Comments on Kahului Wastewater Treatment Plant Shoreline Hardening

Sierra Club Maui Group
PO Box 791180, Paia, HI 96779

To: Hawaii State Board of Land and Natural Resources
Kalanimoku Building, 1151 Punchbowl Street
Honolulu, HI 96813

Re: Agenda Item K. CONSERVATION AND COASTAL LANDS: (CDUA) MA-3688

Conservation District Use Application (CDUA) MA-3688 for the Wailuku-Kahului Wastewater Reclamation Facility’s Shoreline Protection Extension by the County of Maui -Department of Environmental Management Located at 281 Amala Place, Kahului, Maui, Portion of Tax Map Key: (2) 3-8-001:188 and Adjacent Submerged Land.

Aloha Board Members and DLNR Staff:

Sierra Club Maui Group, on behalf of its over 600 members in Maui County, asks that the Board of Natural Resources deny the CDUA MA-3688 permit request, or at the very least, defer the matter until Board members have a full understanding of the alternative options available to Maui County.

As guardians of our Public Trust resources, the BLNR has a duty to ensure that wastewater treatment options for the central Maui area comply with the Constitutional mandate to protect Public Trust resources, follow adopted long-range planning guidelines and do not further increase the vulnerability of wastewater facilities to the effects of natural hazards and impacts of rising sea levels.

We urge the BLNR to deny or defer acceptance of this permit application for the following reasons:

1. The planned revetment will adversely affect sand loss on adjacent coastal areas which are already highly prone to erosion.

2. Loss of beaches impacts traditional and customary use of the shoreline as well as the health of offshore reefs and fisheries, when scoured sand is deposited on top of reefs or fills in fishery areas. These are Public Trust resources that the Board is sworn to protect and this action does not comply with that mandate.

3. The revetment will add large boulders along the shoreline that can become dangerous debris in the event of a tsunami. Since the proposed project is in a known and historic tsunami impact zone, this solution to the current erosion problem should not be found acceptable by BLNR.

4. The proposed action is part of a larger action to extend the life cycle of an inefficient, aging treatment facility in a high hazard zone. Alternative actions, such as a proposed inland state-of-the-art Central Maui wastewater facility proposed by private contractors, should have been considered as alternative actions, but were not. More time is needed to make a sound decision.

5. The continued use of the injection wells at the Kahului facility impairs the water quality for ocean recreational users and marine life and the revetment merely extends that use.

6. BLNR should ask the county to come back with a plan that utilizes the reclaimed water to substitute for imported east Maui stream water, rather than spending millions to protect the existing injection wells, thereby solving two problems with sound conservation planning.

7. Further shoreline hardening is discouraged by state and County coastal planners and is contrary to policies in the Countywide Policy Plan, Maui island Plan and Kahului-Wailuku Community Plan.

8. The BLNR as the guardian of our coastal waters should be encouraging Maui County to replace this aging, substandard treatment facility (the only facility on Maui not producing R-1 quality water) with an inland facility on land that is available near the Central Maui landfill, where the sludge is currently transported.

9. The continued costs of defending this poorly sited facility vs the costs of orderly planning for a new public-private inland facility should be clearly revealed, discussed and taken into account by the BLNR in their decision-making.

10. The high hazard coastal site of the present sewage treatment facility would be better suited for future productive harbor-related use, wildlife habitat and coastal park.

11. The existing Kahului treatment plant area is adjacent to critical habitat area (Kanaha Pond and beach park) for the endangered native A’eo (Himantopus Knudseni) , Koloa (Anas Wyvilliana), Coot (Fulica alai) and Blackburn Sphinx moth (Manduca blackburni).

12. High hazard events such as hurricane, flooding, sea level rise or tsunami that affect the treatment plant will drive the sewer effluent into these important habitat areas. The proposed revetment is not likely to protect against any natural hazards except lower wave action, and even then, other forms of temporary wave deflection strategies are likely to have similar benefits and fewer impacts.

Thank you for your consideration of the health of Maui’s Public Trust resources during your decision-making on this item. Denial or deferment of the permit request is the proper action to uphold your responsibility to our resources, held in trust for present and future generations.

Sierra Club Maui Group

Lucienne de Naie, Conservation Chair.