kaheawa II must increase the confidence in its take numbers.

Mitigation

Besides research, the proposed external mitigation is to increase the amount of restored forest habitat thought to be preferred by the Hawaiian Hoary Bat. Preference is to be given to areas otherwise threatened with development or other changes that would make them less hospitable to the bat. A selected area must be known to already host bats (through acoustical or other detection methods). Bats have been detected all over the island. On Hawaiʻi Island they have been detected from the shoreline to 11,800 feet elevation on Mauna Loa. They have a varied night-time foraging area and range, while the areas where they roost during the day and where they pup are thought to be much more limited, typically to restored/established forests. Preserving their preferred roosting habitats is therefor more important from the standpoint of resiliency of the species than managing their foraging range.

There is no data on the effects of habitat restoration on the bat population. As a matter of fact, it was found at Kahikinui that bat detection frequency decreased after fencing for ungulate (deer, pigs, goats) removal, likely due to less insects which had been attracted by ungulate dung. At this point, population compensation through reforestation must be considered theoretical. This is very different from the situation with Nēnē, where fledglings can be counted in protected areas.

The only operational mitigation known to reduce fatalities is to not run the wind turbines below a cutoff wind speed threshold from sunset to sunrise, or not run them at all during that time – Low Wind Speed Curtailment (LWSC). The bats are able to detect and avoid the turbine blades if they are spinning rapidly. Data from mainland studies indicates that raising the cutoff threshold from 5.0 meters/second wind speed (as proposed by Auwahi and by Kaheawa II for part of the year) to 6.9 meters/second is effective in this regard, while raising it additionally has little or no effect.

The Auwahi wind farm HCP says that the impact of LWSC regimes from studies on the mainland suggest a reduction in bat take ranging from 10 to 92 percent through increasing the cutoff speed, but that there is little or no benefit above 6.9 meters/second:

Bats are detected year round at the wind farms but more often August-October. The following chart is from the Kaheawa II HCP. The highest rate was in September 2015 when bat activity was detected on 58% of the nights.

Comments to the Kaheawa II EIS

1. Multiple non-contiguous habitat restoration areas

The EIS says “Wildfires can cause direct loss of adult bats and dependent young that are unable to escape a forest fire.” A catastrophic fire in an area heavily used for roosting and pupping could dramatically affect the total bat population and the options for species recovery. Sierra Club would like to see appropriate habitat restoration for the ʻOpeʻapeʻa in at least three non-contiguous areas to reduce that risk.

2. Increase the confidence in the take numbers

If some bat fatalities are not detected, we may be underestimating the actual take at any given wind farm. Sierra Club supports the recommendation of the wildlife agencies to expand the buffer zone searched for carcasses by 20%.

Similarly, we propose increasing the frequency of searches for carcasses to once every two days (instead of once/week) for at least a year to see if the detection rate changes.

3. Reduce the fatalities by raising the wind speed cutoff

Based on the mainland studies referenced by the Auwahi revised HCP, Sierra Club proposes a 6.9 meters/second cutoff for all wind farms from 30 minutes before sunset to 30 minutes after sunset year round. The Kaheawa II HCP proposes a nightly cutoff of 5.5 meters/second from February 15 through December 15 and 5.0 the rest of the year. Curtailment would be extended from December 15 to February 15 if fatalities occur outside the proposed curtailment period. It claims that “There are no studies to date that test whether mortality rates decrease significantly when LWSC is raised from 5.5 m/s to 6.5 m/s.“, despite the studies reported in the Auwahi HCP. However, it also says that “increasing curtailment from 5.5 m/s to 6.5 m/s would reduce renewable energy generation from the Project by approximately 328 megawatt hours (MWh) annually (or 0.47% of 70,000 MWh assumed to be produced annually)“. That is a very small price to pay for reducing or possibly eliminating the bat fatalities.

4. Monitor the effects of operational mitigation and increase curtailment if necessary

The proposed increase in take is largely a projection of continued fatalities at the level we have seen the past seven years, which is much higher than originally anticipated. If this already increased take is exceeded, the HCP says:

Once the permittee and/or wildlife agencies have determined the observed take is exceeding the permit year trigger, the appropriate minimization technique determined in consultation with the wildlife agencies would be implemented immediately if minimization includes just a change in wind turbines operation.
Minimization will include any or any combination of the following:
1. a higher level of Low Wind Speed Curtailment if additional research demonstrates a higher
likelihood of success than does current research,
2. periods of complete cessation of operations during the night (such as during the first 2 hours
of the night or during annual periods of highest activity, for example),
3. implementing deterrents that have been proven to reduce fatality rates on at least 50% of the
wind turbines (with the highest bat detection and/or fatality rates),
4. implementing “early-warning” systems on at least 50% of the wind turbines (with the highest
bat detection and/or fatality rates) that detect the presence of bats and shutting down at least
50% of the wind turbines (with the highest bat detection and/or fatality rates) for at least 15
minutes (assuming no additional bat activity is detected),
5. or a not yet identified option.

That is unsatisfactory – requiring that additional research show higher success rates for low wind speed curtailment than current research; they should go with the current research if there is no better research at that time. The rest is speculative and non-committal.

There are no proven bat deterrent technologies yet, although a wind farm on Oʻahu will use a new technology for evaluation as a pilot project.

Habitat restoration is valuable and should be part of the plan, but it cannot (at this time) be demonstrated to compensate for a single bat lost to the wind turbines, much less 38 of them.

Sierra Club feels that the company must commit to curtailing operation to the extent required to reduce the observed take rate so as to not risk jeopardizing the survival of this unique Hawaiian animal, to the point of full night-time curtailment if necessary. New technology such as bat deterrents may help, but the calculated total take should not go to 38 before taking steps that are known to save bat lives. If the tier 1 and 2 mitigation steps do not reduce the observed rate by 50% from the average of the last three years (the basis for the proposed new rates), additional steps should be taken to reduce the take (increase the cutoff rate, not run the turbines at night at all).

 

 

Submit Comments on the Anaergia MANA Draft EIS

(Read about this issue in our previous post here  and in a Maui News article about the recently held public meeting.)

Anaergia/MANA has submitted a Draft Environmental Impact Statement (DEIS) to the county, which must be approved in a final form before the project can move forward.

The deadline to comment on this Draft EIS is Tuesday, February 6, 2018.

We urge Sierra Club Maui members and supporters to submit comments on the Draft EIS.

At first glance, the project might look eco-conscious and economically viable – but when you delve into the details, it becomes very clear this project has not been properly vetted. 

Here is the announcement of the Draft EIS (PDF) in the December 23, 2017 OEQCʻs The Environmental Notice.

The Draft EIS is available for download here (large PD).

 

Comments should be emailed to:

 

Anaergia’s MANA Project Questioned in The Maui News

Original Article at: http://www.mauinews.com/news/local-news/2018/01/sewage-plant-project-would-end-landfill-green-waste-composting/

 

Sewage plant project would end landfill green waste composting

Green waste is dumped off at EKO System's drop-off at the Central Maui Landfill in this photo taken in February 2016. A proposed renewable energy project at the Wailuku-Kahului Wastewater Reclamation Facility would put the 23-year-old composting facility out of business, diverting the sewage sludge that is a necessary component in EKO's composing process. The Maui News / MATTHEW THAYER photo

Green waste is dumped off at EKO System’s drop-off at the Central Maui Landfill in this photo taken in February 2016. A proposed renewable energy project at the Wailuku-Kahului Wastewater Reclamation Facility would put the 23-year-old composting facility out of business, diverting the sewage sludge that is a necessary component in EKO’s composing process. The Maui News / MATTHEW THAYER photo

KAHULUI — Maui EKO Systems, which has processed the island’s green waste and county sewage sludge into compost for nearly 23 years, could be put out of business as early as the end of next year because of a proposed renewable energy project at the Wailuku-Kahului Wastewater Reclamation Facility.

The closure stands as one future impact among several other potential problems residents voiced during a community meeting focused on the project led by Maui All Natural Alternative, an Anaergia Services company, on Wednesday at Kahului Elementary School.

“I think we left the meeting with more questions than answers,” Sierra Club Maui coordinator Adriane Raff Corwin said Thursday. “They didn’t give many specifics at all, so we’ll be following up. But I think last night’s meeting illustrated the community has a huge amount of concerns and questions that aren’t being answered.”

Officials with the energy company and county Department of Environmental Management provided a brief presentation and answered questions during their first public meeting on the project. An environmental impact statement is nearly completed, and a final draft is expected later this year.

“No project I’ve ever seen in my 27 years with the county is perfect, but I think this consists of everything we’re looking for,” Environmental Management Department Director Stewart Stant told the crowd of about 40 people.

Stewart Stant

Stewart Stant

The project calls for installation of an anaerobic digester to produce methane gas from energy crops grown on former Hawaiian Commercial & Sugar Co. lands. The natural gas would be refined on-site and fuel a combined heat-and-power engine to generate electricity for the sewage treatment plant.

Waste heat from the plant’s engine would dry biosolids, or digested sewage sludge, produced by the plant. The anaerobic digester would be located on the west side of an existing aerobic blower building.

The treatment plant is next to the ocean on Amala Place in Kahului. The Kanaha Pond Wildlife Sanctuary is inland of the sewage treatment plant, and Kanaha Beach Park and Kahului Airport are located to the east.

Anaergia and county officials said the renewable energy project would provide 4.5 million kilowatt hours of electricity per year and dry the county’s 24,000 tons of biosolids annually. The biosolids would be treated and returned to the county to possibly be used as fertilizer for parks, including the Waiehu Municipal Golf Course.

The energy company would develop the project at no upfront construction cost to the county and charge the county 29 cents kWh as part of a 20-year contract.

Residents and environmental watchdog groups took issue with the charge per kilowatt hour, which is more than double what Maui Electric Co. pays wind farms and for fossil-fuel generated power.

Doug McLeod, vice president of the Maui Tomorrow Foundation, said the price is high because the county advertised the project as “gas turbine to dry sludge,” which solicited just one bid from Anaergia. He added that there seemed to be “a lot of very strange aspects” in the deal that he believed was not the most cost-effective for taxpayers or the safest for the environment.

“When you look at this price 29 cents that is well more than double the current market price for solar power,” McLeod said Thursday. “It would seem to be a lot more than other renewable options, but we don’t know that because the county didn’t ask” for alternatives.

McLeod, who also runs an energy consulting firm and is the former county energy commissioner, said many solar companies did not bother to meet with the county to discuss the project because of the clear restrictive language that favored Anaergia. He believed only Pacific Biodiesel showed interest.

Raff Corwin also questioned why the county did not seek separate solutions for disposing of biosolids and producing energy. She wondered why the treatment plant proposal needed to combine both aspects into one and was concerned about air quality and odors produced by the plant.

“I still haven’t gotten a clear answer as to why these two needs had to be combined,” she said. “It sounds like we’re going to have a huge amount of dry sludge and green waste no longer turned into composting material.”

In 2014, Anaergia, a California-based company, signed a separate 20-year contract with Mayor Alan Arakawa’s administration to build a waste conversion facility at the Central Maui Landfill.

Anaergia and county officials acknowledged that the wastewater treatment plant waste-to-energy project would be related to the landfill project because it would provide dried sludge for the landfill waste conversion project. But they maintained the contracts for the projects were separate.

McLeod said he is skeptical of the landfill waste-conversion facility, which has yet to have an EIS preparation notice published. Anaergia had previously tried to build an energy plant using wastewater in 2015 but was shot down by the Public Utilities Commission.

“These contracts people think they’re free with minimal upfront cost, but they will cost the county money in the end,” McLeod said. “There’s obviously a lost opportunity.”

As for EKO, the company’s current contract with the county ends in June, but the two sides will likely extend until the end of 2019, plant manager Rubens Fonseca said Thursday. The company has 20 workers.

The composting operation was established to extend the life of the landfill by diverting green waste and sludge.

“I hate to see this product that has been offered to landscapers and farmers here almost 23 years going to be gone,” he said.

* Chris Sugidono can be reached at csugidono@maui news.com.

Raise Your Voice Against Anaergia/MANA’s Digester Facility

Maui County is contracting w/ Anaergia Services, LLC via its local Maui company MANA, LLC (Maui All Natural Alternatives) to build a waste digester power plant.

BUT TO MAKE IT WORK, ANAERGIA NEEDS TO:

  1.  Get water from A&B to –
  2. Grow sorghum crops on A&B land to –
  3. Harvest the crops to –
  4. Bring the crops to Kahului to –
  5. Put in their not-yet-built $20 million waste digester plant to –
  6. Create biogas to power the Wailuku-Kahului Reclamation Facility (WKWWRF) next to it.

THEN: Anaergia will use the heat from the digester to dry all of Maui’s human sludge (excrement) and make it into fertilizer pellets to sell back to Maui residents. And the plant will  be located in the tsunami evacuation zone.

Sierra Club Maui submitted comments on this project, back in late 2016 when the County Council’s Infrastructure and Environmental Management Committee (IEM) was considering a resolution authorizing a lease to Anaergia for this facility. Then, very quickly, the lease resolution was pinched out of the IEM Committee by Council member Don Couch and Chair Mike White, and brought before the full Council in the last meeting of 2016, where the lease was approved without further discussion. In January 2017, some new council members were sworn into office who likely would have put up a fight against rubber stamping this lease – so the actions in December 2016 ensured the new council members couldn’t stop the project.

Flash forward to January 2018. Anaergia/MANA has submitted a Draft Environmental Impact Statement (DEIS) to the county, which must be approved before the project can move forward, and they are holding a public meeting on Wednesday, January 24th for the public to learn about the project.

We urge Sierra Club Maui members and supporters to attend this meeting and to voice concern with this project.

At first glance, the project might look eco-conscious and economically viable – but when you delve into the details, it becomes very clear this project is, in a nut shell, going to lead to a lot of money spent for little-to-probably no improvement, while getting in the way of real improvement in the county’s usage of renewable energy and fiscal responsibility.

There are more efficient, safer, and CHEAPER ways to power the Wailuku-Kahului Wastewater Reclamation Facility (WKWWRF) with renewable energy, like:

  1. Use solar power and battery storage (there was a much more affordable project planned with Haleakala Solar that was unceremoniously cancelled by the county, after which the Anaergia project was announced)***
  2. Harness biogas from existing compost and trash on the island (Maui currently has no industrial compost heap, food goes into the trash stream)

***The cost of electrical generation for the cancelled solar PV project with Haleakala Solar at WKWWTF would have provided energy at about half the cost of Anaergia’s project. The solar PV project was cancelled by former Dept. of Environmental Management Director Kyle Ginoza after Haleakala Solar had already done $75,000 in design work. At that time, solar energy would have cost about 15.9 cents/kwh for the first year, compared with Anaergia’s 29 cents/kwh. And since then, MECO’s latest Purchase Power Agreement for solar has dropped to 11.7 cents/kwh (with cost of storage factored in, the final price would be higher, but it would still cost much less than 29 cents/kwh).

 

Here are our concerns that we gave to the Council in 2016 and that are still very valid today:

  1. Cost: Initially, Maui County would pay for electricity at a rate close to that of today’s oil-based electricity from MECO, but with a contracted rate increase of 2.2% per year for twenty years. Without a doubt, within five or ten years the county will be kicking itself for committing to such an exorbitant price for electricity as the cost of renewable energy continues to fall (and solar is already well below even the starting price). At face value, the proposal may sound economical because Anaergia and its subsidiary assume the cost of building the power plant. However, there is no reason to consider Anaergia to be a charitable organization. Its calculation of the charges to Maui County are based on recouping the $20M construction costs, costs for permitting, costs for running the plant for 20 years (including energy crops), and profits. Rather than a great deal, this can be considered a loan at very high interest to the county. If the project made sense for other reasons, it would be more cost-efficient to issue a bond or seek grants and finance it without contracting Anaergia.
  2. Location: There was agreement at a 2016 hearing, including by Director Stewart Stant, that the location which would host the power plant, being at sea level and in a tsunami zone, is a poor choice. The county has been thinking about moving the WKWRF inland. Director Stant said it is more urgent to move the Wailuku Pumping Station, which supplies waste to WKWRF (Wailuku Kahului Wastewater Reclamation Facility), than to move WKWRF itself. However, one does not exclude the other. Adding a power plant to the existing WKWRF means, 1) it will be much more difficult to move WKWRF, and 2) it canʻt be moved until 20 years after the power plant is online (which itself is likely years away).
  3. Green Waste Disposal Costs: Currently, EKO collects and combines green waste with sludge to produce compost, which it then sells. Removing the lucrative sludge element from the county’s contract with EKO may cause EKO to terminate its remaining green waste contract, as green waste alone has very little resale value. The county would need to contract with a new entity that will collect only green waste; this entity will likely charge a much higher rate per ton because the new entity will need to apply for permits, as well as provide its own location and industrial equipment because EKO’s current location may become a landfill site; with the resale value of green waste so low, the entity will need to charge sky high prices to make a profit. We urge you to pay close attention to the timeline of when EKO’s contract may terminate and when the county could feasibly have a replacement green waste collection entity online. By state law, green waste is not allowed in the landfill, so the county cannot throw away green waste while waiting for a new composting program to come online. [In news articles like this one, county officials claims that the MANA project will bring down costs, but they always fail to mention that the reason why EKO costs are high is because the county wouldn’t give EKO a contract that would last more than 2 years.]
  4. Alternatives: Director Stant said that the reason for proposing the electricity generating plant for the WKWRF instead of the Kihei Wastewater Reclamation Facility is that the Kihei facility already has an excess of solar power during the day but has no way to store the power for use in the evening and at night. A much more cost-efficient investment would be to add battery storage to the Kihei facility. Combining solar and storage at Kihei could be a pilot project which could then be replicated at the other facilities.
  5. Community input: County’s Corporation Counsel said there is no room for public input during contract negotiation for services (which she said is 95% done). However, collecting public information and input only after a contract is finalized is an expensive and cumbersome model which generally leads to community dissatisfaction.

 

These were our concerns regarding the Environmental Impact Statement Preparation Notice, which are still very relevant for the Draft EIS:

  1. Conflict of Interest: Currently, the county is both the proposing agency and the accepting agency, which is a clear conflict of interest. Because the project will be built on state-owned land, we ask that a state agency be the accepting agency. This will resolve this conflict of interest.
  2. Third Party Consultation: We are concerned that this project’s FEIS has not been outsourced to a non-partial third party consultant. If MANA researches and writes its own FEIS, it is very unlikely that potentially serious concerns will be highlighted and examined and that feasible alternatives will be given fair consideration.
  3. Local knowledge: We are concerned that because no local expert consultants have been hired to assess all potential environmental and cultural impacts (especially on the local bird populations in the Kanahā Wildlife Sanctuary) that the FEIS will be severely lacking in important local expertise. We would like to see local avian experts brought on board to analyze this project.
  4. Tsunami Zone: We are very worried about not only placing more expensive long-term infrastructure in the tsunami zone but also the effects it may have on the environment if a tsunami or extreme flooding event happens. If a catastrophe occurs, how will MANA mitigate the risk of waste, flammable gas, and other toxic emissions escaping from the facility into the surrounding industrial and residential areas?
  5. MECO: How will the county negotiate with MECO to take the WKWWRF off its grid? What might be the exit costs of taking the facility off the grid?
  6. Energy Analysis: For the “Identification of Alternatives,” we would like independent energy and waste consultants who have no connection to MANA to create a more robust list of potential alternatives and analysis of their pros and cons.
  7. Carbon and methane footprint: While the facility will create energy from renewable resources, we have doubts as to whether it will actually reduce our carbon and methane footprint. We would like the FEIS to contain a complete analysis of the full carbon and methane footprint of the facility, as well as a listing of any VOC emissions that may occur.

New Maui Water Study

At the request of the Ulupono Initiative, Center for International Energy and Environmental Policy, Jackson School of Geosciences has studied Maui’s water availability.

A Systems Approach for Investigating Water, Energy, and Food Scenarios in East-Central Maui

concludes:

“The water availability for different scenarios is based upon the precipitation, surface water, and groundwater on the Eastern (Haleakala) portion of Maui. Most of the 330 million gallons per day (MGD) of average surface water runoff is already used for some purpose (see Figure E-1). While there appears to be a large amount of groundwater resource available, the costs are prohibitive for accessing the bulk of that water. Many new water supplies such as more pipelines, groundwater wells, reclaimed water facilities, and desalination are constrained by the available capital required to invest in new fresh and potable water sources. There is some opportunity to recover more wastewater that is already being reclaimed. Two strategies, (i) increased water conservation and demand management and (ii) increased wastewater treatment for reclaimed water use, have been determined to be the most promising options for matching Maui potable water demand with supply”

“in an average rainfall year, 30,000 acres of sugar cane in Central Maui cannot be sustainably fully irrigated….

Fully irrigating 23,000 acres of sugar cane (Scenario 2) provides approximately the same total biomass yield as the current practice of partially irrigating 30,000 acres (calibration scenario). Growing cassava and sweet sorghum requires much less water, although the assumption of less water for sweet sorghum corresponds to a relatively low yield for Hawaiian conditions. The 5,850 acres of pasture in Upcountry Maui for intense beef and milk production would require significant irrigation (5 BGY), assumed to come solely from groundwater. The irrigation requirements for 1,000 acres of diversified agriculture are minimal compared to the other crops.”

“Unfortunately, Hawaii’s future might be drier than its past. Rainfall has been experiencing a decreasing trend over the last several decades (see Figure 1), and if this trend continues, there can be significant negative consequences for the Hawaiian Islands”