ENVIRONMENTAL ASSESSMENT
for the
Pahala Large Capacity Cesspool (LCC)
Replacement Project
EPA Grant XP-96942401
VOLUME 2: APPENDICES
Pahala, District of Ka'u, County of Hawai'i, Hawai'i
TMK: 9-6-002:018
U.S. Environmental Protection Agency
Region 9
75 Hawthorne Street
San Francisco, California 94105
County of Hawai'i
25 Aupuni Street
Hilo, HI 96720
FINAL
February 2020
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Final EA, Pahala LCC Replacement Project
Pahala, Ka'u District, Hawai'i
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February 2020
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Final EA, Pahala LCC Replacement Project
Pahala, Ka'u District, Hawai'i
Appendix A
Responses to Pre-Assessment Consultation Letters
February 2020
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Final EA, Pahala LCC Replacement Project
Pahala, Ka'u District, Hawai'i
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February 2020
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Earl Matsukawa
Kosfcdo, Vera B OV (US) N«NNiiS' m&wttut
10349-0)
June 22,2018
Ms. Vera Kestketo, Biologist
U.S. Army Corps of Engineers, Honolulu District
Regulatory Branch
Building 230. Room 203
Fort Shatter, HI 96858
Vera,B.Koskelo@usace.army.mil
Subject Draft Environmental Assessment, Pre-Assessment Coosnltatioo;
TOnis Community Large Capacity Cesspool Replacement
prai-au, Ka'u, Hawai'i
Response to Comment (POH-20I8-0068) v
tor Ms. Koskelo:
Thank for ynm April 11, 2018 ootiwh mratagr regarding the County of Hawai'i Department
of Environmental Management PShala Community Large Capacity Cesspool Replacement
project The Draft Environmental Assessment (EA) will contain Information regarding the
project location, including (he extent of the collection system within the right-of-way of County
strew and the wastewater treatment and disposal site. As Med in Die Project Summary, the
proposed treatment and disposal system would occupy about 14 sow and consist of a beadworks
with screens to remove debris and an odor control unit, four lined aerated lagoons of about 0.3
acres each, an operations building with adjacent disinfection system to remove pathogens, an
odor control unit, a subsurface Bow constructed polishing wetland to remove nitrogen and two
(low rate (SRJlaod treatment basins which will be surrounded by banns on all four side.. SR land
treatment involve* irrigatioa of plant material with the treated effluent. Tht Draft EA will provide
descriptions ami drawings related to tec improvements. The County intends to locate the treatment
and disposal site within an ousting macadamia nut orchard that presently contains a surface
mounted irrigation system.
As put of the Draft EA, a biological resources field survey will beennduewd to Identify flora
ami fauna present on the treatment and disposal site and any wetland conditions that may be
present within the site.
1S07 S. BerMmhl Straw!, Suli»400 - Honolulu. Hawaii • M2* • (808)946-2277
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10349-01
Letter to Ms. Vera Koskdo, Biologist
Page2
June 22.2018
We appreciate your participation in the Draft EA process.
Project Manager
cc: D. Beck, DEM
K, Rao, EPA
C. Lekven. PE, BC
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United States Department of the Interior
FISH AND WILDLIFE SERVICE
Pacific Islands Fish and Wildlife Office
300 Ala Mom Boulevard
Honolulu. Hawaii 96850
co:Bc.
Ajjnl »,»IS
In Reply R*fcr To
0IEPtFW-20IS-TA-O2?S
Mr. Earl Matsukaw#, AICP
Project Manager
Wilson Okamoto Corporation
1907 South Beretauia Street. Suite 400
Honolnlu, HI 96826
Subject; Comments for the Draft Environmental Assessment for the County of Hawaii
Department of Environmental Management Pahala Community Large Capacity
Cesspool Replacement. Paauati, Kau, Island and Conwy of Hawaii
Dear Mr. Matsukawa'
The U.S. Fish and Wildlife Service (Service) received your cwrespondwoe on April 9,2018,
requesting technical assistance in the preparation for the Draft Environmental Assessment for the
County of Hawaii Department of Environmental Management Pahala Community Large
Capacity Cesspool (LCC) Replacement in Paauati, Kau. (TMK: 9-6-002:018). The Service
offers the following comments to assist you in your planning process sothat impacts to trust
resources can be avoided through site preparation, construction, and operation,. Ow comments
are provided under the authorities of the Endangered Species Act of 1 TO
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Mr,. Hart Matsukawa
3
pastures, golf courses, wetlands, natural grasslands and shrublands, and lava flows. Threats to the
species include introduced mammalian and avian predators, wind, facilities, and vehicle strikes.
To avoid and minimize potential project impacts to Note we recommend incorporating the
following applicable measures into your project description:
« Do not approach, teed, or disturb News.
• IfNene are observed loafing or foraging within the project area during the Nene breeding
season (September through April), have a biologist familiar with the nesting behavior of
New survey fnr iwsk in nod around the proj«t area prior to the resumption of any work.
Repeal surveys after any subsequent delay of work of three or more days (during which
the birds way attempt to nest),
o Cease all work immediately and contact the Service for further guidance if a
nest is discovered within a radius at" 150 feet of proposed work, or a
previously undiscovered nest is found within said radius alter work begins.
• fa areas where Nene are known to be present, post and implement reduced speed limits,
and inform project personnel and contractors .about the presence of endangered species
on-site.
Hawaiian petrel. Band-ramped storm-petrel, and NeweU's shearwater
Hawaiian.seabirds may traverse the project area at night during the breeding, nesting and
fledging seasons (March I to December 15). Outdoor lighting could result in scabinl
disorientation, fallout and injury or mortality.. Seabirds are attracted to lights and after circling
the lights they may become exhausted and collide with nearby wires, buildings, or other
structure* or they may land on the ground. Downed seabirds ate subject to increased mortality
due to collision with automobiles, starvation, and prcdation by dogs, cats, and other predators.
Young birds (fledglings) traversing the project area between September 15 and December 15. in
their first flights from their mountain nests to the tea. are particularly vulnerable.
To avoid and minimize potential project impacts to seabirds we recommend you incorporate the
following applicable measures into your project description.
• Fully shield all outdoor lights so the bulb can only be seen from below bulb height and
only use when necessary.
• Install automatic motion sensor switches and controls on all outdoor lights or turn off
lights when human activity is not occurring in the lighted area.
• Avoid nighttime construction during the seabird fledging period, September 15 through
December 15.
Hawaiian stilt and Hawaiian coot
Listed Hawaiian waterbirds are found to fresh and brackish-water marshes and natural or man-
made ponds. Hawaiian stilts may also be found wherever ephemeral or persistent standing water
may occur. Threats to these species include non-native predator*, habitat loss, and habitat
degradation.
Based on the project details provided, our information suggests that your project may result in
standing water or the creation of open water, thus attracting Hawaiian waterbirds to the site. In
particular, the Hawaiian stilt is known to nest in sub-optimal locations (e.g. any ponding water).
Mr. Earl Matsukawa
4
if water is present, Hawaiian waterbirds attracted to sub-optimal habitat may suffer adverse
impacts, such as prcdation and reduced reproductive success, and thus the project may create an
attractive nuisance. Therefore, we recommend you work with our office during project planning
so that we may assist you in developing measures to avoid impacts to listed species (e.g,,
fencing, vegetation control, predator management).
To avoid and minimize potential project impacts to Hawaiian waterbirds we recommend you
incorporate the following applicable measures into your project description:
« ln whirr wwerbicd* are known to be present, post and implement reduced speed
limits, and inform project personnel and contractors about the presence of endangered
species on-site.
• If water resources are located within or adjacent to the project site, incorporate applicable
best management practices regarding work in aquatic environments into the project
design.
* Have a biological monitor that is familiar with the species' biology conduct Hawaiian
waterbird neat surveys where appropriate habitat occurs within the vicinity ofthe
proposed project site prior to project initiation. Repeat surveys again within 3 days of
project initiation and after any subsequent delay of work of 3 or more days (during which
the birds may attempt to nest). If a nest or active brood is found:
o Contact the Service within 48 hours for further guidance.
Q Establish and maintain a 100-foot buffer around all active nests and/or broods
until the chicks have fledged. Do not conduct potentially disruptive activities
or habitat alteration within this buffer.
Have a biological monitor that is familiar with the species' biology present on the project site
during all construction or earth moving activities until the chicks fledge to ensure that Hawaiian
waterbirds and nests are not adversely impacted.
Invasive Species
To avoid and minimize the risk of the road construction introducing harmful invasive pests
including enqui. ants, and weeds into the project sites, we recommend the following measures be
implemented by project contractors:
• Vehicles, machinery, and equipment must be thoroughly pressure washed and visibly free
of mud, dirt plant debris, frogs and frog eggs, insects and other debris. A hot water wash
is preferred. Areas of particular concern include bumpers, grills, hood compartments,
areas under the battery, wheel wells, undercarriage, cabs, and truck beds.
* The interior and a terior of vehicles, machinery, and equipment must be free of rubbish
aiai food Tire interiors uf vehicles and the cabs of machinery must be vacuumed clean
Floor mats will be sanitized with a solution of >70% isopropyl alcohol or a freshly mixed
10% bleach solution.
* All work vehicles, machinery, and equipment may be subject to inspection.
« Any vehicles, machinery, and equipment that do not pass inspection will be turned away
• Staging areas must be kept free of invasive pests.
Minimize Spread of Rapid Ohia Death
Rapid Ohia Death (ROD), a newly identified disease, has killed large numbers of mature ohia
trees (Melnaideros polymorphs) in forests and residential areas of Hawaii Island. The disease is
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Mr. Earl Matsukawa
S
caused, by t vascular wilt fungus {Ceraiacys/u Jimbnota), Crowns of an affected tree turn
yellowish or brown within days' to weeks and dead leaves typically remain on branches for .some
time. All ages of ohia trees can be affected' and can have symptoms- of browning of branches or
leaves. As of early 2017 the disease has baas confirmed in all districts except North and South
Kohala. Additional information on ROD can be found at:
http://www2.ctahr.hawaii.edu/fotwtry/downloads/ROD-trifold-03.2016.pdf and
http:,'/www2.ctahr.hawaii.cdii/fbrcstry.'disease/ohia wilt.html.
The following avoidance and minimization measures should he followed for projects working in
ohia forests or at sites- with ohia frees on Hawaii Island:
1) A survey of the proposed project site should be conducted within two weeks prior to any
tree cutting to determine if there are.' amy infected ohia trees. If infected ohia are suspected
at the site, the following agencies should be contacted for further guidance.
*. Service - please contact the name at the bottom of this letter
b. Dr. J B. Friday. University of Hawaii Cooperative Extension Service.
808W69-82S4 m jbfiridayf#haw«i.eclu
c Dr. Flint Hughes. USDA Forest Service, 808-854-2617. ftughes(§tfs.fed.HS
d. Dr. Lisa Keith, USDA Agriculture .Research Service,
$08-959-4157, LiM,Keitl^|ars.usda.gov
2) Both prior to cutting ohia and niter the project is complete:
a. Tools used for cutting infected ohia trees should be cleaned with a 70 percent
rubbing alcohol solution. A freshly prepared 10 percent solution of chlorine
bleach and-water can be used as long as toots are oiled afterwards, as chlorine
bleach wdl corrode metal tools. Chainsaw blades should be brushed clean,
sprayed with cleaning solution, and run briefly to lubricate the chain,
b. Vehicles used off-road in infected forest are® should be thoroughly cleaned. The
tires and undercarriage of the vehicle should be cleaned with detergent if they
have travelled from an ansa with ROD or travelled off-road. Use a pressure
washer with soap to clean all soil off of the tires and vehicle undercarriage
c. Shoes and clothing used in infected forests should also be cleaned. Shoes should
be- decontaminated by dipping the soles in 70 percent' rubbing alcohol to kill the
ROD fungus. Other gear can be sprayed with the same cleaning solutions.
Clothing can be washed in hot water and detergent.
d. Wood of affected ohia trees should, not.be transported to other areas of Hawaii
bland or interisland. All cut wood should be left on-site to avoid spreading the
disease. The! pathogen may remain viable for over a year in dead wood. The
Hawaii Department of Agriculture has passed a quarantine rule that prohibits
interisland movement, except by permit, of'all ohia plant or plant parts.
If this project should receive federal Rinding, federal permit, or any federal authorization, it will
require a Section 7 consultation with the Service. The Service only conducts Section 7
consultations with the federal action agency or their designated representative.
Mr. Earl Matsukawa 6
Thank you for participating with us in the protection of our endangered species. If you have any
further questions or concerns regarding this consultation, please contact: Eldridge Naboa. Pish
and Wildlife Biologist, 803-284-0037, e-mail: eklridte ntibcwfflfWs.«;ov. When referring to this
project, please include this reference number 0IEPIF0Q-2018-TA-O27S.
Sincerely.
Ifini
JWUI oyXXXCMAWW*
(¦"HARCICD*1""-®18**3
wnAKKIfcK^^,,,, w
Jodi Charner
Acting Wind Team Leader
Maui Nut and Hawaii Island
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WILSON OKAMOTO
CORPORATION
•• » I- . • V n' i 2 *
10349-01
August 20,2018
Ms. Jodi Chairier. Acting Team Leader
Maui Nui and Hawaii Island
fish and Wildlife Service
US. Department of the Interior
300 Ala Moan* Boulevard
Room V122, Box 50088
Honolulu, HI 96*50
Attention- BMrtdge Naboa, Fish ami Wildlife Biologist
Subject: Draft Environmental Assessment, Pre-Assessment Consultation;
Pihala Community Large Capacity Cesspool Replacement
Paiiu'au, Ka'Q Ka'u, Hawaii
Response to Comment (O1EPIFO0--2O18-TA-O275)
Dcnr Ms Charrier
'Thank you for your April 23,2018 comment letter (0IEPrF0O-20IX-TA-O27S) and the April 10,
201S e-mail message from Eldridge Naboa regarding the County of Hawat' i Department of
Environmental Management PShala Community Large Capacity Cesspool Replacement project.
As stated in the Project Summary, the PShala Community Large Capacity Cesspool Replacement
project would be funded by an Environmental Protection Agency (EPA) Special Appropriation
Grant and by the Stele of itawai'i Clean Water State Revolving Fund (CSRF) loan program, As
such, we understand consultation will need to be conducted by a federal agency or by a
designated non-federal representative.
On June 7, 2018, EPA .Region 9 Water Division, designated Eastern Research Group, Inc. (ERG)
as the non-federal representative for undertaking the consultation for this project.
As part of the Draft 1A, in August 20 IS, botanical and biological field studies were undertaken
along the streets and adjacent areas of wastewater collection system and at the 14 0 acre
wastewater treatment and disposal facility project site. The results of the field surveys showed
the collection system'Will be instilled along already paved roadways within PShala. They also
revealed that vegetation is located entirely within yards and consist of ornamental plants.
1907 S. Bmtanla Stmt. Stika 400 • Honolulu, Hawaii • 96§2« • |
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!03W-oJ.
STATE OF HAWAII
OEPARTMENT OF HEALTH
SAFE OBWCINB WATER BRANCH
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April 3, 2018
en
Mr Earl Matsukawa. AICP
Project Manager
Wilson Okamoto Corporation
1907 South Beretania Street, Suite 400
Honolulu, Hawaii 96828
Dear Mr, Matsukawa'
f) K If .«¦"( '
1 am ii a»
llSii*E6«*»W"
SUBJECT' DRAFT ENVIRONMENTAL ASSESSMENT (EA). PRE-ASSESSMENT
CONSULTATION FOR PAHALA COMMUNITY LARGE CAPACITY
CESSPOOL REPLACEMENT PAAUAU, KAU. HAWAII
The Safe Drinking Water Branch (SDWB) lias iBviawwi yuui Matuli 15, 2018 request
for comments as part of the Draft EA pre-assessmeot consultation for the subject
project.
The project is located above the Underground Injection Control (UIC) line. Areas above
the UIC line are considered to be on top of underground sources of drinking water.
Sewage injection wells are not allowed to be constructed above the UIC line. There is
an existing drinking water well located' approximately one (1) mite mauka of the
proposed wastewater disposal and treatment site. In consideration of the project's
location and situation, wastewater disposal by (and application appears to to a very
sensible proposal.
If you have any questions regarding this response, please contact Mr. Norns Uehara,
Supervisor of the Safe Drinking Water Branch UtC program at 586-4258.
Sincerely.
jU £.i>-
JOANNA I- SETO. PE , CHIEF
Safe Drinking Water Branch
NUcb
WILSON OKAMOTO
CORPORATION
INROVMC RS .
10349-01
June 21,2018
Ms. Jam Seto. Branch Chief
tote of Hawaii
Department of Health
Safe Drinking Water Branch
2385 Wuraano Home Road
Pearl City, HI 96782
Attention: Norris Uehara
Subject; Draft Environmental Assessment. Pre-Assessment Consultation;
PUtala Community Large Capacity Cesspool Replacement
Pi'aa'au, Ka*u, Hawgfi
Response to Comment
Dew Ms. Seto;
Think for your April 3,2018 comment fatter (SOWS Pitata LLC Replacement) regarding the
County of Hawai'i Department of Environmental Management PShala Community Large
Capacity Cesspool Replacement project.
The Draft Environmental Assessment (EA) will describe the project as located above the
Underground Injection Control (UtC) tine and, at such, will overlie underground sources of
drinking water. Farther, an existing drinking water well is located shoot 1 wile mauka of the
treatment and disposal site. Lastly, the Draft EA will include that the project's disposal by slow
land application is a very sensible proposal,
Thank yew for your participation in the Draft EA process.
Sincerely.
Matsukawa, AICP
Project Manager
«: D. Beck, DEM
K. Rao, EPA
C. Lekven, PE. BC
ISO? S. BwManta Street. Suits 400 • Honolulu. Hawaii • 3C826 • (SOS) 846-2277
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STATE OF HAW*
DEPARTMENT OF HEALTH
MhSOXSHS
HONOiuuiiHiieBm'SNft SP01&082
April 3,2018
Mr Earl Matsufcawa, AICP
WHSOfi URamoto uOipormKm
1907 S. tetania Street, Site 400 UH APR 0 9 201
Honolulu. Kiwi 96826
Qogf |ty. MaiSUKfiWai
lesifi
MtSB tfttfflty UBflSMlti
SUBJECT: Pre-Assessment Consultation Draft Environmental Assessment (PAC DEA) tor PahBln
Community f fliry* OffftHffiy CfriifHKri ftftpfMfl'BHfflt, Ksti. ttewtiff
The Department ol Hei8h (DOH), Environmental Planning Mm (EPO), actaawtedgss receipt of your PAC DEA to
OUI ofhee Oft Mao 20.2018
We undersland (mm the project summary thai V* flateto Community large Cajjaefly Casspoof Qosm pm/ecl
improvements would consist of a new wtimatar cotteKw s0m tocaW ftepuMe nprnhtay amia
treatment ami cfeposaJ system located on a currently privately-ometi parcel (TMK: 9-6-002 019} wftfch HOT to
aa/und by the County."
Hawaffs environmental review laws require Environmental Assessments (EM) and Environmsntai impac
Statements (EISs) to consider heallhinthe discussion and to mitigation measures to reduce negative impacts. In its
tMNfen of Impacts/ §11-200-2, Havttl AdmMstatwB Rute (HAR) includes health effects, whether ptfiwry
(dnd), saoondaiy (iMfctei), or ojmuWw. flatter, §11-200-12(b)(5), HAR, Us pubic hsilth as one of the oftena
for determining whether an action may nave a significant unpad on the ©svirottmsni
In the development and imptenentalion of all prqMs, EPO strongly recommends regular iwlewof State and
Foderal environmental health tond use guidance. Sal® stamtenl comments to support sustainable healthy design
at® provided at: wip:;;in;aMh„>Bwali.ooi^witrtawtoa. Pretests aw required to adhere to all applicable standard
EPO also encourages you lo examine and utilize the Hawaii Environmental Health Portal at: tite^aha-
doud.doh.liawail.iw, This site provides links to cur e-Perrnittmg Portal, Environmental Heallh Warehouse.
£3rounr^ster OoniiirninaNfM'i Viewer, Hawaii Frrw/fjfincy Regions;? Exchange, Hawaii Sis is 3nd Local Emission
fiitiwifcrtg.. f*. Mr, —* A, iaKm. ?"»,*.•.*, m nil, i a nr-, linpBtnni
inventory oysieni, waief poiuaton control vHswer, water Qualify usia, warnings, Aavtsoiiss ana posiircgs,
o
We suggest you mm the requirements of the Ctaen Water Branch (Hawaii AdnWstwftw Rules (HAR), Chapter
11-64-1.1, -3,4-8) amttif B» National Pollutant Discharge Elminalion System PP0ES} pem# (HAR, Chapter 11-
55) al: httorf/hea»h.hawaioovterti. II you ha*e any quasttetw, please contact #» Clean Water Starch (CW8),
Enomeenna Section at 18081SB6-4309 or claanwateroianch'y doft.hawag.aov. If your pnojact involves waters o! the
U.S., it is IngMy recommended that you contact the Army Corps of Engineers, Regulatory Branch at: (808) 835-4303.
Please note that all wastewater plains roust content! to applicable provisions (HAR, Chapter 11 *62, "Wastewater
Systems"). We reserve the right to review the detailed wastewater plans tof conformance to applicable rules. Should
Mr. Earl Mataukawa, AICP
F*HQ® 2
April 3.2018
you have any questions, please review online gutfcKa at: WB»lia3lti.»ia»aii.ua">.vsinvaier and contact the
Planning and Design Section of the Wastewater Branch (WWB) at (808) W-«,
II temporary futftm dusl wwsstons could to totted when Ifmumjeet ait# • prepared tor cowliwfion antfor vrhen
constwdion cMIh occur, m rw»«m«»d jw iwim ft# need andfer requnnenh tor a aaan Wr Branch (CAB)
pemiit (HAR, Gltt^er 11 ¦«. 1 "Air PoliHtai CMHraT). Effective air oolution control measure* need to be provided to
ptevew or winimfte any fugitive dust amissions caused by construction wo* from affecting the surrountog areas.
This fcdudis fta oil-site madis-aysuseiJ lo wteifexit fa prajcol The cwliot metsures could indude.but are not
llwlled to, I* we ol we«er wajtms, sprmWer systems, and dust tews. For qrations contact the Oean Air Branch
*la e-mal * CaMaieaWtbhiiawat.gov or call (808) 588-4200.
Any waste genooted by the polect (tot is nol a hazaiOouswastt as dellwd In stale hazaidous waste laws and
regulations), needs to 1* disposed ot at» soHd waste management hefty that comptes with the applicable
pwisians (HAR, Chapter 11-5B.1 "Solid Waste Management Control"). The open burning of any of these wastes, on
orolfstti, fe strictly proNbtted. You may wish you review (he MrtmBng Constmaion & OemoWon Waste
Management Guide * Additional Monoamn s
aeeessbleal: hap.-'heeth rawi novsrwiti. For specie qwttons all (808) 586-4228,
If noise created dunngt* construction phase of the project may exceed tte maximum allowable levels (HAR.
QiifMer 11-46. "Community Noise ControT) then t note permit my be laqumd and needs to be oferad below
the comrnencemeni ol worti RelewW informality! Is online at tHtp' htalln ta.vjn aa».»r>ti noise EPO recommends
pucofflaa the indoor and Radiological Heallh Branch (IRHB) al (808) 68B-47M w toed on na&naly conasient
data arrtcoirtjrws swironmantt ami demographic Wfcators In naps and reports. ETO tnawr^es.yw to
ejplwft launch awl utii» Ihis powerful tool in planning your prated The EPA EJSCREEN tort is awllabteal;
httB'./'wiirw.epa.aBWBiscMM.
SVa hope this rtomatoi Is helptol It you have any questions pleas# contact us al DOH.ei»8doh.hawaii.novor eal
us at (808) 5864337, Ttiank you for Bis opportunity to comment
Mahalonuilw,
"'Laura lelatota WBps Mdntyw, AICP
Environmental Planning Office
LMirm
c DOH: DUO HI, WIS {via etna# only)
Attachment: U,& EPA EJSCREEN Report to Project Area
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WILSON OKAMOTQ
CORPORATION
l«IOVMO«>. HUMINE** .CNGIMfm
10349-01
Juoe21,2018
Ms. Laura Leialoha Phillips Mclntyre, A1CP
Environmental Planning Office
State of Hawaii Department of Health
P.O. Box 3378
Honolulu, Hawaii 96813
Subject: Draft Environmental Assessment, Pre-Asgessroent Consultation;
P&hala Community L#rge Capacity Cesspool Replacemem
PTau'au, Ka'u, Hawai'i
Response to Continent
Dear Ms. Mclntyre:
Thank you for your April 3,2018 comment letter (EPO 18-082) regarding the County of Hawai'i
Department of Environmental Management FShala Community Large Capacity Cesspool
Replacement project The Draft Environmental Assessment (EA) will be prepared to in
accordance with the requirements of Chapter 343, KRS, as amended, and Hawai'i
Administrative Rules (HAR) Title 11, State of Hawai'i Depanmeot of Health, Chapter 200,
Environmental Impact Statement Rules, including an assessment according to HAR §11-200-
I2«CS}.
The Draft EA will include a discussion of surface waters and erosion control measures related to
construction storm water runofT. as may be required for a National Pollutant Discharge
Elimination System (NPDES) permit. Also, the Draft EA will include a discussion of surface
water sources in the area and potential discharge to waters of the U.S.
As pan of the project description, the Draft EA will note the wastewater treatment plant must
conform to applicable provisions (HAR, Chapter 11-62, "Wastewater Systems").
With respect to air quality, the Draft EA will discuss fugitive dust emissions and potential
measures to mitigate emissions during construction activities and from the emergency generator
in relation to the requireotenls of HAR, Chapter J 1-60.1 "Air Pollution Control." Hazardous
waste will be discussed in relation to construction activities and the applicable provisions (HAR,
Chapter 11-58.1 "Solid Waste Management Control"). The Draft EA will elate the open burning
of any of these wastes, on or off site, is strictly prohibited.
19UT 8. BeratMts Street, SuttB 400 * Honolulu. Hawaii. 868% • (608) S4MW7
10349-01
Letter to Ms. Laura Leialoha Phillips Mclntyre, A1CP
Page 2
June 21. 2018
An analysis of noise created during the construction will also be included in the Draft EA.
As noted in Use Project Summary, the Pahala Community Large Capacity Cesspool Replacement
project would be feudal by an EPA Special Appropriation Giant and by the State of Hawai'i
Clean Water State Revolving Fund (SRJF) loan program As such, the Draft EA will include on
environmental justice (El) discussion on the PShsta community.
We appreciate your participation in the Draft EA process.
Sincerely,
Matsukawa. AlCP
Project Manager
ec: D. Beck, DEM
K. Rao, EPA
C. Lekven, PE. BC
-------
SiPis i
AFS fij
(ffiSp
W*"
•wrWWiw
co'eo
OMb
STATE OF HAWAII
DEPARTMENT OF HEALTH
P.ttUlWWt
HMMIttMU
April 4,2018
04007CEC 18
Mr. Ear! Matsukawa
Project Manager
Wilson Okamoto Corporation
1907 S. Beretania Street, Suite 400
Honolulu, Hawaii 96826
Dear Mr, Matsukawa
SUBJECT: Pre-Assessment Consultation Comments on
Patiata Community Large Capacity Cesspool Replacement
Paauau, Kau, Hawaii
The Department of Health (DOH), Clean Water Branch (CWB), acknowledges receipt of
your tetter dated March 15,2018, requesting oomments on subject County of Hawaii
(COH). Department of Environmental Management (DEM) proposed project The
DOH-CWB has reviewed the subject document and often these comments. Please
note that our review Is based solely on the information provided In the subject document
and Its compliance with the Hawaii Administrative Rules (HAR). emptors 11-54 and
11-55 The City and County of Honolulu, Department of Environmental Services
(Applicant) may be responsible tor fulfilling additional requirements related to our
program. We recommend that you also read our standard comments on our website at
htto//health. hawan.oov/epo/tiles/20t3/05/C>can-WatBr-Bran ch-Std-Commenta.pdf
A. General Comments
1. Any project and its potential impacts to State waters must meet the following
criteria:
a. Antldegradaion policy {HAR, Section 11 -54-1.1), which requires that tie
existing uses and the level of water quality necessary to protect the existing
uses of the receiving State water be maintained and protected.
b Designated uses (HAR, Section 11-54-3), as determined by the classification
of the receiving State waters.
c. Water quality criteria (HAR. Sections 11-54-4 through 11-54-8)
Mr. Eart Matsukawa 04007CEC 18
Apnl 4, 2018
Page 2
2. The COH-DEM may be required to obtain National Pollutant Discharge Eliminate*
System (NPDES) permit coverage for discharges of wastewater, including storm
water runoff, into State surface waters (HAR, Chapter 11-55). For NPDES general
permit coverage, a Notice of Intent (NO!) form must be submitted at least
30 calendar days before the commencement of the discharge. An application for
an NPDES individual permit must be submitted at least 180 calendar days before
the commencement of the discharge. To request NPDES permit coverage, you
must submit the applicable form fCWB Individual NPDES Form* or "CWB NOI
Form! through the e-Permitting Portal and the hard copy certification statement
with the respective filing tee ($1,000 for an individual NPDES permit or $500 tor a
Notice of General Permit Coverage), Please open the e-Permitting Portal website
located at https://eha-cloud.doh,hawaii.gov/epermit/. You will be asked to do a
one-time registration to obtain your login and password. Alter you register, didc on
'he Application Finder toot and locate the appropriate form. Follow the instructions
to complete and submit tie form.
3. If COH-DEM project involves wo* in. over, or tinder waws of the United State,
it Is highly recommended that they contact tie Army Corp of Engineers,
Regulatory Branch (Tel: 835-4303) regarding their permitting requirements.
Pursuant to Federal Water Pollution Control Act [commonly known as the "Clean
Water Act" (CWA)], Paragraph 401(a)(1), a Section 401 Water Quality
Certification (WQC) is required for *[a}ny applicant for Federal license or permit to
conduct any activity including, but not limited to, the construction or operation of
facilities, which may result in any discharge iftto the navigable waters...*
(emphasis added). The term discharge* is defined in CWA, Subsections 502(16),
502(12), and 502(6); Title 40 of the Code of Federal Regulations (CFR),
Section 122,2; and Hawaii Administrative Rules (HAR), Chapter 11-54.
4. Please note, that all discharges related to the project construction and/or
operation aetivites, whether or not NPDES permit average and/or Section 401
WQC are required, must comply with the Stele's Water Quality Standards
(WQS). Noncompliance with water qualify requirements, contained in HAR,
Chapter 11 -54, and/or permitting requirements, specified in HAR, Chapter 11 -55,
may be subject to penalties of $25,000 per day per violation.
5. It is aw State's position that ail projects must reduce, reuse, and recycle to
protect, restore, and sustain water quality and beneficial uses of State waters.
Project planning should:
a. Treat storm water as a resource to be protected by integrating it into project
planning and permitting. Storm water has long been recognized as a source
-------
Mr Eari Matsukawa 04007CEC.18
April 4, 2018
Page 3
of irrigation that will not deplete potable water resources. What is often
overlooked Is that storm water recharges ground water supplies and feeds
streams and estuaries; to ensure that these water cycles, are not disrupted,
storm water cannot be relegated as a waste product of Impervious surfaces.
Any project planning must recognize storm water as an asset that sustains
and protects natural ecosystems and traditional beneficial uses of State
waters, like community beauMcation, beat* going, swimming, and fishing,
The approaches necessary to do so, including low impact development
methods or ecological bio-engineering of drainage ways must be Identified in
the planning stages to allow designers opportunity to Include those
approaches up front, prior to seeking zoning, construction or building permits.
to. Clearly articulate the State's position on water Quality and the beneficial uses
of State waters. The plan should include statements regarding the
implementation of methods to conserve natural resources (e.g., minimizing
potable water for irrigation, gray water re-use options, energy conservation
through smart design) and improve water quality,
c. Consider storm water Best Management Practice (BMP) approaches that
minimize the use of potable water for Irrigation through storm water storage
and reuse, percolate storm water to recharge groundwater to revitalize natural
hydrology, and treat storm water which is to be discharged
d. Consider the use of green building practices, such as pervious pavement and
landscaping with native vegetation, to Improve water quality by reducing
excessive runoff and the need for excessive fertilization, respectively,
e. Identify opportunities for retrofitting or bio-engineering existing storm water
infrastructure to restore ecological function while maintaining, or even
enhancing, hydraulic capacity. Particular considerafion should be given to areas
prone to flooding, or where the infrastructure is aged and will need to be
¦wkMktlMiMfaui'
renaDjiiiaieo
Mr. Earl Matsukawa 04007CEC 18
April 4,2018
Page 4
If you haw any questions, please visit our website at htto://health hawaii oov/ewb. or
contact the Engineering Section. CWB, at (808) 588-4309.
Sincerely.
ALEC WONG, P E„ CHIEF
Clean Water Branch
EC:ak
-------
WILSON OKAMOTO
CORPORATION
¦ NNOftrOIS -t>U««(l>S. l«milD
10349-01
June 21,2018
Mr. Alec Wong, P,E» Chief, Clean Wur Branch
State of Hawai'i
Department of Health
Clean Water Branch
P O Box 3378
Honolulu, Mt 96801
Subject: Draft Environmental Assessment. Pre-Assessment Consultation;
Pahala Community Largs Capacity Cesspool Replacement
P®*a»'au, Ka'u, Hawai'i
Response to Comment
Dear Mr. Wong;
Thank you for your April 4.2018 comment letter (04007CEC. 18) regarding the County of
Hawal't Department ofEmtranmemal Management Pihal* Community Urge Capacity
Cesspool Replacement project. The Draft Environmental Assessment (EA) will be prepared to
in accordance with the requirements of Chapter 343, HRS. as amended, and Hawai'i
Administrative Ruka (HAR) Title 11, State of Hawaii Department of Health, Chapter 200,
Environmental Impact Statement (tales, including an assessment according to HAR § 11 -200-
!2
-------
STATE OF HAWAII
DEPARTMENT OF HEALTH
peso* aw
moau hi ¦*>.»!
April 10.2018
Mr. Earl Matsukawa. AICP
Project WanaQ&r
Wilson Okamoto Corporation
1907 South Berstania Street. Suite 400
Honolulu, Hawaii96828
. *n ^
lUD-3 9 6«J2GtB
DEA Pmm Commurahr-iDS98«
'cH/
I!)
Dear Mi Mstsuisawa
Subject: Draft Environmental Assessment Fre-Assessment Consultation
Rahata Community Large Capacity Cesspool Replacement
Paauau. Kau. Hawaii TMK (3) 9-6-002; 013
Request tor Comment
Thank you for allowing us the opportunity to provide comments for the subject protect.
The subject project wit! be funded by the Hawaii Clean Water State Revolving Fund (CWSRF)
Program tn order to comply with the Hawaii CWSRF Program requirements, the environmental
assessment must address all applicable. Federal environmental 'cross-cutting' authorities which
can be found in the Hawaii State Environmental Review Process document
Please be Wormed that the proposed wastewater systems far the community may have to include
design considerations to address any effects associated with the construction of and/or discharges
torn t» wastewater systems to any pubic trust, Native Hawaiian resources or the exercise of
traditional cultural practices In addition, all wastewater plans must conform to applicable
provisions of the Hawaii Administrative Rules Chapter 11-62, "Wastewater Systems."
Should you have any questions, please call Mr. Mailt Tomomitsu at 566-4294,
Sincerely,
StNA PRUDER, P.E., CHIEF
Wastewater Branch
LMMSMm
Ms tmm IfeMstm, OOH-EKX
Mt AnyCott.OOHWMniHtoSufti'Mamal
Mt OMW mmnM. ocm-WMBt Km a* Kit enwi
WILSON OKAMOTO
CORPORATION
maoynrgii ¦ pi.an*w».
10349-01
June 22,2018
Ms. Sina Pruder, Branch Chief
Wastewater Brunch
State of Hawai'i
DcpmUuoil of Health
2827 Wutnaao Home Road
Pearl City. lfl 96782
Subject; Draft Environmental Assessment, Pre-Assessment Consultation,
Pahala Communis Large Capacity Cesspool Replacement
PTau'au, Ka'u, Hawai'i
Response to Comment
Dear Ms, Proder.
Thank you far your April 10,2018 comment letter (LUM96002 18) regarding the County of
Hawai'i Department of EnviratuaenUl Management Mala Community Large Capacity
Cesspool Replacement project Hie Draft Environmental Assessment (EA) will confirm that the
project will use funds from the Hawaii Clean Water State Revolving Find (CWSRF) project and
will include to various "cross cutter" authorities requited as part of the Sate Environmental
Review Process (SERP).
An archaeological inventory of survey will be conducted fir the project and will include
consultation with various governmental agencies, Native Hawaiian Organizations and interested
parties to identify the concerns related to the project.
Lastly, the Draft EA will sate the design of the collection system and the wastewater treatment
and disposal system meets the requirements of Hawai'i Administrative Rules, Chapter 11-42.
We appreciate your participation in the Draft EA process.
Project Manager
ee: D. Beck, OEM
K. Rao, EPA
C. Lekven,PE,BC
190? 8. Berolania Street* MM 400 • Honolulu. Hawaii • 96826 • («•*) 9*8-2277
-------
OFFICE OF PLANNING
STATE OF HAWAII
.. APR is ?m I ##
..bii.lWoiUiitH.Uii'iMtffil 0S
, w
tfQUABUWOON
23S South 8aw«trt»
Street, 8M> Floor, Honolulu, Hawaii 96813
P.O. Bo* 2359. Honolulu, Hawaii 96804
&
fnw,
W#6* Ktji>!//pl«niN|^h**mt,(j9v<
OTS201804051430RI
April 5.2018
Mr,, Earl Matsulcawa. AICP
Project Manager
Wilson Okaniote Corporation
19(17 S. Beretania Street, Suite 400
Honolulu, Hawaii Y6S26
Dear Mr. Matsukawa:
Subject: Draft Environmental Assessment. Pre-Assessment Consultation; Pahala
Community Large Capacity Cesspool Replacement, Paauau, Kau, Hawaii,
TMK: (3)9-6-002:018
Thank you for the opportunity to provide comments on the pre-consultation request for
the (separation of a Draft Environmental Assessment (Draft EA) on the Pahala Community
cesspool leptaccment ptoject. The pre-conjultatran review material was transmitted to our office
via letter dated March 15, 2018.
It is our understanding that the County of Hawaii Department of Environmental
Management (DEM) proposes the construction of a wastewater collection and treatment system
to replace the current large capacity cesspools thai currently serve the residents of Pahala. The
new wastewater collection system would comply with U.S. Environmental Protection Agency
(EPA) regulations. The new wastewater system 'would also meet State Department of Health
guidelines for the collection, treatment, and disposal of treated effluent.
The site for the proposed wastewater treatment system is currently used to grow
macadam>a nut trees. The trees will be removed and the area cleared for the installation of the
system The wastewater system would consist of 11,000 linear feet of gravity How piping on 14
acres of land. It will include headwords with screens to remove debris, an odor control unit,
lined aerated lagoons, an operations building with a disinfection system to remove pathogens, a
stow Bow rate land treatment tasm„an
-------
Mr, Earl Matsukawa, AICP
Frojeci Manager
April 5, >01*
PigeJ
Please consult with the Counly of Hawaii, Department of Planning on lite need for a
Special Permit for this project on. approximately 14 acrc*.
Pursuani to HAR § 11 -200-10(6) - identifieaticM awl summary of impacts awl
alternatives considered; to ensure that the surface water and nearshore marine
resources near the coastal arc* of the Kau District remain protected, the negative
ctlccis of stormwater inundation from this cesspool closure and wastewatersystem
construction anion should he evaluated in the Draft EA.
Issues that may be examined include, but are not limited to, project- site' characteristics
in relation to flood and erosion prone areas, potential vulnerability of surface water
resources, soil absorption characteristics or the area, risk of effluent seepage, and
examining the amount of permeable versus impervious surfaces in the area.
Developing mitigation measures for the protection for surface water resources and the
coastal ecosystem should take this into account, pursuant to HAR § 11 -200-10(7).
To assist in Ihe development of storm water runoff strategies, OP has developed,
guidance documents on this subject. We recommend consulting these stormwater
evaluative tools when developing mitigation approaches for polluted runoff They
offer useful techniques to keep land-based pollutants and sediment in ptece, white
considering the management practices best, suited for the topography of the area and
the types of contaminants potentially affecting nearby water resource*, The
evaluative tools that- should he used during the design process include:
• Hawaii Watershed Guidance provides direction on mitigation strategies for
urban-development activities that will safeguard watersheds and implement
watershed plans totp;//fiies.hawaiigov/dbcdt/op/eMi/taMative/nonpoint/HT
'Watershed Guidance 'PinaLpdf
• Siormwater Impact Assessments can he used to identify and analyze
information on hydrology, sensitivity of coastal and riparian resources, aid
management measures to control runoff, as well as consider secondary and
cumulative impacts to the area.
http://files,hawaii.gov/db«dt/op/c»«j/mitiBtivc/storowiterJniapct/ftnal_stomi
waterjmpact_assessments__guidance.pdf
• Low Impact Development (1.113). A Practitioners Guide covers a range of
structural BMPs for stormwaier control management, onsite infiltration
techniques, aid water reuse methods that minimize negative environmental
Mr. Earl Matsukawa, AIC?
Project Manager
April 5, MIS
Page 4
impacts. tttp;//Bles.hawaii.gov/dbedt/op/caii/initiative/lld/lid jsukie 2006.pdf
If you hive any questions regarding this comment letter, please contact Joshua itekexta
of our office at (SOS) 5*7-2X45.
Sincerely.
1-eo R. Asuncion
Director
-------
WILSON OKAMOTO
CORPORATION
10349-01
Jfune 21,2018
Mr, Leo Asuncion, Director
State of Hawai'i
IX-partment of Business, Economic Development and TouHsn
utiice of r tanning
PO Box 2359
Honolulu. Hi 96804
Attention; Joshua Hetoekia
Subject- Draft Environmental Assessment, Prc-Assessment Consultation;
PShala Community Large Capacity Cesspool Replacement
Pi'au'an, Ka'u, Hawai'i
Response to Comment
Dear Mr. Asuncion:
Thank you for your April S, 2018 comment letter (DTS2018040SI430RI) regarding the County
of Hawaii Department of Enviromnenlal Management Patala Community Large Capacity
Cesspool RepiaceoieM project The Dnft Environmental Assessment (EA) will be prepared to
in accordance with the requirements of Chapter 343, HRS, as amended, and Hawaii
Administrative Rules (HAR) Title 11, State of Hawai'i Department of Health, Chapter 200.
Environmental Impact Statement Rules, including an assessment according to (HAR) § 11-200-
10(4)
The Draft EA will include a discussion on the project's consistency with the Chapter 226,
HRS, as amended.
The Draft EA will include a discussion on the project's consistency with Statewide
sustoinability goals.
3. Obfectives and Policies of the Hawai'i Coastal Zone Management tCZM) Program.
As stated above, the Draft EA will be prepared to in accordance with the requirements of
Chapter 343, HRS, as amended, and Hawai'i Administrative Rules (HAR) Title 11, State
of Hawai'i Department of Health, Chapter 200, Environmental Impact Statement Rules
which includes an assessment as project's conformance to each of (he goals aid
objectives as listed in Chapter 20SA-2, HRS.
1907 S.
Street,
400 . Honolulu, Hawaii ¦ 96BXC • (S08! 946-2277
10349-01
Letter to Mr. Leo Asuocio*
Page 2
June 21,2018
4 State Land Use Agriculture District Permitted Uses.
The Draft EA will note the approximately 14.9-acre treatment and disposal project
site is within the State Land Use Agricultural District and the project will require
approval of a Special Use Permit from the County of Hawai'i Windward Planning
Commission.
3. Stormwater Runoff. Erosion, and Water Resources.
As stated above, the Draft EA will be prepared to in accordance with the requirements of
Chapter343, HRS, as anmded, and Hawai'i Administrative Rules (HAR) Title 11, State
of Hawai'i Department of Health, Chapter 200, Environmental Impact Statement Rules,
which includes discussion of impacts to surface water sources, the effect of tain evens on
the project and the amount of impervious surfeces created by the pmject.
We appreciate your participation to the Draft EA process.
Sincerely,
fl i
rfeaii Maeukawa, A1CP
Project Manager
cc; D. Beck, DEM
K. Rao, EPA
C, Lekven, PE, BC
-------
.a-
!.£Si
STATE OK HAWAII
DEPARTMENT Of HAWAIIAN HOME LAUDS
EM
March 27, 2018
|§f iflf 1
WAR 2 'J ?0U
Attention: Earl Matsukawa, AICP .i:ii«S«!ttatJiiiUi!3%iSUIJ*
Wilson Otamoto corporation
1907 South Beretania Street, Suite 400
Honolulu, Hawaii 96826
Dear Mr. Hatsukawa:
Subject: Draft Environmental Assessment, Pre-Anne* eaten t
Consultations Pahala Community Large Capacity
Cesspool Replacementi Paauaw, Kau. Hawaii
Request for Comment
The Department of Hawaiian Home Lands acknowledges receiving
the request Cor comments on the above-cited project. After
reviewing the materials submitted, due to its lack of proximity
to Hawaiian Home Lands, we do not anticipate any impacts to our
lands or beneficiaries from the project.
However, we highly encourage all agencies to consult with
Hawaiian Homestead community associations and other (Hlnative
Hawaiian organizations when preparing environmental assessments
in order to better assess potential impacts to cultural and
natural resources, access and other rights of native Hawaiians.
Hahalo for the opportunity to provide comments. I£ you have
any questions, please call Rae too Hyatt, at 620-9480 or contact
via email at raeann.n.hvattflhawa i1.gov,
Sincerely,
M. Kaleo Manual
Acting Planning Program Manager
WILSON OKAMOTO
CORPORATION
l»NOV*IO»i. »1ANI1(«S. IB6INIMS
10349-01
June 21,2018
Mr. M. Ksleo Mcoud, Acting Planning Program Manager
Slate of Hawaii
Department of Hawaiian Hook Lands
P.O.Box 1879
Honolulu, HI 9680S
Attention: Roe Ann Hyatt
Subject: Drift Environmental Assessment, Pre-Assessment Consultation;
Pttata Community Large Capacity Cesspool Replacement
Pi'aifau, Ka'u, Hawai'i
Response t» Comment
Dor Mr, Manuel:
Thank you foe your Match 27,20J8 comment letter regarding (be County of Hawai'i Department
of Environmental Management Pahala Community Large Capacity Cesspool Replacement
project. The Draft Environmental Assessment (EA)will note that due to the project's tack of
proximity to Hawaiian Home lands, the Department of Hawaiian Home Lands does not
anticipate any impacts to its lands or beneficiaries ten the project
As noted in the Project Summary, the Plhala Community large Capacity Cesspool Replacement
project would be fancied by an EPA Special Appropriation Grant and by the Stale of Hawai'i
Clean Water State Revolving Fund fSRF) loan program. As such, the Draft EA, will include
consultation with Hswaiiaa Homestead community associations and other Native Hawaiian
organizations to better assess potential impacts to cultural and natural resources, access and other
rights of Native Hawaiian.
We appreciate your participation in the Draft EA process.
Sincerely,
a-
1 Matsukawa, AiCP
Project Manager
D. Beck. DEM
It Rao, EPA
C.Lekven,PB,BC
1907 S. Berotania Straw, Suits 400 • Honolulu. Hawaii - 36626 ¦ (808) 946-2277
-------
#
( / MM
miMrmMVAU
C4- BC-
STATE OF HAWAII
IJWAItTMBtVT Of LA NO AND NATURAL WBWtJHCBS
UM»MVMKW
KSTomceiioMJt
HONOLULU, HAWAII ¦«*»
AprS 18.2018
Wilson Okamoto Corporation
Attention: Mr. Eart Matsukawa, AICP via email: wocewitsonokamoto.com
1907 South Beretania Street, Suite 400
Honolulu, Hawaii 96826
Dear Mr. Matsukawa:
SUBJECT Pte-Assessment Consultation tor Draft Environmental Assessment for the
Pahata Community Large Capacity Cesspool Replacement Project
located at PaWau, Ka'u, islando( Hawaii: within the Public Right-of-Way
and TMK (3)9-64)02:018
Thank you for the opportunity to review and comment on the subject matter. The
Department of Land and Natural Resources' (DLNR) Land Division distributed or mads
available a copy of your report pertaining to the subject matter to DLNR Divisions tor their
review and comments.
At this time, enclosed are comments from the (a) Engineering Division and (b) Land
Division - Hawaii District on the subject matter.. Should you have any questions, please feel
free to call Darlene Natamura at (80S) 587-0417. Thank you.
Sincerely,
RUS908Y.TSU|I
Land Administrator
CmrfosHjftt
c
-------
DEPARTMENT OF LAND .AND NATURAL RESOURCES
ENGINEERING DIVISION
LD/Rusxci] Y. Tmjl
Ref: Pre-Aucsmrat Consultation tor Drift Environmental AiraiDoil for the
I'uhula Community Large Capacity Cesspool Replacement Project,
P«'«"'»U, Ka'u, Island of Hawaii; Within the Public Right-of-way and
TMK: (3)9-6-M2:«18
COMMENTS
The rules and regulations or the National Flood Insurance Program (NK1P), Title 44 of
the Code of Federal Regulations (44CFR), are in effect when development falls within a
Special Flood Itasart Area (high risk ureas), State projects are required to comply with
44CFR regulations as stipulated in Section 60,12. Be advised that 44CPR reflects the
minimum standards as set forth by the' NFIP Local community flood ordinances may
stipulate higher standards that can be more restrictive and would take precedence over the
minimum NFIP standards.
IT* owner of the project properly and/or their representative is responsible to research
the Flood Hazard Zone designation for the project, Flood Hazard Zones are designated
on FEMA's Flood Insurance Rate Maps (FIRM), which can be viewed on our Flood
1 hard Assessment Tool (PI IAT) (http://gis.hawaunfip.or8/FHAT}.
If there are questions regarding the local flood ordinances, please contact the applicable
County NPIP coordinating agency below;
o ftte'City and County of Honolulu, Department of Planning and Permitting
(80S) 76X-8098.
a ilesvaiilsjflfid: County of Hawaii, Department of Public Works (SOS) 961-8327.
o Maui/Molototi/l;an«l County of Maui, Department of Planning (808) 270-7253.
o Kauai: County of Kauai, Department of Public Works (SOS) 241-4846.
«lb
WW* RECEJVEB
; AND OfVISWH
#» aih* uii
18 APR 13
«?l OPH
WBftAl RE
118 APR 13 AH £36
STATE OF HAWAII MM MR 90 o n- no
. I 0 PqgKWSJBOT OF LAND AND NATOKAI., HESOUKCES " £1 ^ «" UH
jm,
rwtvrrivfiowAW unnu iliiiSiU
honouhuhawad «oce H1L0. HAWAII
March 27,2018
DLNH Agencies:
Dl«. of Aquatic Resnms
_0lv. of Boating & Ocean Recreation
JLEnglowring Division
_Dlv. of Forestry & Wildlife
_J»», of State Partes
JCCommlsalon on Water Resource Management
Office of Conservation & Coastal Lands
_&JLand Division - Hawaii District
V f H I mli 1 f%, nnn imltin.i.
A nlaWriC t froafliVnuOfl
r
-PffoM: /tWsseTY. Tsu)l, Laid Administrator
SUBJECT: f Pra-Asssssmeitt CansultaMon for Draft Environmental Assessment for the
LOCATION; Pa'au'au, Ka'u, island of Hawaii; Within the Public Blght-of-Way and
TMK; (3) 9-8-002:018
APPUCANT: Wilson Okamolo Cotporallon on behalf of the County of Hawaii, Department
of Environmental Management
Transmitted tor your review and comment Is Information on Ihe atom-referenced
sut?|B0t matter. We would appreciate your commenls by April 12,201B.
If no response to received ly Btb date, we wi assume your agency has no comments.
If you have any questions about this request, please contact Dartene Nakamura at SB7-Q417.
Thank you.
( K^Werwvanoat^cion*.
(i/j We have no comments.
( ) Commenls are attached.
oigneu:
ck Central F»es
Oato: v/tv/iX*
i>Jk~ ( f3)
fm-. M>u»
-------
WILSON OKAMOTO
CORPORATION
10J49-0I
June 22,2018
Mr. Russell T- Tsuji, Laid Administrator
Land Division
Department of Land and Natural Resources
State of Hawai'i
1)51 Punchbowl Street
Honolulu, HI 96813
Attention: Ms. Darienc Nafcamwti
Subject: Draft Environmental Awcssment, Pre-Assessment Consultation;
PShala Community Large Capacity Cesspool Replacement
PI'au'aa, Ka'u, Hawai'i
Response to Comment
Dear Mr. Tsuji:
Thank you be your April 16,2018 comment letter regarding the County of Hawai'i Department
of Environmental Management Plhala Community Large Capacity Cesspool Replacement
project. The Draft Environmental Assessment (EA) will include that the Engineering Division
stated the responsibility for conducting research as to the flood hazard designation for the project
site ties with the project proponent. Further, the Land Division Hawaii District has no comment.
We appreciate your participation in the Draft BA process.
Project Manager
cc: D. Beck. DEM
K Rao. EPA
C. Lakven, PE, BC
1907 S. BnM Street. Suite 409 • Honolulu. Hawaii • MOfr • (BOB) MM??
-------
lOtyt'Ol
»"uc nr i «»»»>%*
4I*&I&m
. ,9/ •OnKTK.tttfM
CXs , 0>
jmrrr.rMttON.rx
STATE OF HAWAII
DEPARTMENT OF LAND AND NATURAL RESOURCES
DtVtSION OF RWBSTTl V AND WILOUFR
1191 PUNCHBOWL STREET. ROOM MS
HONOLULU. HAWAH W«t %
Earl Matsukawa
Project Manager
Wilson Okamoto Corporation
1907 South Berecania Street, Suite 400
Honolulu, Hi 96826
cc'
AftA-llb
April 18.2018
Dear Earl Matsukawo,
The Department of Land and Natural Resource's Division of Forestry and Wildlife (DOFAW) has
received your inquiry regarding the proposed Pahala Community large capacity cesspool
replacement located in Pa'au'au, Ka'u cm the island of Hawsi'i. The County of Hawaii Department
of Environmental Management is proposing to construct wastewater system improvements to
replace the current system servicing Pihala. The new wastewater collection system would consist
of 11,000 linear feet of gravity flow piping ranging from 8 to 12 inches in diameter. The proposed
treatment and disposal system would occupy approximately 14 acres and consist of headwords
with screens to remove debris and on odor control unit. four lined aerated lagoons of about 0.3
acres each, subsurface flow constructed polishing wetland and four land treatment basins. A
security fence will be constructed along the perimeter of the site.
The State and Federally listed Hawaiian hoary bat or 'Ope'ape'a (Lmiuntfi rinereu\ semMw) has
the potential to occur in the vicinity of the proposed project. Hawaiian hoary bats roost in both
exwie and native trees. DOFAW recommends avoiding the use of baited wire, as bat mortalities
have been documented as a result of becoming ensnared by barbed wire during (light. Bats are also
known to be attracted to water features and ponding of water. If any trees are planned for removal
during the bat breeding season there is a risk of injury or mortality to juvenile batB. To minimize
the potential for Impacts to this specie*. site clearing should be timed to avoid disturbance to
breeding Hawaiian hoary bats; woody plants greater than 15 feet 04.6 meters) tall should not be
disturbed, removed, or trimmed during the bat birthing and pup tearing season (June 1 through
September 15)
The endangered Hawaiian hawk or 'io (Burto solitaries) may occur in the project vicinity.
DOFAW recommends surveying the area to ensure no Hawaiian hawk nests are present if trees
are to be cut. DOFAW would like to ensure that effective avoidance measures are in piece to
prevent adverse impacts to native seabirds. Artificial lighting can causing disorientation which
could result in collision with man made artifacts or grounding of birds. If nighttime lighting is
required DOFAW recommends that any lights used be folly shielded to minimize impacts.
Construction of aerated lagoons, polishing wetland and land treatment basins are likely to attract
endangered waterbirds such as the Hawaiian duck (Anas wyviltiana), Hawaiian stilt (Himantapus
mexicmus kntutstnf), Hawaiian coot (Fulica alai). Hawaiian goose, or Ncne!Branta sundm cnsis)
and Hawaiian moorhen (GalUmtta chloraput saiulvicensix) to the proposed project site. DOFAW
requests thai the project proponent initiate consultation with our office to further assess the impact
of the project on endangered and threatened species.
We appreciate your efforts to work with our office for the conservation of our native species. If
you have any questions, please contact lames Cogswell. Wildlife Program Manager at (808) 587-
4187 or iamet-M.Cogsweliehawau.Bov.
-------
WILSON OKAMOTO
CORPORATION
103494)1
August 20,2018
Mr. Junes Cogswell, Wildlife Program Manager
Division of Forestry and Wildlife
Stale of Mswati
Department, of Land and Natural Resources
1151 Punchbowl Street
Honolulu. HI %813
Subject; Draft Environmental Assessment. Pre-Asstrssmettt Consultation;
Pihala Community Large Capacity Cesspool Replacement
PS'au'au. Ka'u. Hawai'i
Response to Comment
Dear Mr.. Cogswell;
Thank you tor your April 18, 2018 comment letter regarding the County of Hawaii Department
of Environmental Management Pihala Community Large Capacity Cesspool Replacement
project As part of the Draft Environmental Assessment (EA), in August 2018, botanical and
avian Held studies were undertaken along the streets and adjacent areas of the wastewater
collection system ant! at the wastewater treatment and disposal facility project site.
The avian survey recorded a total of 175 individual birds of 13 species, representing nine
separate families during station counts. Avian diversity and densities were very tow, in keeping
with the current usage of the site us a mature macsdamta nut orchard, with minimal ground cover
and few weedy or shrubby specks. All of the species recorded during the course of the survey
are established alien species. No native avian species were recorded during tlw course of this
survey.
No species of plants or animals currently proposed for listing or listed under either the federal or
State of Hawaii endangered species statutes were recorded by the survey.
The potential that the ncauuem and disposal facility could atuuei a listed species will be
discussed in the Draft EA, along with the .avoidance and minimization measures as set forth in
your April 18,2108 letter.
I80T S. B»r»t.n« Stwut, Slid. 400 • Honolulu M»w»ll • 9682# < (808) *46-227?
10349.01
Letter to Mr. James Cogswell, Wildlife Program Manager
Page 2
August 20,2018
We appreciate your participation in the Draft EA process.
Earl MMsukawa, AICP
Vice President. Director - Planning
D, Beck. DEM.
K, Rao. EPA
B. Rosen, ERG
€.. Lekven, PE, BC
-------
DAVIO V, IQE
(om-ou
<%,' SO _««.
JMX r HUT A*
STATE OF HAWAII
DEPARTMENT OF TRANSPORTATION
MB PUNCHBOWL STREET
HONQLUtU, HAWAII MSt3<50S7
April 10.2018
Mr. Earl Maisukawa. AICP
Project Manager
Wilson Okamoto Corporation
1907 South Beretania Street. Suite 400
Honolulu, Hawaii 96826
Dear Mr. Matsukawa:
(MCK
Dm 032?
STP 8.2379
If II
» MB I
Subject: Pahala Community Large Capacity Cesspool Replacement
Draft Environmental Assessment, Pn-Assesanent Consultation
Paauau. K«u» Hawaii
TMK: (3) 9-6-002:018
The Department of Transportation (DOT) understands, The County of Hawaii Is proposing to
construct wastewater system improvements to replace the current system servicing Pahala. 'The
Pahala Community Large Capacity Cesspool Closure project improvements would consist of a
new- wastewater collection system located within the public right-of-way under the County
jurisdiction and a treatment and disposal system located on a currently privately-ownis! parcel
(TMK: 9-6-002:018) which will be. acquired by the County. While the project location map
reflects the subject project being adjacent to Mamalaboa Highway, we understand the project
will be approximately 60 feet from the highway right of way.
Based on the information provided, the subject project is not expected to significantly impact the
State highway facility.
If there arc any questions, please contact Mr. Blayne Nikaido of the DOT Statewide
Transportation Planning Office at telephone number (808) 831-7979.
WILSON OKAMOTO
CORPORATION
IMtOVMMS -HSKNtBI. tUCIHCItl
10349-01
June 22,2018
Mr. Jade Butay, Director
Slate of Hawaii
Department ofTransportatioo
D£fl IKinnhknmt S»f,
no" runcnDowi jjircci
Honolulu, HI 96813
Attention. Blayne Nikaido
Subject: Draft Environmental Assessment, Pro-Assessment Consultation;
Pahata Community Large Capacity Cesspool Replacement
Pi'au'au, Kj^HawaiS
Response to Comment
Dear Mr. Butay:
Thank you fir your April 10,2018 comment letter (DIR 0327 STP 8.2379) regarding the County
of Hawaii Dcpanmens of Environmental Management PShala Community large Capacity
Cesspool Replacement project Hie Draft Environmental Assessment (EA) will confirm the
wastewater collection system and the treatment and disposal project site are located outside of
the highway right of way.
We appreciate your participation in the Dixit EA process.
Earl Matsukawa, AICP
Project Manager
D. Beck, DEM
K. Rao, EPA
C. Lekven. PE, BC
!90T S. Beretania Stmt.
408 • Honolulu, Hawaii • S682I • (008) 94&22T7
-------
m
STATE OF HAWAII
DEPARTMENT OF ACCOUNTING AND GENERAL SERVICES
eo m*. na Hoaousui, Horn «>•»*«•
(P>HM4
APR 2 0 2018
s?: ?c: f>- ii
U API! ? 3
«, _ ... , .••^a(,uuwiv
Mr. Bart Mateukawa, AICP
Wilson Okainoio Corporation
1907 South Bereiaiiia Stmt, Suite 44%
Honolulu. Hawaii. 96826
Dear Mr. Matsukawa:
Subject: Draft Environmental Assessment, Pre-Assessnrem Consultation
Pahala Community Large Capacity Cesspool Replacement
Paauau, Kau, Hawaii
Thank ymi tor the opportunity to provide comments on the subject project. The project does not
impact any of the Department of Accounting sod General Services' projects or existing facilities,
and we have no comments to offer at this time,
>f you have any questions, your staff may call Mr. David DePoate of the Public Works Division
at S864)492.
Sincerely,
—v..
RODERICK K. BECKER
Comptroller
c: Mr. John Chung. DOE Facilities
Mr. Cory Kaiwta, DAOS Hawaii
0 WILSON OKAMOTO
CORPORATION
10349-01
August 20, 2018
Mr. Roderick Becker. Comptroller
Stale of Hawai'i
Department of Accounting and General Services
1151 Punchbowl Street
Honolulu, HI 96813
Attention: David DcPnnte
Subject: Draft Environmental Assessment, Pre-Assessmeiu Consultation;
Pibata Community Large Capacity Cesspool Replacement
Pi'au'au, Ka'u. Hawaii
Response to Comment
Dear Mr. Becker:
Thank you foryour Apnl 20.2018 comment letter regarding the County of Hawai'i
Department of Environmental Management Pahala Community Large Capacity Cesspool
Replacement project. We acknowledge that the project does not impact any Department of
Accounting and General Services projects or existing facilities.
We appreciate your participation in the Draft EA process.
Vice President, Director - Planning
cc: D. Beck, OEM
K. Rao. EPA
C. Lekven, PE, BC
1S07 S. B«#tanit Strml, Suits 400 • Honolulu. Hawaii ¦ 9M2J « (1081944-227T
-------
94/13/2818 15:48 3009322928
HAWAII FIRE OEFT
Countp of ?$atoai'i
HAWAI'I wmB DEPARTMENT
J$ lUifmt tm«« M» MM « tth. WMB1I1*?*«
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PAGE 01/02'
cpy-oj)
Darrca j. Roaario
vrlckJ, Vlet*wi»o
/5^^c^r
April 13,2018
Earl Matsukawa. AICP
Wilson Okamoto Cotpotstfcm
Project Manager
190? S. Banana Street, Suite 4«0
Honolulu, Htwii'i 96826
Dear Mr Eart Matsukawa:
SUBJECT: Draft Environmental Assessment, Pie-Assessment Consultation;
PShfllB Community Large Capacity Cesspool Reptaoramm^ Pmuw, Ka'fl H««*»
We are in receipt of your fate dated March 15,2018 ta rcgwfb to a draft Environmental
Assessment and Anticipated finding of no significant Impart for the above listed wbjeet.
The Hawaii Fire Department ha no issue or comments with regwto to the request for draft
Environmental Assessment, Pre-Assessntcnt Consolation.
(f you should have any questions, please feel free to contact my office at (808)932-3911,
Mahalo,
Ck
DARREN J. ROSARIO
Fire Chief
RP/ds
$
fAnn
-------
tarry Kim
Mfgw
April 2, 2MB
County of Hawai'i
POLICE DEPARTMENT
J*JCa0i<«lMLSlnel • 98?»M9«
{8M)93S-131I * FwJI0««l-33JK»
T*3W
J/,4
ftfeGW
Ey\
lieiiti
1 atobi an
Mr, Earl Matsukawa, A1CP
Project Manager
Wilson Qkamoto Corporation
1907 South Beretanla Street, Suite 400
Honolulu, HawaU 96826
SUBJECT: DRAFT ENVIRONMENTAL ASSESSMENT, PRE-ASSE5SMENT CONSULTATION;
pShala community large capacity cesspool repucement
PAWAU, KAU HAWAII
REQUEST FOR COMMENT
Dear Mr. Matsukawa:
Staff has reviewed the draft regarding the Pafiala Cesspool Replacement Project The
Hawaii Police Department does not have any comments or concerns at this time.
Thank you for allowing the Hawaii Pofice Department the opportunity to provide Input into
this assessment
Should you require additional assistance or Input, please contact Captain Kenneth Quiocho,
Commander of the Ka'u District, at (808) 939-2520 or via email at
Sincerely,
PAUL K. FERRBRA
POLICE CHIEF
KQ
Niwat't Cmmy » m Pra»i
WILSON OKAMOTO
CORPORATION
ICS • moiNitts
10349-01
June 21.2018
Chief JL Paul Ferteiw, Police Chief
County of Hawai'i
Police Department
349 Kapiolaoi Street
Hito, HI 96720
Subject: Draft Environmental Assessment, I'rc-Asscssmeni Consultation;
PShaia Community Large Capacity Cesspool Replacement
Pa'au'au, Ka'u, Hawaii
Response to Comment
Dear Chief Ferreini:
Thank you fir your April 2,2018 comment letter regarding the County of Hawai'i Department
of Environmental Management Pihala Community Large Capacity Cesspool Replacement
project. The Draft Environmental Assessment (Eh) will irate the Hawai'i Police Oeparimcnt tad
no concerns at this time.
We appreciate your participation in the Draft EA process.
Sincerely,
flCQrZ-
fySari Matsukawa, A1CP
Project Manager
cc: D. Beck. DEM
It Rao, EPA
C. Lckvcii. BC
18ST8.
Streoi, Sulta 4M • Honolulu, Hawaii • 9682t - (808) 948-227?
-------
Harry Rim
Wot Haw* tOUkc
74-«H4 AncX<»hiA»MeHw>
Ka**'fcv»,ltowati%7«}
nww{«o«»J3:3-4Tw
County of Ilawai'i
PLANNING department
fpSAjjt)
CO#*
Mtchitcl Y«
Mivaar
Daryn A.n»
Drpttft Dim-far
Eva H«wni'» Officr
Hito, %72»
rho»w»SOS>06l-83«
r-Mimtm-xu-}
April 25.2018
Mr. Ear! MMsukawa
Wilson Okamoto Corporation
1907 South Beretania Street. Suite 400
Honolulu, HI
Dear Mr, Maisukawa:
SUBJECT: REVISED Draft Environmental Anexsment, Pre-Assessment Consultation
Project: Pthaia Community Large Capacity Cesspool Replacement
TMK: (319-6-002:018. Pl'iu'iu. Ka'Q. Hwnl'l
Thank you for your letter dated March 15, 2018, requesting comments from this office regarding
the preparation of n Draft Environmental Assessment (DEA) for the subject project. Please note,
this letter replaces our previous response dated April 16, 201$.
The County of Hiwai'i. Department of Environmental Management (DEM) is proposing to
construct wastewater system improvements to replace the current County owned system
servicing PShala, These wastewater system improvements would allow the County to comply
with Environmental Protection Agency (EPA) regulations requiring, closure of the large capacity
Cesspools and to construct a system meeting current Stale of Hawaii Department of Health
(DOM) and DEM design guidelines for the collection, treatment, and disposal of the treaied
effluent We would respectfully ask that you consider expanding the collection system to service
the greater urban PShala area or design the treatment facilities capacity to ensure expansion is
possible in the hi lure.
The subject parcel consists of 42.5 acres and is zoned Agricultural (A-20a> by the County. It is
located in the State Land Use Agricultural (A) district. In addition, the parcel is designated Low
Density Urban (LDU> and Industrial (IND) by the Hawaii County General Plan Land Use
Pattern Allocation Guide (LUPAG) Map. lie subject parcel is not located within the Special
Management Area' (SMA).
11 (51P f P r>
, '
*+* btSAVmmk# WW Hawui t CtmUv is «i Equat f'n>nter mtd Kmpkixvt 0*-"W>U£2 ffii
Mr. Earl Mattukawa
April 25,2018
Page 2
According to Hawaii County Code (Zoning), Section 25-5-?2(c), Public uses and structures,
other than those necessary for agricultural practices are permitted in the Agricultural district,
provided that a special permit is obtained for such use if the building site is located within the
Stale land use agricultural district Therefore, the treatment and disposal facility, considered a
public use, would require-a special permit.
In addition, the Land Study Bureau (USB) classifies the subject parcel » B and D sails.
Agricultural lands of Importance to the State of Hawai'i (ALISH) classifies (he subject parcel as
a mix of Type 0 (Unclassified), Type, I (Prime Lands), and Type 3 (Other). Hawaii Revised
Statutes (HRS) 205-4.5 (a) states "Within the agricultural district, oil tends ivith sail limnified
Iff the land study bureau "s detailed land classification at tnvrall productivity rating class A or B
and for solar emrg> facilitim, class 0 or C, shall Im restricted to the fallowing permitted toes:
(?) Public, private, and quasi-public utility lines and roadways, tmiafbmer Marians,
eommimimtlom equipment ktiUings, solid waste transfer stations, major water storage tanks,
and appurtenant small buildings such m boaster pumping, nations, but not including offices or
yards for equipment, material, whicle storage, repair or maintenance, treatment plants.
corporation yards, or other similar structures;" Therefdre, when considering the Special Permit
application, it would be advisable to locate the treatment facility on the proposed property in the
LSB D soil and ALISH Type 0 area.
The public utilities chapter of the County of Hawaii General Plan 2005 (as amended), includes
the following policy (11.6.2) pertinent to the proposed project:
c) immediate steps should he taken to designate treatment plant sites, sewerage pump
Mtbm sites, and tewtr easements according to facility plans to facilitate their
acquisition.
In the DEA, please describe how the proposed use is consistent with the policies, standards and
courses of action of the County of Hawaii General Plan.
Hie project site is located' in the Katt Community Development Plan (CDP) planning area and
the DEA should include a discussion of the proposed project's alignment with the CDP. which
can be found electronically at http:ffwww,bawaiieountvcdt>.inft>/l
-------
Mr, Bart Matsukawa
April 25,2018
Page 3
• P»!icv 120: Extend the primary wastewater collection tines in f'Shala and Nit "alehu so
that infill development projects am connect i mstewmer systems built for new
subdivisions to Ike County systems,
We recommend the DEA also describe the proposed project's consistency with Hawaii Revised
Statutes (HRS), Chapter 20SA, Coastal Zone Management, More specifically, the DEA should
describe the 'projects consistency with Policy (3)(B) to "Smart that new dmvlopments are
compatible with their visual environment by designing and locating mch developments to
minimize the alteration of natural land/arms and existing public views to and along the
thorelinv"
Finally, given Hrfl's rich heritage of natural and cutuuat resources, appropriate attention should
he given to identifying any existing resources on the subject property or surrounding areas thai
maybe impacted.
We have no further comments to offer at this time. However, please keep us informed and
provide our department with » copy of the DEA tor our review and comment.
Should you have any questions, please feel tree to contact Kciko Mereado of this office at
Keiko,MTOmdo(#hawaiict»Mnty,gov or (8081 % I 8131.
K.M:bm:ja
\urOHJ.^Ia«m»ng^MiblM^«Afmini0lhKako\KA-E!S KcvimVl'iwoit&ulltaiuriEA-Falwfa Laige.CtssiioBJ.KeittMrcnrnt.KEVlhHD ttoi;
-------
WILSON OKAMOTO
CORPORATION
10349-0!
August 20,20 i 8
Mr, Michael Yetr. Director
County of Hawaii
Planning Department
Aupuni Center, 101 Pauahi Street, Suite J
Hilo.Hl 96720
Subject: Draft Environmental Assessment, Pre- Assessment Consultation;
PShala Community Large Capacity Cesspool Replacement
Pa'au'su, Kj'u. Hawai't
Response to Comment
Dear Mr. Yeei
Thank you for your April 2S. 2018 comment letter regarding the County of Hawaii Department
of Environmental Management Plhala Community Large Capacity Cesspool Replacement
project As stated in the Project Summary, the Pihala Community Large Capacity Cesspool
Replacement project would he funded by on Environmental Protection Agency {EPA) Special
Appropriation Grant and by the State of Hawaii Clean Water Stale Revolving Fund (CSRF) loan
program administered by the Department of Health (DOH) Wastewater Branch, Both the EPA
aid DOH require preparation of an Environmental Assessment (EA) according to their
respective guidelines.
The Draft Environmental Assessment (EA) will confirm that the treatment and disposal project
site is zoned Agricultural
-------
10349-01.
letter (a Mr, Michael Yee. Director
Page 3
August 20,2018
As previously stated, the Draft EA will be prepared to meet the DOU requirements which would
include a discussion of plans and policies applicable to the project she and surrounding uti
including Chapter 205A. Hawaii Revised Statutes, Coastal Zone Management
The Draft EA will discuss archaeological and cultural resources and -consultation with the State
of Hawal'l Department of Land and Natural Resources Srate Historic Preservation Division and
various Native lUwai'mn Organisations as required by 54 U.S.C. §300101 and 54 5 506108
We appreciate your participation in the Draft EA process,
Earl Matsukawa. A1CP
Vice President, Director - Planning
cci D. Beck, DEM
K. Rao. EPA
C. l.ckven. PE. BC
-------
(doutrfy
DEPARTMENT OF PUBLIC WORKS
Attend Cmttr
101FMU SMI, Suk T MIk HMi'l W7SM2M
mnm-mi - Fa
-------
o
¦ej)
DEPARTMENT OF WATER SUPPLY • COUNTY OF HAWAI'I
34S KEKQAWAO'A STREET, SUITE 20 • HILO. HAWAI I S67JO
TELEPHONE fl«1-B0S0 • FAX (S0»! 9«1-SSS7
Aprils, 20IS
p)!®PWf
Mr. Earl Maoukawa f| APR 0 5 2018
W flsorv Oktmoio Corporation aw
1907 South Beretania Street, Suite 400 nUamnUaUIUOWlWHW
Honolulu, in 96826
Dear Mr. Matsukawa:
Subject: Pre-Environmental Aaaeamcut Cooialtatkm
PMuia Villages Uije Capacity Cesspool Coovenkra Replacement
PMute, Ka'8, Mux) of Hawai'i, Hawai'i
Tn Map Key (3) 9-4-002.-918
This «in response to your Pr&-Environmental Assessment letter dated March 15,2018
Please be informed that Ihe subject parcel does not have in existing Water service with the Department as the
parcel is beyond the service limits of the Department's existing water system. The nearest point of connection is
from an existing 6-inch walcrlinc gt the intersection of Huapata Street and Msile Street, approximately 2,000
feet northeast of the property.
The Department would request estimated maximum daily water usage calculations, prepared by a professional
engineer, licensed in the Stale of Hawai'i, for review. After review of the calculations, the Department will
determine if water is available and a water commitment can be issued, Ihe water oomraitment deposit amoant,
facilities charges due, and water system improvements and other conditions for fin3l approval.
The Department requests that the conjunction plana show, and the proposed sewer lines be installed with, the
proper horizontal and vertical clearances from our existing water system facilities and concrete jacketing at
waterfine crossings, where necessary, as recommended by the Department's Water System Standards.
In addition, bock flow prevention devices must be installed when there are connections to our water system at
wastewater processing and treatment facilities.
Should then be any questions, please contact Mr. Ryan Quitoriano of our Water Resources and Planning Branch
at 961-8070, extension 256.
Sincerely yuurs.
Keith 1C Okamoto. P.E.
Manager-Chief Engineer
RQ:dmj
copy- County of Hawai'i. Department of Environmental Management, Wastewater Division
... 'Water, Our Most 'Precious Hfsouru ...Kji Waiji T&nt,..
OuMMmarx W««r SupeV * m fqu^OpponunHj' pvrtto **
WILSON OKAMOTO
CORPORATION
i««ov»ro>5 ¦ . inciKiias
10349-01
June 21,2018
Mr. Keith Okamoto, Manager-Chief Engineer
County of Hawai'i
Deportment of Water Supply
345 Kekuanaoa Street, Suite 20
Hilo, HI 96720
Attention: Ryan Qoitoriano, Water Resources Planning Branch
Subject; Draft Environmental Assessment, Pre-Assessment Consolation;
Pihala Community Large Capacity Cesspool Replacement
W'au'au.Ka'u, Hawai'i
Response to Comment
Dear Mr. Okamoto:
Thank you for your April 5.2018 comment letter regarding (be County of Hawai'i Department
of Environmental Management mala Community Large Capacity Cesspool Replacement
project The Draft Envirotmemal Assessment (EA) will note tbe treatment and disposal project
site parcel does not have an existing water service from the Department as tbe parcel is beyond
the service limils of the Department's existing water system. TT>e nearest point of connection is
from an existing 6-inch wsteriioe at the intersection ofHuapaia Street and Maile Street,
approximately 2,000 foet northeast of the property.
TheDraflEA will note thai Ihe project will require estimated maximum daily water usage
calculations be prepared by a professional engineer, licensed in the State of Hawai'i After
review of the calculations, the DepaiUneiit will determine if water is available and a water
commitment can be issued, tbe water commitment depositamount, facilities charges due, and
water system improvements and other conditions for final Bpproval
The construction plans will stow proposed collection system lines aid the horizontal and vertical
clearances Anm voter system lines.
1107 *. Bants* SSn< Batta 4M • HoneMu, Hawaii. S682S • (MM) MC-22T7
-------
10349-01
Letter to Mr. Keith Okamoto
Page 2
June2I, 2018
We appreciate your participation in the Draft EA process.
Project Manager
cc: D. Beck, DEM
K. Rao, EPA
C. Lekven, PE. BC
-------
Final EA, Pahala LCC Replacement Project
Pahala, Ka'u District, Hawai'i
THIS PAGE INTENTIONALLY LEFT BLANK
February 2020
-------
Final EA, Pahala LCC Replacement Project
Pahala, Ka'u District, Hawai'i
Appendix B
November 2019 Preliminary Engineering Report (PER)
February 2020
-------
Final EA, Pahala LCC Replacement Project
Pahala, Ka'u District, Hawai'i
THIS PAGE INTENTIONALLY LEFT BLANK
February 2020
-------
Pahala Wastewater
Treatment Plant
Preliminary Engineering
Report
Prepared for
County of Hawaii, Department of
Environmental Management
Juno 2018
November 2019
-------
Pahala Wastewater Treatment Plant
Preliminary Engineering Report
Prepared for
County of Hawaii, Department of Environmental Management
June 2018
November 2019
/CV LICENSED Y^\
I Of PROFESSIONAL ^"-2.1
ENGINEER j*
Mo. 13003-C
VA!I, U
THIS WORK WAS PREPARED BY ME OR UNDER MY SUPERVISION.
Brewtwl
Caldwellj
2261 Aupuni Street, Suite 201
Wailuku, Hawaii 96793
-------
Table of Contents
List of Figures vi
List of Tables vii
List of Abbreviations ix
1. Introduction 1-1
1.1 Background 1-1
1.2 Existing System 1-1
1.3 Report Contents 1-1
2. Flow and Load Projections 2-1
2.1 Service Area 2-1
2.2 Flow Projections 2-3
2.3 Influent Characteristics 2-3
2.4 Influent Mass Loads 2-3
2.5 Mass Loads to the Environment via Existing LCCs 2-4
3. Effluent Management Options and Regulatory Requirements 3-1
3.1 Effluent Management Options 3-1
3.1.1 Ocean Discharge 3-1
3.1.2 Subsurface Disposal via Injection Wells 3-1
3.1.3 Water Recycling 3-2
3.1.4 Land Treatment 3-2
3.1.5 Drain Field 3-3
3.1.6 Recommendation 3-3
3.2 Treatment Requirements 3-3
4. Wastewater Treatment Evaluations 4-1
4.1 Preliminary Treatment 4-1
4.1.1 Screening 4-1
4.1.2 Influent Flow Measurement 4-2
4.1.3 Influent Flow Sampling 4-2
4.1.4 Preliminary Design of Headworks 4-2
4.1.5 Odor Control 4-4
4.2 Aerated Lagoon Treatment System 4-5
4.2.1 Aerated Lagoon Kinetics 4-5
4.2.2 Aeration in Lagoon Systems 4-5
4.2.3 Aerated Lagoon Configuration 4-7
4.2.4 Lagoon Liner 4-8
4.2.5 Lagoon Cover 4-9
4.2.6 Lagoon Sludge Management 4-11
Brown AND Caldwell \
!!!
-------
Pahala Wastewater Treatment Plant Preliminary Engineering Report
Table of Contents
4.3 Subsurface Flow Constructed Wetland 4-11
4.3.1 Denitrification in Subsurface Flow Constructed Wetlands 4-11
4.4 Disinfection 4-12
4.4.1 Calcium Hypochlorite 4-12
4.4.2 Ultraviolet Light (UV) Disinfection 4-16
4.4.3 UV System Design Summary 4-16
4.4.4 Cost Evaluation 4-17
4.4.5 Disinfection Recommendation 4-17
4.5 Effluent Management 4-18
4.5.1 Design 4-18
4.6 Ancillary Systems 4-20
4.6.1 Water 4-20
4.6.2 Access Road 4-20
4.6.3 Stormwater Management 4-21
4.6.4 Pre-development Stormwater Conditions 4-21
4.6.5 Electrical Systems 4-26
4.6.6 Telemetry Systems 4-26
4.6.7 Operations Building 4-26
4.6.8 Site Fencing 4-26
4.6.9 Alternative Energy 4-26
5. Preliminary Design of Improvements 5-1
5.1 Site Plan 5-1
5.2 Process Schematic 5-1
5.3 Design Criteria 5-4
5.4 Environmental Benefits 5-6
5.5 Cost Estimates 5-8
5.6 Future Expansion 5-8
5.6.1 Full Buildout Flows 5-8
5.6.2 Improvements 5-8
6. Implementation 6-1
7. Alternative Treatment Options Evaluation 7-1
7.1 Option Descriptions 7-1
7.1.1 Option 1: Aerated Lagoons/Constructed Wetland/Land Application 7-1
7.1.2 Option 2: R-l Treatment/Land Application 7-1
7.1.3 Option 3: R-l Treatment/Seasonal Water Recycling 7-2
7.1.4 Option 4: R-l Treatment and Storage for 100% Water Recycling 7-4
7.1.5 Option 5: Maximum Practical Treatment 7-6
7.2 Cost Comparisons 7-7
7.2.1 Capital Costs 7-7
7.2.2 Operation and Maintenance Costs 7-7
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Table of Contents
7.2.3 Recycled Water Sale Proceeds 7-8
7.2.4 Life-Cycle Costs 7-8
7.3 Non-Economic Discussion 7-9
7.3.1 Labor Requirements 7-10
7.3.2 Operational Complexity 7-10
7.3.3 Energy Consumption 7-11
7.3.4 Sludge Management 7-11
7.4 Living Machine® 7-11
7.5 Septic Tank Alternatives 7-12
7.5.1 Community Septic Tank 7-12
7.5.2 Converting LCC to Seepage Pit 7-12
7.5.3 Leachfield Disposal 7-13
7.5.4 Conversion to Individual Wastewater Systems 7-13
7.5.5 Gray Water Systems/Composting Toilets 7-14
7.6 Package Plant 7-14
8. Alternative Site Evaluation 8-1
8.1 Methodology 8-1
8.2 Site Locations 8-1
8.3 Criteria 8-3
8.4 Criteria Weighting Factors 8-7
8.5 Raw Scores 8-8
8.6 Weighted Analysis 8-9
8.7 Results 8-10
8.8 Conclusion 8-10
9. References 9-1
Appendix A: Cost Estimates A-l
Appendix B; Collection System Plan B-l
Appendix C: Wastewater Flow Calculations C-l
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Table of Contents
List of Figures
Figure 1-1. Pahala Existing Sewer Collection System and LCC Service Area 1-2
Figure 2-1. Pahala WWTP Service Area 2-2
Figure 3-1. Irrigation Demand Assessment 3-2
Figure 4-1. In-Channel Cylindrical Screen 4-2
Figure 4-2. Headworks 4-3
Figure 4-3. Activated Carbon Scrubber (GAC) 4-4
Figure 4-4. High Speed Floating Aerator 4-7
Figure 4-5. Normal Lagoon Configuration Schematic 4-7
Figure 4-6. Floating HDPE Shade Balls 4-10
Figure 4-7. Floating shade balls with current and turbulence in reservoir 4-10
Figure 4-8. Subsurface Flow Constructed Wetland Concept 4-11
Figure 4-9. Typical Calcium Hypochlorite Feed System 4-13
Figure 4-10. Chlorine Contact Tank Configuration 4-15
Figure 4-11. Land Application System Schematic 4-19
Figure 4-12. Existing Drainage System 4-22
Figure 4-13. Flood Insurance Rate Map 4-24
Figure 4-14. Operations Building Preliminary Floor Plan 4-28
Figure 5-1. Preliminary Site Plan 5-2
Figure 5-2. Recommended Facility Process Schematic 5-3
Figure 5-3. Environmental Benefits of Proposed Project 5-7
Figure 7-1. Option 1 Schematic Diagram 7-1
Figure 7-2. Option 2 Schematic Diagram 7-2
Figure 7-3. Option 3 Schematic Diagram 7-2
Figure 7-4. Irrigation Demand Assessment 7-3
Figure 7-5. Option 3 Recycled Water Demand Assessment 7-3
Figure 7-6. Comparison of Irrigation Demands at Pahala and Kealakehe 7-4
Figure 7-7. Option 4 Schematic Diagram 7-5
Figure 7-8. Seasonal Storage Reservoir Analysis 7-6
Figure 7-9. Option 5 Schematic Diagram 7-7
Figure 7-10. Life-Cycle Costs of Options 7-9
Figure 7-11. Comparison of Electrical Energy Requirements 7-11
Figure 8-1. Pahala Site Alternatives 8-2
Brown AND Caldwell j
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Table of Contents
List of Tables
Table 2-1. Pahala WWTP Flow Projections 2-3
Table 2-2. Summary of Assumed Influent Characteristics 2-3
Table 2-3. Projected Influent Mass Loads 2-3
Table 2-4. Mass Loads to the Environment via Existing LCCs 2-4
Table 3-1. Nutrient Water Quality Standards for Class AA Embayments 3-1
Table 3-2. Applicable HAR 11-62 Land Disposal Requirements 3-3
Table 4-1. Normal Configuration Aeration and Mixing Requirements 4-8
Table 4-2. Lagoon Shade Ball Cover Application Parameters 4-9
Table 4-3. Calcium Hypochlorite Summary 4-13
Table 4-4. Chlorine Demand 4-14
Table 4-5. Chlorine Contact Tank 4-14
Table 4-6. UV Disinfection Design Summary 4-16
Table 4-7. Estimated Disinfection Costs 4-17
Table 4-8. Ultraviolet Disinfection - Advantages and Disadvantages 4-17
Table 4-9. Potential Land Application System Tree Species 4-18
Table 4-10. Potential Water Demands 4-20
Table 5-1. Preliminary Design Criteria 5-4
Table 5-2. Environmental Benefits of Proposed Project 5-7
Table 5-3. Pahala WWTP Order of Magnitude Construction Cost Estimate 5-8
Table 5-4. Pahala WWTP Full Buildout Flow Projections 5-8
Table 6-1. Implementation Schedule 6-1
Table 7-1. Summary of Capital Cost Estimates 7-7
Table 7-2. Summary of O&M Cost Estimates 7-8
Table 7-3. Summary of Annual Recycled Water Sale Proceeds 7-8
Table 7-4. Summary of Life-Cycle Cost Estimates 7-9
Table 7-5. Comparison of Operational Labor Requirements 7-10
Table 7-6. Comparison of Operator Certification Requirements per HAR 11-61 7-10
Table 8-1. Environmental, Social and Cultural Criteria 8-3
Table 8-2. Location and Site Characteristics 8-4
Table 8-3. Collection System and Service Area Criteria 8-5
Brown AND Caldwell j
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Table of Contents
Table 8-4. Land Use and Availability Criteria 8-6
Table 8-5. Relative Weighting Factors 8-7
Table 8-6. Alternatives Analysis - Raw Scores 8-8
Table 8-7. Alternatives Analysis - Weighted Scoring 8-9
Table 8-8. Alternative Site Ranking 8-10
viii
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Table of Contents
List of Abbreviations
million gallons
millimeter
mean sea level
nitrogen
net present value
Operation and Maintenance
Phosphorus
pounds per square inch
ribonucleic acid
right-of-way
standard cubic feet
Soil Conservation Service
slow rate
total suspended solids
Underground Injection Control
United States Environmental Protection
Agency
ultraviolet
Water Quality Volume
Wastewater Treatment Plant
HDPE high density polyethylene
HELCO Hawaii Electric Light Company
hp horsepower
hp/Mgal horsepower per million gallons
hr hour
hp-hr horsepower-hour
L liter
lbs pounds
LCC large capacity cesspools
LPHO low pressure high output
MBR membrane bioreactor
Mg milligrams
AND
ix
AB
aggregate base
Mgal
AC
asphalt concrete
mm
BMP
Best Management Practices
MSL
BODs
5-day biochemical oxygen demand
N
CCH
City and County of Honolulu
NPV
cfs
cubic feet per second
O&M
COH
County of Hawaii
P
CFR
Code of Federal Regulations
Psi
DNA
deoxyribonucleic acid
RNA
DEM
Department of Environmental Management
ROW
DOH
Department of Health
scfm
ELLF
end-of-lamp-life
SCS
FIRM
Flood Insurance Rate Map
SR
FOG
fats, oils, and grease
TSS
ft3
cubic feet
UIC
FTE
full-time equivalent
USEPA
GAC
granular activated carbon
gpm
gallons per minute
UV
H2S
hydrogen sulfide
WQV
HAR
Hawaii Administrative Rules
WWTP
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Introduction
1.1 Background
The town of Pahala is located in the Kau district of the Island of Hawaii. According to the 2010
United States Census, the town population is approximately 1,350 persons.
The Pahala community was established as the result of the sugar operations of the C. Brewer
Company. A portion of the community is serviced by a sewer system that was privately built, owned,
and operated by the C. Brewer Company. The wastewater collected by the sewer system discharges
into large capacity "gang" cesspools. Many years after its establishment, the private sewer system
ownership was conveyed to the County of Hawaii (COH) Department of Environmental Management
(DEM).
In 1998, the U.S. Environmental Protection Agency (USEPA), promulgated regulations, 40 Code of
Federal Regulations (CFR) 144.14, that require the elimination of large capacity "gang" cesspools
(LCCs). The County intends to construct a new sewer collection system located within public right-of-
way (ROW) and replace the existing LCCs with a wastewater treatment plant to address the
wastewater treatment and disposal needs of the Pahala community.
This report summarizes a proposed wastewater treatment plant (WWTP) needed in order to treat and
dispose of the wastewater flow that is currently discharged to the LCCs, plus additional sewer
connections. The report presents the existing and estimated future flows and loads to the treatment
plant, the proposed treatment processes, recommendation for the WWTP upgrades needed to meet
the future treatment needs, and an initial opinion of the cost to construct the improvements project.
1.2 Existing System
Figure 1-1 shows the collection system network and service areas for the LCCs. The collection
system is a network of gravity sewers that discharge to two existing LCCs. A detailed analysis of the
existing wastewater collection system was completed by others (M&E Pacific, December 2004). The
report concluded that the Pahala community existing sewer system consists of about 3,000 linear
feet of 6-inch diameter and 10,000 linear feet of 4-inch diameter pipelines. Residential laterals
connect to 4-inch sewers that discharge into 6-inch sewer mains, predominately found in private
property, which transmit wastewater to the LCCs. There are approximately 8 manholes in the sewer
system. There are no pump stations and the system is not designed to collect stormwater.
1.3 Report Contents
Section 2 presents flow and load projections for the new WWTP. Section 3 evaluates effluent
management options, and the treatment requirements for the preferred option. Section 4 presents
evaluations conducted to develop the preliminary design of the proposed WWTP, which is presented
in Section 5. An implementation plan is briefly presented in Section 6, followed by discussion of
other treatment options that were considered and evaluated. The report concludes with a site
selection consideration in Section 8.
Brown AND Caldwell j
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 1
INSERT FIGURE
Figure 1-1. Pahala Existing Sewer Collection System and LCC Service Area
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Flow and Load Projections
This section summarizes the flow and load projections for the new WWTP.
2.1 Service Area
Within the town of Pahala, there is an existing wastewater collection that services approximately 109
properties. The collection system is currently located within easements in private properties and is
treated and disposed through two LCCs. Figure 2-1 shows the service area for the new WWTP. The
Kau Community Development plan indicates that the sewer system may eventually be expanded to
service the entire community; however, the initial collection system and WWTP presented in this
report will service the properties currently connected to the LCCs or located adjacent to the new
collection system. Although this report does not include design for the full buildout service area, the
proposed WWTP has been designed to accommodate modifications within the proposed 14.9-acre
site for the anticipated future expansion of the service area.
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Pahaia Wastewater Treatment Plant Preliminary Engineering Report
Section 2
LEGEND
1 F i -.! n- •- ( ji jif i -,1C,"
r 1 i- fcjtf Coakc* to W/TP
m BManM* r-r*>vr« io vvwtp iuv r,Ti
¦ EltttftS L**0» C4(UK«y CMipsa iLCC)
Brown
Caldwell
Figure 2-1. Pahaia WWTP Service Area
Brown Caldwell •
2-2
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 2
2.2 Flow Projections
Wastewater flow projections were developed using the City and County of Honolulu's (CCH) current
(2017) wastewater standards. Table 2-1 summarizes the flow projections.
I
Description
Average dry weather flow
Peak day wet weather flow
Peak hour wet weather flow
Tabic 2-1. Pahala WWTP Flow Projccti
Value
189,000 gallons per day
662,000 gallons per day
630 gallons per minute
Peaking Factor
1.0
3.5
4.8
The WWTP will be designed to provide an average dry weather flow capacity of 190,000 gallons per
day.
2.3 Influent Characteristics
The properties within the existing service area are primarily residential, but do include several
commercial, apartment, and industrial zoned parcels. The wastewater characteristics of the WWTP
influent are assumed to be similar to typical domestic wastewater. Table 2-2 provides a summary of
the assumed influent characteristics.
I
Table 2-2. Summary of Assumed Influent Chamctcristi
Parameter
Value
I
5-day biochemical oxygen demand (BODs)
300 mg/L
Total suspended solids (TSS)
300 mg/L
Total nitrogen
40 mg/L
Total phosphorus
7 mg/L
2.4 Influent Mass Loads
Table 2-3 summarizes the projected loads to the WWTP, based on the proposed average dry weather
capacity of 190,000 gallons per day and the influent characteristics presented in Table 2-2.
Table 2-3. Projected Influent Mass Loads
Description
Value
BODs
1 480 Ibs./day
TSS
480 Ibs./day
Total nitrogen
i 60 Ibs./day
Total phosphorus
| 10 Ibs./day
Brown AND Caldwell «
2-3
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 2
2.5 Mass Loads to the Environment via Existing LCCs
Currently, 109 properties discharge without treatment to two LCCs, as shown in Figure 2-2. These
types of cesspools are a public health and environmental concern because of their likelihood of
releasing disease causing pathogens and other contaminants, such as nitrate, to groundwater. The
current annual mass loads to the environment via the existing LCCs based on the flow projections
and assumed wastewater characteristics presented above are summarized in Table 2-4.
Parameter
Annual Load
BODs
174,000 Ibs./year
TSS
174,000 Ibs./year
TotalN
23,000 Ibs./year
TotalP
4,000 Ibs./year
2-4
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Effluent Management Options and
Regulatory Requirements
Effluent management options are evaluated in this section, followed by an assessment of regulatory
requirements for the recommended effluent management system.
3.1 Effluent Management Options
Effluent management options are evaluated below.
3.1.1 Ocean Discharge
Ocean discharge of treated effluent is not considered a viable option for this small community due to
the long distance to the shoreline (approximately 3 miles), high cost to construct an outfall, stringent
receiving water quality standards, high receiving water monitoring cost due to the distance to Hilo
harbor, and difficulty and length of time required to secure the required permits.
The coastal waters in the Pahala area are classified as "AA" marine waters by DOH. HAR 11-54
does not allow zones of mixing in waters up to a distance of 300 meters (one thousand feet) off
shore if there is no defined reef area and if the depth is greater than 18 meters (ten fathoms). The
water quality criteria for nutrients for Class AA embayments are listed in Table 3-1. If a mixing zone
is not provided, then a WWTP discharging to the coastal waters would be required to treat water to
meet the applicable water quality criteria. Treatment to the specified levels is not feasible with
current technologies. Therefore, ocean discharge is not feasible.
Tabic 3-1. Nutrient Water Quality Standards for Class AA Einbayments
Parameter
Geometric mean not to exceed
Not to exceed the given value
more than 10% of the time
Not to exceed the given value more
than 2% of the time
Total nitrogen
200 iig/L
350 |jg/L
500 Mg/L
Ammonia nitrogen
6 [Jg/L
13 Mg/L
20 Mg/L
Nitrate + nitrate nitrogen
8 Mg/L
20 Mg/L
35 Mg/L
Total phosphorus
25 Mg/L
50 Mg/L
75 Mg/L
3.1.2 Subsurface Disposal via Injection Wells
Per Hawaii Administrative Rules (HAR), Title 11, Chapter 23, disposal to groundwater via an injection
well is not allowed mauka of the State of Hawaii Department of Health (DOH) Underground Injection
Control (UIC) line. Since the town of Pahala is located mauka of the UIC line, an injection well is not a
viable option.
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 3
3.1.3 Water Recycling
An irrigation assessment was prepared to assess the viability of water recycling as the primary
effluent management system, assuming the recycled water would be used to irrigate macadamia nut
trees. Figure 3-1 is a summary of the assessment that shows there is typically no irrigation demand
for six months of the year due to high rainfall. In addition, the DOH requires that all water recycling
programs have a 100 percent backup disposal system in place to handle flow that does not meet
recycled water quality standards or when recycled water supply exceeds demand. Therefore, water
recycling is not a viable primary effluent management strategy for the community. However, water
recycling treatment, storage, and distribution systems could be added in the future.
8
7
JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
Month
^^—Precipitation Evapotranspiration Irrigation Requirement
Figure 3-1. Irrigation Demand Assessment
3.1.4 Land Treatment
The USEPA defines land treatment as "the application of appropriately pre-treated municipal and
industrial wastewater to the land at a controlled rate in a designed and engineered setting. The
purpose of the activity is to obtain beneficial use of these materials, to improve environmental
quality, and to achieve treatment goals in a cost-effective and environmentally sound manner"
(USEPA, September 2006).
Land treatment systems rely on soil and vegetation to achieve treatment objectives, rather than
energy-intensive mechanical equipment. As such, they are considered to be a form of "natural"
treatment (Crites, et. al., 2014).
Brown and CatdweU •
3-2
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 3
Land treatment is not a new concept. "Land application of wastewater was the first 'natural'
technology to be rediscovered (after passage of the Clean Water Act of 1972). In the 1840s in
England, it was recognized as avoiding water pollution as well as returning nutrients in wastewater
back to the land. In the 19th century it was the only acceptable method for waste treatment, but it
gradually slipped from use with the invention of modern devices" (Crites, et. al., 2014).
The soils at the proposed WWTP location are suitable for slow rate (SR) land treatment. SR land
treatment consists of irrigation of land and vegetation with effluent. Significant treatment is
provided as the water percolates through the soil. The vegetation uses the nutrients in the effluent
as fertilizer, and transpires a portion of the applied water.
3.1.5 Drain Field
A drain field (i.e., leach field) could potentially be constructed for subsurface disposal of treated
effluent. Preliminary assessment of the concept based on the site soil characteristics indicate
approximately 20,000 linear feet of drain field trench would be required to accommodate the
anticipated flow. It would be difficult to evenly distribute effluent throughout a drain field of this size.
In addition, DOH regulations require a redundant drain field for subsurface disposal systems, making
this option expensive to implement. This option is considered impractical for the community.
3.1.6 Recommendation
A slow rate land treatment system is recommended for effluent management for the community.
3.2 Treatment Requirements
The DOH regulates land treatment as "land disposal" per Hawaii Administrative Rules (HAR) 11-62.
Table 3-2 lists the applicable effluent requirements for land disposal applicable to the project that
were in effect at the time this report was prepared.
Table 3-2. Applicable HAR 11-62 Land Disposal Requirements
Description
Value
HAR Reference
BODs
30 mg/L monthly average
11-62-26
60 mg/L peak
TSS
30 mg/L monthly average
11-62-26
60 mg/L peak
Disinfection
Except for subsurface disposal systems, continuous disinfection of the
treated effluent shall be provided
11-62-24
Setbacks
Treatment units shall be not less than 25 feet from property lines nor
less than 10 feet from any building
11-62-23.1
Public accessibility control
6-foot-high fence surrounding treatment units
11-62-08
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Wastewater Treatment Evaluations
This section presents the evaluations conducted in development of the proposed WWTP.
4.1 Preliminary Treatment
The preliminary treatment system will include screening, influent flow measurement, and influent
sampling equipment.
4.1.1 Screening
Screening is recommended to protect the downstream system operations from large objects, debris,
and rags that can be present in wastewater. Aerated lagoon treatment systems require a minimum
of coarse screens to protect the aeration equipment. The industry trend is towards finer screening
systems that remove greater amounts of debris from the waste stream; screens with 6-millimeter
(mm) (V4-inch) openings are frequently used for activated sludge treatment systems. An aerated
lagoon treatment system can benefit from %-inch screening to reduce the amount of floatable debris
on the lagoon shoreline, creating a cleaner facility that is less attractive to birds. Since the Pahala
WWTP will not be continuously staffed, a screening process requiring minimal attention is desirable.
Furthermore, the screenings volume is expected to be small, subsequently screenings disposal is
expected to be infrequent; weekly at most. Therefore, the screenings must be washed of organic
debris to prevent the accumulation of nuisance odors and flies in the screenings barrel or bag
between screening disposal events.
4.1.1.1 In-channel cylindrical screen
We recommend an in-channel cylindrical screen for this installation. The in-channel cylindrical
screen combines screening, screenings washing, dewatering, compacting, and bagging/disposal
within a single unit. The screening portion consists of an inclined screen basket inserted into the
wastewater channel. The screening basket can consist of bars, perforated plates or sieves,
depending on the application and clear opening required. The controls can be set to allow a mat to
build up on the screening surface, allowing finer screening of the wastewater. Controlled by head
loss, a rake arm starts rotating within the screen basket, pushing the screenings off the rake and
into a perforated screenings hopper located at the screen's central axis. A shafted auger along the
screen axis conveys the screenings from the hopper through an inclined tube, which dewaters and
compacts the screenings. The tube includes a perforated dewatering section. The discharged
screenings are about 40-percent dry, and can be discharged into a bin or directly into a bagging
system. Figure 4-1 illustrates the process. Manufacturers include Lakeside and Huber. The key
benefit to this system is the integrated screenings washing system, minimizing additional screenings
handling and odor potential.
For this installation, the headworks will include two in-channel cylindrical screens, one will be on-line
when the other is redundant, plus a bypass channel with manually cleaned bar rack.
Brown AND Caldwell j
4-1
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Pahaia Wastewater Treatment Plant Preliminary Engineering Report
Section 4
Figure 4-1. In-Channel Cylindrical Screen
4.1.2 Influent Flow Measurement
Influent flow measurement is recommended to allow assessment of flows and loads to the biological
treatment process, and to assess the biological treatment process performance. A Parshall flume
will be provided upstream of the screening system to continuously record influent flow rates.
Parshall flumes work well for influent measurement because the flume can operate in an open-
channel configuration, can accommodate wide ranges of flows, and is self-cleaning. A straight
approach length of at least 20 times the flume throat width will be provided upstream of the flume to
provide favorable hydraulic conditions.
4.1.3 Influent Flow Sampling
An automatic refrigerated composite sampler is recommended to allow influent composite samples
to be collected. Influent composite samples, when combined with influent flow measurement, can
be used to calculate influent mass loading rates to the WWTP to assess the treatment performance
and optimization of aeration rates in the biological treatment process. Periodic influent sampling is
also recommended to monitor for changes in the influent characteristics.
4.1.4 Preliminary Design of Headworks
Figure 4-2 shows a plan and section of the proposed headworks. Influent wastewater will enter the
upstream end of the headworks channel. Stop plates will be used to divert the flow to one of the two
the in-channel cylindrical screens, or to the manually-cleaned bar rack. The slide gates will be
designed to allow automatic overflow to the other channels in the event of mechanical screen
failure. The washed and compacted screenings will be deposited in a bag or 55-gallon drum for
periodic disposal. The Parshall flume and automatic refrigerated composite sampler wili be iocated
upstream of the screens. The channels will be covered with fiberglass or aluminum plate to facilitate
foul air collection, which will be conveyed to an odor control unit. In addition, a free-standing roof
structure will be constructed over the headworks to protect the operators and equipment from rain
and sun.
Brown Caldwell •
4-2
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 4
SLIDE
GATES
IN-CHANNEt
CYLINDRICAL
BAR SCREEN
PAR5MALL I
FLUME L
INTLUENT-
INH urNl H.OVV
MHFK AW>
AUrOMATIC SAVPLER
WANUAi I Y~Ci f AN^D
3AK RACK
IN-CHANNEL CYLINDRICAL
BAR SCREEN
FIBERGLASS OR
ALUMINUM PLATE
-•AH3HALL COVERS
"LUME ,
INFLUENT-
SUDh
CA1F
SECTION A - A'
55 QALLCI.X
DRUM
• SLIDE
GATE
— TO
AERATED
LAGOONS
¦ Brown,.™!
jCaldwaUJ
SCALE
«OB NO
PAHALA WASTEWATER TREATMENT PLANT
HEADWQRK3
FIGURE
4-2
Figure 4-2. Headworks
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Pahaia Wastewater Treatment Plant Preliminary Engineering Report
Section 4
4.1.5 Odor Control
A notorious location for foul odor is the headworks of a wastewater treatment plant. This odor is
caused by hydrogen sulfide (H2S), which is formed under anaerobic conditions of the wastewater
collection system. Due to H2S low solubility in wastewater, when there is an excessive concentration
of H2S in the wastewater or if there is turbulence, H2S gas escapes into the atmosphere. This
release produces the distinct rotten egg smell. In addition to H2S, there are other foul odorous
compounds that can be released from wastewater, such as ammonia, amines, diamines,
mercaptans, skatole, and organic sulfides.
Treatment of foul odors can be approached in two ways: preventing odors through liquid treatment
or controlling odors in the gas phase. While liquid treatment provides control of odors prior to their
release, gas phase treatment involves the collection and treatment of gases once they have been
released from wastewater. Treatment methods can be aimed at one type of odor, or can treat a
range of odors.
4.1.5.1 Granular Activated Carbon
A granular activated carbon (GAC) scrubber is recommended for the Pahaia WWTP headworks. A
GAC scrubber passes odorous air through a bed of activated carbon, which adsorbs the odorous
constituents within the pore spaces of the carbon.
Chemical oxidation or reduction of some compounds can also occur. As pore spaces become
occupied, efficiency degrades, and the carbon must be replaced or regenerated. Carbon is most
effective on higher molecular weight molecules such as the organic sulfur compounds, which makes
it the technology of choice. Package GAC scrubbers are available for small headworks and vessels
can be situated vertically, horizontally, or radially to optimize footprints and reduce structure
elevation profiles. Figure 4-3 illustrates the process. The County currently operates GAC scrubbers
at other facilities, and purchases the GAC media in bulk to reduce costs.
t
Treated .Ail
t
Granular Activated
Carbon Beds, typical
Condensate
Drain >
Access
Hatch,
typical
;at«
Will Willli'M
Foul
.Ail
Figure 4-3. Activated Carbon Scrubber (GAC)
| Brown and Caldwell^
4-4
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 4
4.2 Aerated Lagoon Treatment System
The biological wastewater treatment needs at the Pahala WWTP will be met by a series of aerated
lagoons. A floating cover will be installed on the last cell to reduce algae in the effluent. The
preliminary design of the aerated lagoon treatment system is developed in this section.
4.2.1 Aerated Lagoon Kinetics
The Pahala WWTP design is reliant on partial mix aerated lagoon environments to provide the
community's wastewater treatment needs for the initial buildout condition. Partial mix aerated
lagoon kinetics are described below.
4.2.1.1 Partial mix model
Partial mix aerated lagoons are based on the concept of allowing solids to settle in lagoons while
providing only enough aeration and mixing to meet the oxygen requirements of the naturally
occurring micro-organisms in the system. The solids tend to settle in areas of the lagoon that are
subject to less mixing energy, where they anaerobically decompose. Infrequent sludge removal is
required to maintain sufficient lagoon treatment volume.
Removal of BODs in partial-mix aerated lagoons depends on the hydraulic detention time. The
design model for partial mixed ponds of equal size in series is (Crites, et. al., 2006):
Cn _ 1
~Co~ [\ + (kt/n)n
Where Cn = effluent BODs concentration in cell „ , mg/L
Co = influent BODs concentration, mg/L
t = partial-mix first-order reaction rate constant, day1
, = total hydraulic residence time in the lagoon system, day
= number of cells in the series
If the lagoons in a system are of unequal size, then the equation must be applied to each lagoon in
the series. The Ten-States Standards recommends using a value of 0.276 day1 at 20 °C for the
reaction rate constant (Great Lakes - Upper Mississippi River Board, 1997).
4.2.1.2 Mixing in Lagoon Systems
The energy required for mixing in aerated lagoon systems is generally provided by the aeration
system. For partial mix systems the aeration system is sized to provide enough oxygen to maintain
aerobic conditions and no more. For mechanical aeration systems energy input of at least 30
horsepower per million gallons (hp/Mgal) of lagoon volume is required to keep solids in suspension
(Rich, 1999).
4.2.2 Aeration in Lagoon Systems
Oxygen requirements in aerated lagoon systems are based on the organic loading entering the cell.
Supplying oxygen at a rate of 1.5 times the BODs mass entering the cell has been found to be
sufficient to treat the wastewater. The following equation is used to estimate the oxygen transfer
rate (Crites, et. al., 2006):
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 4
N = ~r —=r
a ^~C^ (1.025)(rw"20)
Where N = Equivalent oxygen transfer to tap water at standard conditions (Ibs/hr)
Na = Oxygen required to treat the wastewater (Ibs/hr)
= (oxygen transfer in wastewater)/(oxygen transfer in tap water)
c„ -fflP.y = oxygen saturation value of the waste, mg/L
p = wastewater saturation value/tap water oxygen saturation value = 0.9
Css = tap water oxygen saturation value at temperature Tw
P = ratio of barometric pressure at the site to barometric pressure at sea level
cL = minimum dissolved oxygen concentration to be maintained
Cs = oxygen saturation value of tap water at 20°C and 1 atm pressure
Tw = wastewater temperature, °C
Oxygen can be supplied to aerated lagoon systems using mechanical aerators or diffused aeration
systems. Mechanical aerators are commonly rated by the number of pounds of oxygen the units will
supply under standard conditions per horsepower-hour (lbs. 02/hp-hr). Diffused air requirements are
calculated using the following equation (Crites and Tchobanoglous, 1998):
W
_ oxygen
z~-air
(AOTE)(O2)(yair)(U40)
Where Qair = Required air flow (ft3/rnin)
Woxygen = Oxygen requirements (lbs/day)
AOTE = Actual oxygen transfer efficiency, expressed as a fraction
o2 = Fractional percent of oxygen in air by weight (0.2315)
7air = Specific weight of air (0.075 lbs/ft3 at 1 atmosphere and 20°0
The oxygen transfer efficiency of a diffused air system is a function of the air bubble size and the
depth of the water column. Smaller air bubbles result in higher oxygen transfer efficiencies than
larger bubbles, as do diffusers that are set at deeper depths within the water column.
4.2.2.1 High speed floating aerators
High-speed floating aerators are commonly used for aerated lagoon systems. The units consist of a
motor and impeller attached to a float. The units are typically anchored to the lagoon shore using
cables. High-speed floating aerators are designed to pump water from the lagoon and spray it into
the air, allowing oxygen to diffuse into the water droplets. The high-speed floating aerators can be
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Pahaia Wastewater Treatment Plant Preliminary Engineering Report
Section 4
outfitted with draft tubes to enhance deep water iagoon mixing or anti-erosion plates to ensure water
is drawn from the surface. Figure 4-4 shows a typical high-speed floating aerator.
Figure 4-4. High Speed Floating Aerator
Advantages of this system include low capital costs, relatively high oxygen transfer efficiency, good
mixing efficiency, and simple operation and maintenance. The chief disadvantage of the system is
the creation of aerosols as the lagoon water is sprayed into the air.
Manufacturers of this type of aerator include Aqua-Aerobics, Aerator Products and Europlec/Aerornix
Systems Inc.
High-speed floating aerators are recommended for the Pahaia WWTP due to their relatively high
oxygen transfer efficiency, low capital cost, and simple operation and maintenance. High-speed
floating aerators are easy to remove from service, and can be easily moved between lagoons or cells,
if needed.
4.2.3 Aerated Lagoon Configuration
The normal operating condition for the Pahaia WWTP will be to operate the four iagoon cells in series
as partial mix environments. Figure 4-5 is a schematic representation of the normal operating mode.
The fourth cell will be outfitted with a floating cover to preclude algae growth. Having four lagoons
will allow the County to take a lagoon out of service for maintenance.
LEGEND
PM PARTIAL MIX
® AERATOR WITH INDICATED
HORSEPOWER
INFLUENT
190,000 GPD
300 mgfl BOD5
PM
PM
PM
PM
©
©
©
©
©
190,000 GPD
<30 mg/L BOD5
- SHADE BALL
COVER
Figure 4-5. Normal Lagoon Configuration Schematic
Brown and Caid well :
4-7
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Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 4
Table 4-1 summarizes the results of the aeration and mixing calculations for the normal operational
configuration treating the design average dry weather flow rate of 190,000 gallons per day.
Comparison of the minimum aerator requirements shown in Table 4-1 with the proposed aerator
layout shown in Figure 4-4 reveals that the aerator power supplied exceeds the minimum
requirements. An aerator control system will be provided that will intermittently turn the aerators on
and off in accordance with the operator settings to supply sufficient oxygen to the system.
Table 4-1. Normal Configuration Aeration and Mixing Requirements
Cell
Volume
(gal)
Influent BODs |
(mg/L) !
Effluent BODs
(mg/L)
Minimum Aerator
Requirement (hp)
Mixing Density
(hp/Mgal)
l
80,000
300
139
27
34
2
80,000
139 !
64
13
16
3
80,000
64 I
30
6
7
4
80,000
30 1
<30
2
3
4.2.4 Lagoon Liner
Lagoon liners are required to prevent wastewater seepage into the ground. The liner will be exposed
to sunlight, so resistance to ultraviolet light (UV) degradation is a key factor in the selection of the
liner material, as is the compatibility of the material with typical domestic wastewater characteristics
and ease of liner maintenance. An 80-mil textured high density polyethylene (HDPE) geomembrane
is recommend for this application.
Textured HDPE is known to have excellent UV resistance, good chemical resistance, and generally is
not affected by fats, oils, and grease (FOG). Maintenance of HDPE requires a specialty contractor
who can complete fusion weld repairs. Unlike smooth HDPE, textured HDPE presents minimal
slipping hazard to operations personnel. Furthermore, the anticipated useful service of an HDPE
liner in typical Hawaii municipal wastewater treatment conditions is 25 to 30 years.
Alternatively, the lagoons may be constructed of concrete.
Brown AND Caldwell «
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 4
4.2.5 Lagoon Cover
In the normal operating mode, the final cell in the lagoon series will be covered in order to deprive
algae of sunlight. This will reduce the algae concentration, which can increase total suspended
solids (TSS) levels in the system effluent. The cover should float on the surface of the water, be UV
resistant, suitable for windy environments, and allow for rainwater to pass through the cover to
prevent ponding. A floating shade ball cover is proposed for this installation.
Floating shade balls covers have been used for decades in in the mining, water and wastewater
treatment industries. Figure 4-6 shows the design elements of a typical shade ball, and Figure 4-7
shows how shade balls provide cover on a reservoir. In addition to reducing algae growth, shade ball
covers deter waterfowl from storage ponds. The black, UV-stable HDPE resin has known to withstand
a range of challenging chemical and environmental conditions. Table 4-2 summarizes technical data
for the balls.
I
Table 4-2. Lagoon Shade Ball Cover Application Parameters
Requirement
¦ Description
Algae Control
Balls - 90% shade coverage
Temperature
50°C to 95°C
Wind Resistance
| Balls ballasted with potable water tested in winds of 120 mph (category 3 hurricane)
Waterfowl Safety
Waterfowl do not recognize ball-covered pond as a water body and will not nest on the
unstable surface
Lifecycle/Warranty
The shade balls are warrantied for 10 years, with an expected resin lifeof 25+years
Operations and
Maintenance
Self-cleaning, self-levelling and require little to no maintenance
Balls will move out of the way of maintenance barge, and can be restrained with booms
Little installation effort required
Precipitation does not affect the cover
Sustainability
Resin is recyclable, para ben free and suitable for drinking water applications
Ballast is potable water
Resin can be made from recycled plastic
Environment
Balls have been installed in chemically harsh environments (mining industry), in drinking water
reservoirs, and in tropical locations
Balls reduce algae formation and corresponding disinfectant byproducts in chlorination
applications
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4-9
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Pahaia Wastewater Treatment Plant Preliminary Engineering Report
Section 4
DIMENSIONS
About 4 Inches In diameter
and weighs approximately
245 grams
PLASTIC MATERIAL
The ,04 Inch
walls are made
o« high density
polyethylene, the
same material used
to mold milk Jugs.
SPA free a net NSF
certified for contact
with drinking water
The ball:
WATER
BALLAST
Filled will* air.
with some
holding about
205 grams
of water
so they arc
more deeply
Immersed and
do not blow
away
Figure 4-6. Floating HOPE Shade Balls
Figure 4-7. Floating shade bails with current and turbulence in reservoir.
Brown Caldwell •
4-10
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Pahaia Wastewater Treatment Plant Preliminary Engineering Report
Section 4
4.2.6 Lagoon Sludge Management
Partial -mix aerated lagoons are designed to allow solids to settle to the bottom of the lagoon, forming
a sludge layer. The sludge slowly anaerobically digests in the bottom of the lagoon. The mechanical
aerators in the lagoon maintain an aerobic water cap at the surface of the lagoon that oxidizes any
odors that are released from the anaerobic sludge layer at the bottom of the lagoon. Sludge is
removed infrequently, typically every 15 to 30 years, when the sludge blanket thickness begins to
affect treatment performance or in conjunction with lagoon liner replacement. Aerated lagoon
operators typically monitor sludge blanket thicknesses semi-annually to assess sludge accumulation.
Sludge removal contractors are typically employed to dredge the solids, dewater, and haul to a
landfill for disposal. Sludge from aerated lagoons is typically not offensive when dewatered due to
the long residence time in the bottom of the lagoon.
Alternatively, the sludge can be recycled if a permitted land application site is available and the
sludge meets State and Federal requirements for land application or composted with green waste at
a permitted composting facility.
4.3 Subsurface Flow Constructed Wetland
A subsurface flow constructed wetland is recommended to provide additional treatment and
polishing of the aerated lagoon effluent. It is anticipated that the aerated lagoon system will convert
ammonia that is present in the wastewater influent into nitrate via a process called nitrification. A
subsurface flow constructed wetland will remove this nitrogen from the wastewater via a process
called denitrification. Reduction of nitrogen loading through the constructed wetland will decrease
the area required for overland flow effluent management.
Subsurface flow wetlands consist of shallow lined basins that are filled with gravel media and
planted with emergent wetland vegetation. Water is introduced to the gravel media layer and flows
horizontally through the basin. The water level in the wetland is maintained below the gravel surface
at all times. Treatment occurs through physical, chemical, and biological mechanisms as the water
flows horizontally through the gravel media bed. Figure 4-8 is an illustration of the concept.
WETLAND
ROCK INLET ZONE VEGETATION ROCK OUTLET ZONE WATER LEVEL
CONTROL
GRAVEL MEDIA
LINER OR COMPACTED SOIL
Figure 4-8, Subsurface Flow Constructed Wetland Concept
4.3.1 Denitrification in Subsurface Flow Constructed Wetlands
Denitrification is a biological process whereby nitrate molecules are transformed into nitrogen gas
molecules by naturally-occurring bacteria. The denitrifying bacteria require five conditions for the
process to occur:
• A place to grow.
Brown Caldwell •
4-11
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 4
• A source of nitrate.
• An anoxic (low-oxygen) environment.
• A source of carbon.
• Adequate water temperature.
The equation used to predict denitrification in subsurface flow constructed wetlands is shown below
(Crites, et.al., 2014).
7T = exp (~KTt)
where:
Ce = effluent nitrate-nitrogen concentration (mg/L)
C0 = influent nitrate-nitrogen concentration (mg/L)
KT = temperature-dependent rate constant = 1.00(1.15)~205 days1 when T>1°C
t = hydraulic residence time (days)
Subsurface flow constructed wetlands are capable of providing additional treatment benefits beyond
nitrogen reduction, such as removal of organic carbon, suspended solids, phosphorus, metals, trace
organics, and pathogens. The additional treatment benefits are not primary design parameters, but
should be considered as additional polishing treatment benefits that may be realized for the Pahala
WWTP.
4.4 Disinfection
Disinfection processes selectively kill pathogens or render them incapable of reproduction or harm to
humans. Disinfection at WWTPs is employed for the purposes of protection of public health,
reduction of organic matter, inorganics, nutrients, odor, aesthetics, and maintaining waste-
assimilative capacity of receiving water bodies. The protection of public health through the control of
disease-causing microorganisms is the primary reason for wastewater disinfection (WEF, 1996). As
the last barrier of protection from pathogenic organisms, disinfection at WWTPs is an important
process. To address disinfection, both a calcium hypochlorite system and a UV system were
evaluated.
4.4.1 Calcium Hypochlorite
Calcium hypochlorite is the most common solid form of hypochlorite used for disinfection. It can be
found as a powder, granules, pellets, or as tablets in concentrations up to 70 percent. Calcium
hypochlorite will degrade in strength at a rate of 3 to 5 percent per year. Once applied to the
wastewater, the chemistry is similar to that for sodium hypochlorite. Calcium hypochlorite
decomposes in an exothermic reaction if exposed to moisture.
The solid can be directly applied to wastewater at very small WWTPs. Figure 4-9 shows a typical
calcium hypochlorite feed system.
Brown AND Caldwell j
4-12
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Pahaia Wastewater Treatment Plant Preliminary Engineering Report
Section 4
Treated water Chlorinated water
Service valve
Flowmeter
Service valve
Check valve
Flow control valve
Pump
x Hypochlorite tablets
Figure 4-9. Typical Calcium Hypochlorite Feed System
The advantages of using calcium hypochlorite for disinfection at small, remote WWTPs is that it is
available in concentrated form as powder, pellets, or tablets. This makes the transportation and
storage of disinfectant optimal for small WWTPs. Table 4-3 summaries calcium hypochlorite
characteristics.
Table 4-3. Calcium Hypochlorite Summary
Description
Characteristic
Transported form
Solid
Typical transported concentration
70%
La rgest tra n spo rted vo 1 um e ava i la ble
55 lb. pails
Decay Rate
Decays 3-5% peryear
pH
N/A
Hazards
Toxic if ingested (usually through dust or liquid form)
Storage constraints
Must be stored in a cool, dry, dark place
Special equipment
Tablet feeder
Particular issues
Heats and combusts if not stored properly Scaling in pipes, Off gassing
4.4.1.1 Dose and Contact Time
The effectiveness of a chlorination system is highly dependent on the characteristics of the
wastewater, the initial mixing and contact time, and the chlorine dose used. For nitrified effluent, the
recommended dose is between 8 and 18 mg/L. The WWTP will discharge to a land application
system during normal flow and wet weather periods when the secondary effluent will be diluted by
precipitation falling onto the overland flow terraces. For planning purposes, a 10 mg/L dose was
assumed to be sufficient for the WWTP for most circumstances, but equipment will be sized to
Brown Caldwell •
4-13
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Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 4
provide chemical feed at a rate of up to 100 Ibs./day, which will ensure an adequate chlorine dose
for peak wet weather discharge flows.
Table 4-4 lists the chlorine demand for various flow conditions.
——
Description
Flow
Chlorine Demand
Average dry weather flow |
0.19 mgd |
16 Ibs./day
Peak day wet weather flow |
0.662 mgd I
55 Ibs./day
The recommended minimum contact time for chlorination is 15 minutes (Ten States Standards
Wastewater, Recommended Standards for Wastewater Facilities, 1997, Great Lakes - Upper
Mississippi River Board of State and Provincial Public health and Environmental Managers). The size
of the chlorine contact tank will need to accommodate a 15-minute contact time for the peak
discharge rate. For this application, the peak discharge rate will be equal to the peak day wet
weather flow, due to the flow equalization provided by the aerated lagoons. Table 4-5 summarizes
the contact tank dimensions, while Figure 4-10 shows a conceptual contact tank configuration.
Table 4-5. Chlorine Contact Tank
Description
Value
Peak discharge rate
460 gpm
Minimum chlorine contact tank
15 minutes
Tankvolume required
920 cubic feet
Channel water depth
5 feet
Channel width
3 feet
Tank channel total length
61 feet
Tank dimensions including channel walls
13 feet x 24 feet
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4-14
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 4
WASlr'A'AlhH
J
-C
DISINFECTED
tTL'JE-C
1 CHLORINE
SOLUTION
TO CHLOR'MATQR
BUDDING
CHLORINE
C OSTAC""
THAMME-
Brown ,
Caldwell
SCALE Fieia
JOB NJMEER: 150440
PAHA;. A wastewater treatmen~ =lant
CHLORINE CONTACT TANK
CONFIG U RATI ON
FIGURE
4-10
Figure 4-10. Chlorine Contact Tank Configuration
Brown a® Caldwell •
4-15
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 4
4.4.2 Ultraviolet Light (UV) Disinfection
A common alternative to a chlorine disinfection is ultraviolet light (UV). Ultraviolet systems destroy
microorganisms by affecting their deoxyribonucleic acid (DNA) and ribonucleic acid (RNA) and impeding
their ability to reproduce. A UV disinfection system is comprised of lamps, a reactor, and control
panel. Wastewater can flow either parallel or perpendicular to the lamps in the reactor, while the
control box provides a starting voltage and maintains the continuous current needed. Currently,
most systems are equipped with an automated lamp cleaning system, to maintain lamp efficiency
levels.
A UV system's effectiveness is dependent on the characteristics of the wastewater, the dose, and the
exposure time. In the case of UV radiation, the most important factor is the transmittance of the
water, which has a direct effect on the ability of UV light to penetrate through the liquid and reach
microorganisms present at the required intensity. Ideally, the discharge undergoing treatment
should not have a transmittance lower than 55 percent, with the intensity decreasing the farther the
microorganisms are from the lamp. The optimum wavelength to effectively inactivate
microorganisms is between 250 and 270 nanometer.
The main types of UV lamps used for wastewater disinfection are conventional low-pressure lamps,
low pressure high output (LPHO) lamps and medium pressure lamps. Several UV systems include
lamps with automated sleeve cleaning.
4.4.3 UV System Design Summary
A UV disinfection system requires a about the same size footprint as chlorine. Disinfection occurs as
the organism is exposed to the UV radiation as the water flows past the UV lightbulbs. The Trojan
UV3000+ system is used at numerous facilities across the US, including some treatment plants in
Hawaii. The estimated cost included in this report are based on an assumed UV transmittance of 65
percent. The amalgam lamp used with the UV3000+ system has an end-of-lamp-life factor (ELLF) of
0.98 indicating little loss in UV light output over the life of the lamp. This ELLF has been tested and
approved by the State of California and is also accepted by the State of Hawaii for reuse
applications. The system would use LPHO lamps with automatic sleeve cleaning. LPHO lamps are
energy efficient and the UV300+ system is furnished with automatic sleeve cleaning devices to
reduce labor requirements. Each UV lamp is enclosed in a quartz sleeve to separate it from the water
medium. Each lamp draws 254 watts at full output and is driven by electronic ballast. The
electronic ballast allows the lamps to be dimmed to conserve power based on a control signal from a
flow meter. The LPHO lamps will have a minimum life of 12,000 hours when operated in an
automatic mode and limited to a maximum of 4 on/off cycles per 24 hours. Table 4-6 summarizes
the size and design criteria for the UV system required to treat the WWTP discharge.
I
able 4-6. UV Disinfection Design Siiinnm
I
Description
Value
Peak Hour Wet Weather Discharge
| 630 gpm
Minimum UV transmittance
65 percent
No. of UV channels
1
Design dose
35,000 pWs/cm2
Disinfection limit
30 e-coli per lOOmL
Validation factors
0.98 end of lamp factor
Brown AND Caldwell •
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 4
4.4.4 Cost Evaluation
A summary of capital and life-cycle estimated costs for both chlorination and UV disinfection is
presented in Table 4-7 for comparison.
The capital costs include the materials and equipment costs, construction costs, electrical,
instrumentation and control, soft costs, and contingency. As shown in the table, the UV option incurs
higher capital costs. The life cycle costs look at the impact of the capital costs along with the annual
operations and maintenance costs, including power, materials, chemicals, and labor costs over the
next 30 years. The life-cycle costs for chlorination option appear to be about 78 percent of the UV
option.
Tnblc4-7. Estinintcd Disinfection Costs
Description
Chlorination
UV System
Capital Cost
| $200,000
$800,000
Annual Operations and Maintenance
I $15,000
$6,000
Life-cycle Cost (30-Year Net Present Value)
$746,000
$947,000
4.4.4.1 Non-Economic Evaluation
Table 4-8 presents a summary of advantages and disadvantages of using an ultraviolet light for
disinfection.
Table 4-8. Ultraviolet Disinfectio
l - Advantages and Disadvantages
Advantages
Disadvantages
Effective at inactivating most viruses, spores, and cysts
Low dosage may not be effective on some pathogens and
some organisms can repair and reverse the destructive
effects of UV
It's a physical process, instead of chemical - it
eliminated the need to transport, handle, store toxic or
corrosive chemicals
Turbidity and TSS in the wastewater can reduce UV
disinfection effectiveness
No harmful residual compounds created that are toxic to
humans or aquatic life
Will likely require more call-outs by operators due to
alarms caused by "dirty power".
Shorter contact time (less than a minute)
The relative intensity of equipment maintenance
requirements, including staffing training and on-island
avaliablity.
4.4.5 Disinfection Recommendation
A4aMet-eM0fiH'a#efl-^ystefl^-fte-re^efimefl4e444slMeeti0R-0p#efl-^vef4^e-yV-systeffl-f0f4-he
WWTF-keeatfse-tt4ftews-lewefr^aftto<-aft44tfeeyete-eeste. I n a4ditl0R74aMet-€W0ma#eB-wlti be
fnefe-retiakle4haft The County has elected
to install a UV system at the Pahala WWTP, to reduce the use of chemicals at the facility. An
uninterruptable power supply may be installed to address "dirty power" concerns.
Brown AND Caldwell \
4-17
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 4
4.5 Effluent Management
For effluent management, a slow-rate land application system is proposed. The concept is to
intermittently apply wastewater to crops growing in permeable soils. As the applied water percolates
through the soil matrix or is taken up by the crop, it is treated by physical filtration and by biological
mechanisms. After an application period or wetting period, the surface can dry and oxygen can enter
the soil matrix, which aids aerobic biological treatment. The frequent wetting and drying also
maintains the infiltration rate through the soil surface and minimizes soil clogging. This method of
land application is an effective treatment process for BODs, TSS, trace organics, phosphorus, metals
and pathogen removal. Furthermore, removal of nitrogen can be significant when system is
managed for that objective.
4.5.1 Design
The slow-rate system site consists of a net area of approximately 5.5 acres. The 5.5 acres will be
divided into 4 small groves of native trees, so that water application will be rotated to a different
grove each day. An additional small grove will bo utilized as an emergency (overflow) or reserve
when surface or distribution system maintenance is conducted. By using one groove per day the
wet/dry cycle will be 1-day wetting and 3-days drying.
The groves will be planted with native Hawaiian trees. Trees grown within the land application area
will need to be water tolerant. Table 4-9 lists potential native tree species.
m
gyyjjyyl
mm
Common Name
Genus Species
Salt
Tolerance
Water Requirements
Rubbish and
Maintenance
Preferred Elevation
Milo
Thespesia populnea
Very
Dry to Wet
| Moderate
Low to Medium
Loulu
Pritchardia hillebrandii
Very
Dry to Wet
| Low
Low
Aalii
Dodonaea viscosa
Very
Dry to Medium
Low
Low to High
Kou
Cordia subcordata
Very
Dry to Wet
Moderate
Low
Golden Loulu
Pritchardia arecina
Moderate
Dry to Wet
Low
Low to Medium
Wiliwili
Erythrina sandwicensis
Moderate
Dry to Medium
Moderate
Low
The distribution system will consist of gated piping located on the surface. The piping will have slots
to allow the applied wastewater to uniformly be distributed over the grove surface. A perimeter
fence will be installed to limit access. Access roads will surround each grove. Figure 4-11 reflects
the proposed land application schematic.
Brown AND Caldwell «
» m il
4-18
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 4
J v..
PLAN
VAl'.TtNAN.-.i
HI A'l !
.'i
X
Jt
r uc n\u
SECTION A - A'
¦«>!)
Brown w !
Caldweli 8
S, A; .-I V - 'tv
\w.iI IWft" LH 'WVMW.N* !'LANI
i ANii aivl irA'ii >*,- s* sim u nr i» i n:
4-11
Figure 4-11. Land Application System Schematic
Brown a® Caldwell •
4-19
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 4
4.6 Ancillary Systems
4.6.1 Water
Potable water is not currently available at the site. The nearest potable water system is located
uphill in town. Table 4-10 provides an initial assessment of the potential water demands at the
WWTP. The water demands are either for process or potable uses. As shown in the table, the
process water demands are significantly greater than the potable demands.
Tabic 4-10. Potential Water Demands
Description
Flow Rate
Type
Priority
Screenings washer |
20 gpm for 10 min/hour
4,800 gpd
Process
Mandatory with screen
Hose bibs I
10 gpm for20min/day
200 gpd
Process
j Desirable to maintain facility
Emergency eye wash / shower |
20 gal peruse
Potable
| Mandatory
Restroom I
20 gpd
Potable
Recommended
To supply water to the WWTP, it is recommended to construct approximately 2,000 linear feet of pipe
from the intersection of Huapala Street and Maile Street to the site and install a 1-inch water meter
with 112-inch backflow preventer.
A plant water system will be supplied by the County water meter. The on-site water system will be
split into two branches, one for process water and one for potable water. The potable water will
service the restroom and emergency eye wash/shower. A second backflow preventer will separate
the process water uses from the potable connections.
4.6.2 Access Road
All weather access will be required to operate and maintain the WWTP. Access to the site will be
provided by connection to Maile Street. A paved driveway apron is proposed at Maile Street and an
all-weather driveway will extend into the site and provide access to and around the various WWTP
infrastructure. Additionally, a turn-around area large enough to accommodate a fire truck will be
provided.
Access road pavement options include aggregate base (AB) gravel, asphalt concrete (AC), or
concrete. AB is the lowest cost option, but requires the most maintenance. AC pavement is not
recommended for steep (greater than 12 percent) grades. Concrete is the highest cost option, but is
the most durable and requires the least maintenance.
The recommended driveway pavement section is 2-inches of AC over 6-inches of aggregate base
course. For portions of the driveway that exceed 12 percent slope, a concrete pavement section is
recommended.
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Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 4
4.6.3 Stormwater Management
The overall goal of stormwater management is to mitigate the adverse impact of new construction on
the environment. Stormwater management can generally be separated into two areas:
1. Stormwater Quantity: management of the quantity to prevent increased flows and
volumes leaving the site on the downstream watercourses.
2. Stormwater Quality: management of the quality of stormwater runoff to prevent
contaminants such as silt, trash, hydrocarbons, heavy metals, and pesticides from
leaving the site through stormwater runoff.
4.6.4 Pre-development Stormwater Conditions
4.6.4.1 On-site
The majority of the proposed 42.5-acre site is currently utilized as macadamia nut orchards,
consisting of trees or unimproved agricultural roads. The parcel is bound on two sides by improved
county and state right-of-way and to the east by additional macadamia nut orchards.
The existing elevations range between 580 to 780 feet above mean sea level (MSL) and slopes in
the southerly direction at an average rate of 8 percent. The soils in this area are described as
Naalehu medial silty clay loam (NaC) by the Soils Conservation Service (SCS). These soils are
considered well drained with low runoff and slight erosion hazard.
On-site stormwater run-off generally sheet flows in a southerly direction to off-site swales along the
roadway frontages, Maile Street and Hawaiian Belt Road (also known as Mamalahoa Highway).
There is no known on-site drainage collection system, see Figure 4-12.
4.6.4.2 Off-site
Swales that run and collect along the roadway frontages of the property are conveyed through a box
culvert at the intersection of Maile Street and Hawaiian Belt Road and discharged makai. Similarly,
running along the north property line is an abandoned concrete flume, which was previously utilized
to discharge process water from the adjacent old sugar mill to agricultural land makai of Hawaiian
Belt Road. Figure 4-12 conceptualizes the existing drainage system.
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Pahaia Wastewater Treatment Plant Preliminary Engineering Report Section 4
TMK
TWK: (9>hM02A»
¦Emum
roadway
CIA VERT
PAHALA WASTEWATER TREATMENT PLANT
Brown™
Caldwell
Figure 4-12. Existing Drainage System
Brown Caldwell •
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Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 4
4.6.4.3 Flood Hazards
The subject property flood zone is designated Zone X, area of minimal flood hazard corresponding to
areas outside of the five-hundred-year flood plain, as indicated on the current September 29, 2017
Flood Insurance Rate Map (FIRM), Community Panel No. 1551661800F. Zone X designations are
not subject to the requirements of the Standards of Floodways, Chapter 27, Section 22 of the Hawaii
County Code. See Figure 4-13 for the Flood Insurance Rate Map.
On April 16, 2018, the State of Hawai'i Department of Land and Natural Resources Engineering
Division stated the responsibility for conducting research as to the flood hazard designation for the
project site lies with the project proponent Also on April 16, 2018, the County of Hawai'i
Department of Public Works confirmed that the proposed treatment and disposal project site at Site
7 is designated as Zone X on the FIRM and is outside the 500-year floodplain.
The WWTP site slopes from approximately north to south (mauka to makai) such that, during rain
events, surface flows pass through the existing orchard to the southern (makai) end where the flows
eventually drain through the culvert located at the Maile Street-Mamalahoa Highway intersection to
the areas below (makai) the highway. Most of the land surface area below the existing macadamia
nut orchard contains little to no vegetation to absorb or slow these flows. The gradient of the site
and surrounding area results in this natural pattern of surface flows which also existed when the
area was planted in sugar cane and is not considered flooding.
Based on the roadway flooding concerns expressed by the community during the Pahala public
meetings held in December 2017 and October 2018, the State of Hawai'i Department of
Transportation (DOT) Hawai'i District office was contacted to discuss drainage at the treatment and
disposal facility project site and the culvert at the Maile Street and Mamalahoa Highway
intersection. On February 20, 2019, the District office confirmed via telephone that the DOT owns
and maintains the culvert at the Maile Street intersection, and that they have no record of the
roadway being inundated by stormwater drainage during storm events.
Stormwater drainage flows generated from the existing orchard mauka of the treatment and
disposal facility project site will be directed around the perimeter of the site via diversion swales that
will convey flow back to the existing drainage pattern that flows to the existing culvert at Maile
Street. During heavy rain events, stormwater may temporarily back up behind the culvert. There
will be no changes to this culvert and the WWTP facilities will not be located within the area of the
culvert
The on-site stormwater management system to collect runoff via grated inlets or swales, and flows
would be conveyed to on-site drainage detention systems, such as subsurface linear infiltration or
depressed detention basins. Landscape buffers with dirt berms would also be constructed around
most of the perimeter of the facility to act as secondary containment in the event of a large storm
event. The on-site stormwater management system would meet the requirements of Hawai'i County
Code, Chapter 27, Section 20, which mandates drainage plans to accommodate runoff caused by
the facility for a 1-hour, 10-year storm event.
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 4
Brown i
Caldwell
¦
¦¦Bill
Figure 4-13. Flood Insurance Rate Map
Brown a® Caldwell •
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Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 4
4.6.4.4 Stormwater Quantity
The increase in peak flow and runoff volume is a function of the increase in impervious areas
associated with the proposed improvements.
All exposed (not enclosed) treatment processes will be sized to include free-board depth to
accommodate the 24-hour, 100-year storm event. Thus, no stormwater runoff from these areas is
anticipated.
A drainage system will be designed to address stormwater surface run-off caused by impervious
portions of the WWTP development. Per the Hawaii County Code, Chapter 27, Section 20, the site
drainage plan shall accommodate the run-off caused by the proposed development, within the site
boundaries, for a one-hour, ten-year storm event. The pre-development runoff (10-year, 1-hour
storm) is approximately 23 cubic feet per second (cfs). The post-development runoff is
approximated at 24.5 cfs, which is a net increase of 1.5 cfs.
To ensure that there is no adverse impact on adjacent or downstream properties due to post-
development flows, an on-site drainage system will collect runoff via grated inlets or swales. These
flows will be conveyed to on-site drainage detention systems, such as subsurface linear infiltration or
depressed detention basins, to detain flows and volumes to their pre-development condition.
Furthermore, landscape buffers with dirt berms will be constructed around most of the perimeter of
the property acting as secondary containment in the event of a large storm event.
A complete analysis of the pre and post development drainage condition will be completed during
the design phase. The site drainage plan will be prepared to comply with sections 27-20(a) and (b)
and section 27-24, and shall include a storm water disposal system to contain run-off caused by the
proposed development, within the site boundaries, up to the expected one-hour, ten year storm
event as shown in the department of public works "Storm Drainage Standards"." A geotechnical
engineering assessment of berm stability will be conducted during the design process for any berms
constructed to act as secondary containment in the event of a large storm event.
To meet the requirements of HCC, Chapter 27, Section 20 (f), the project site "shall not alter the
general drainage pattern above or below the development". Thus, no increase in flow amount will
be directed to either of the culverts at the highway as a result of the site development. A drainage
study will be prepared during the design process to evaluate the improvements necessary to comply
with HCC requirements.
The wastewater treatment processes will be designed to accommodate the peak flows during wet
weather events, including precipitation that falls on the area occupied by the aerated lagoon
treatment system. Section 2 outlines the anticipated peak wastewater flows from the community,
based on the applicable flow standard. The aerated lagoons will be lined with high density
polyethylene liners or concrete to prevent water seepage through the bottom and sides of the
lagoons. The aerated lagoons will be designed with operational freeboard that will be available to
contain and to equalize lagoon flows during peak wet weather events. In addition, the slow-rate land
application groves will be designed to completely contain both peak effluent flows and precipitation
from a 100-year, 24-hour storm event. This will be accomplished by constructing berms around the
land application tree groves. The tree groves will be designed in accordance with the EPA's "Process
Design Manual, Land Treatment of Municipal Wastewater Effluents". Effluent will be applied at a
hydraulic loading rate that is a small percentage of the percolation rate of the soil, ensuring
sufficient capacity for assimilation of peak effluent flow rates and precipitation from the design
storm event.
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 4
4.6.4.5 Stormwater Quality
The quality of stormwater leaving the site is also a concern. Stormwater quality degrades with
development and increased impervious surfaces, because various pollutants are introduced into the
stormwater runoff.
The first half-inch of runoff during a storm is referred to as the Water Quality Volume (WQV) or the
"first-flush" volume. This portion of the runoff from a storm contains measurably more suspended
solids plus other contaminants per cubic foot than would be expected in runoff occurring later in the
storm.
To mitigate the quality of runoff, the drainage system will incorporate permanent Best Management
Practices (BMP's). Recommended permanent BMP include scheduled good-housekeeping, which
will reduce litter and other constituents from being washed into the storm drain system, and
detention basins and underground infiltration facilities that prevent the release of sediment and
other pollutants to downstream waterways or adjacent properties. A full assessment of all available
BMP's to optimize water quality will be provided during design of the project.
4.6.5 Electrical Systems
It will be necessary to bring electrical power to the WWTP site. It is anticipated that Hawaii Electric
Light Company (HELCO) will bring overhead power lines to the site and supply 480-volt, 3 phase
power to the WWTP via a pole-mounted transformer to a service panel with a meter.
The floating surface aerators will consume the majority of the electricity supplied to the site. An
electrical room will house the electrical gear, plant control equipment and the chlorination system.
Exterior lighting at the site will be limited to manually switched lights at the entrance to the electrical
building and at the headworks area.
A standby power system will be provided in the form of a pad mounted diesel generator and above-
ground fuel tank with capacity to support three consecutive days of operation. In addition, the
electrical service panel will be equipped with a manual transfer switch and generator receptacle to
allow connection of a trailer-mounted generator in the event of emergency generator failure during
an extended power outage.
4.6.6 Telemetry Systems
A land-line telephone telemetry system with auto-dialer will be provided to provide Hilo-based
operation staff of alarm conditions and key operational parameters at the WWTP. Additionally, a cell
phone will be available for backup.
4.6.7 Operations Building
An operations building will be constructed to include the electrical room, chlorinator generator room,
restroom, and maintenance/storage room, as shown in Figure 4-14.
4.6.8 Site Fencing
The entire WWTP site, including the treatment systems and the land application system, will be
fenced (6-foot high chain link) and posted to prevent public access.
4.6.9 Alternative Energy
The WWTP does not include utilizing alternative energy systems such as photovoltaic solar as a total
replacement for connecting to the HELCO grid due to:
Brown AND Caldwell j
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Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 4
• the need for consistent power supply;
• emergency backup power requirements;
• up fron t capital cost;
• full utilization of the 14.9-acre proposed site for the treatment and disposal facility;
• objective to minimize the amount of land area removed from agricultural production; and
• EPA-enforced project implementation schedule deadlines.
Partial augmentation of traditional power utilizing photovoltaic solar panel arrays on the headworks
and operations building rooftops will be further analyzed during the detailed design phase after
loads, demand patterns, and roof orientation are better understood. Additional alternative energy
systems can be added in the future if prioritized and funded by County Council, and the electrical
systems will be designed to accept additional alternative energy input. The capital cost for rooftop
photovoltaic solar is estimated to be approximately $13,000 per kW of peak capacity.
Methane gas is generated at wastewater treatment plants using a process called anaerobic
digestion. The proposed WWTP is too small for anaerobic digestion to be economical; the design
flow to the Pahala WWTP is 190,000 gallons per day, and anaerobic digestion is only economically
attractive for WWTPs that treat at least 5 to 10 million gallons per day. In addition, the anaerobic
digestion process requires primary darifiers as part of the liquid treatment process, but primary
clarifiers tend to be odorous in tropical climates, due to the relatively high wastewater
temperatures. The proposed alternative relies on natural treatment systems that require relatively
low energy input.
Small-scale wind generation systems require a high level of maintenance attention due to the
mechanical systems required to convert wind energy into electricity, and is not appropriate for a
small, remote wastewater treatment facility.
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 4
I
r ;¦ r ^ 1,
Brown ik 1
Caldwell ,
H.Mfc, ,i1* '
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PAHALA WA5TFWATE R TREATMENT R ANT
OPERATIONS BIMtOlNS PRELIMINARY FLOOR WAN
4-14
Figure 4-14. Operations Building Preliminary Floor Plan
4-28
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Preliminary Design of
Improvements
The following is a summary of the preliminary design for the proposed Pahala WWTP.
5.1 Site Plan
The existing parcel is an active macadamia nut tree orchard. The prevailing grade is in the north to
south direction at 5 to 10 percent slope. Approximately 14.9 acres of the land will be cleared for the
construction of the proposed facility. Figure 5-1 presents a preliminary site plan for the WWTP.
5.2 Process Schematic
Figure 5-2 presents the recommended facilities process schematic.
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Pahaia Wastewater Treatment Plant Preliminary Engineering Report
Section 5
PkAlNAt^t WAV
SCALE IN FEET
PAHALA WASTEWATER TREATMENT PLANT
SCALE: 1" = 200'
JOB NO: 150440
FIGURE
Brown mu
Caldwell
PRELIMINARY SITE PLAN
Figure 5-1. Preliminary Site Plan
Brown Caldwell •
5-2
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Pahaia Wastewater Treatment Plant Preliminary Engineering Report
Section 5
¦ WW FLOW PATH
. WW AlTFRNATIVf FLOW PATH
II
!
it
AUTOMATIC 1
SCREEN ?
ACRATED LAGOONS
CONSTRUCTED
WtJLAWU
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IRRIGATION
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SCALE" NONE
JOB NO; 150440
PAHALA WASTEWATER TREATMENT PLANT
RECOMMENDED FACILITIES PROCESS SCHEMATIC
etGUfffi
5-2
Figure 5-2. Recommended Facility Process Schematic
Brown and Caid well :
5-3
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Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 5
I
Influent flows:
#
Average dry weather
190,000 gpd
#
Pea kday wet weather
662,000 gpd
#
Peak hour wet weather
630 gpm
Influent characteristics
#
BODs
300 mg/L
#
TSS
300 mg/L
Odor control - granularactivated cartoon
#
Airflow rate
500 cfm
#
H2S Inlet concentration
1-10 ppm
#
H2S removal efficiency
99%
#
Media type
High-capacity cartoon
#
Vessel diameter
3 feet
#
Vessel height
6 feet
#
Minimum cartoon quantity
570 lbs
#
Minimum bed depth
3 feet
#
Fan motor
2 hp
#
Nominal inlet size
8 inches
Mechanical screens
#
Number of units
2
#
Type
In-channel cylindrical
#
Screen opening size
0.25 inch (6 mm)
#
Maximum flow rate capacity
Greater than 625 gpm each
#
Screening washing
Integral
#
Screening compaction
Integral
#
Screening wash water flow
20 gpm
#
Screening wash water pressure
50 psi
Bypass screen
#
Type
Manually-cleaned barrack
#
Bar spacing
1 inch
#
Rake
Interlocking with bars
Screenings receptacle
Brown** Caldwell {
nil 1
5-4
5.3 Design Criteria
Table 5-1 provides preliminary design criteria.
Table 5-1. Preliminary Design Critcr
Description
Value
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 5
able 5-1. Preliminary Design Criteria continuec
•
Type
55-gallon drum or bags
#
Screenings volume per million gallons treated
5 fWMgal
#
Estimated screenings quantity
1 ft3/day
#
Disposal frequency
1/week
Influent flow metering
#
Type
Parshall flume
#
Maximum flow capacity
Greater than 630 gpm
#
Minimum straight upstream channel section
20 times the throat width
Influent flow sampling
Refrigerated automatic composite sampler
Lagoon cells
•
Number of cells
4
•
Maximum lagoon temperature
25°C
•
Minimum lagoon temperature
20°C
•
Freeboard
3 feet
•
Working water depth
15 feet
•
Allowance for sludge
3 feet
•
Total water depth
18 feet
•
Side slope
3(H): 1(V)
•
Working volume of lagoon 1 to 3
0.80 Mgal
•
Working volume of lagoon 4
1.60 Mgal
Aerators
•
Type
Floating mechanical surface aerators
•
Cell 1 aerators
30 hp (2 at 15 hp)
•
Cell 2 aerator
15 hp
•
Cell 3 aerator
10 hp
•
Cell 4 aerator
5 hp aspirator style, floating ball cover foralgae control
Constructed Wetland
•
Water temperature
25 degrees C
•
Aerated lagoon effluent nitrate-N concentration
19 mg/l
•
Aerated lagoon effluent ammonia-N concentration
1 mg/l
•
Constructed wetland effluent total N concentration
15.3 mg/l
•
Total constructed wetland surface area
0.25 acres
•
Flow path length
50 feet
•
Hydraulic application width
200 feet
•
Media depth
24 inches
•
Media type
Medium gravel, Dio = % inch
5-5
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 5
Table 5-1. Preliminary Design Criteria continued
• Media porosity
38 percent
• Percolation prevention system
60 mil high density polyethylene (HDPE) liner
• Vegetation
Native Hawaiian reeds and/or rushes, species to be
determined
Disinfection system
• Type
UV
« Fern
Cateium-hypeehtefiteteblets
® BeaigR-eMeme-dese
40-mg/L
« GMeme-eeirtaeHime
15 minutoo minimum
Effluent flow metering
• Type
Magnetic
Effluent sampler
• Type
Refrigerated automatic composite
Effluent quality
• BODs
Less than 30 mg/L monthly average
Less than 60 mg/L peak
• TSS
Less than 30 mg/L monthly average
Less than 60 mg/L peak
Effluent management system
• Type
Slow-rate land application groves
• Number
4
• Minimum depth
5 feet
• Design percolation rate
0.0095 inches per minute
• Design application rate
8 percent of percolation rate
• Distribution system
Gated pipe
• Storm water containment
100-year, 24-hour storm event
• Vegetation
Native Hawaiian trees
Storm water site management
10-year, 1-hour storm
5.4 Environmental Benefits
A well-designed and managed land treatment system limits wastewater application to rates to
minimize adverse impact to groundwater quality. The deep percolate from the SR land treatment
system is expected to contain less than 1 mg/L of BODs and TSS. While the State of Hawaii has not
adopted formal groundwater quality standards, the drinking water standard for nitrate (10 mg/L as
N) in the annual average deep percolate below the land treatment system was used as a
performance target to design the land treatment site. Phosphorus adsorption is excellent in SR land
treatment systems, and 99 percent or greater phosphorus removal is anticipated. Table 5-2
compares the current loads to the environment via the LCCs and the loads to the environment after
the proposed project is implemented via the deep percolate from the land treatment system. Figure
1
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 5
5-3 provides a graphical representation of the environmental benefits of the proposed project
compared to the status quo.
Table 5-2. Environmental Benefits of Proposed Project
Parameter
Current Annual Load to
Environment via LCCs
Annual Load to Environment
via Proposed Land Treatment
System Deep Percolate
Reduction
BODs
174,000 Ibs./year
600 Ibs./year
>99%
TSS
174,000 Ibs./year
600 Ibs./year
>99%
Nitrogen
23,000 Ibs./year
4,100 Ibs./year
83%
Phosphorus
4,000 Ibs./year
40 Ibs./year
>99%
180,000
174,000
174,000
160,000
140,000
"5 120,000
(A
_Q
^ 100,000
0)
>-
1—
o. 80,000
in
"O
C
o 60,000
D. '
I Current (Status Quo)
Proposed (After Treatment)
40,000
20,000
23,000
4,100
4,000
BOD
TSS
Figure 5-3. Environmental Benefits of Proposed Project
Brown and CatdweU •
5-7
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 5
5.5 Cost Estimates
An order of magnitude probable construction is summarized in Table 5-3. The estimate includes a
25 percent estimating contingency. The detailed cost estimate is included as Appendix A.
Tabic 5-3. Pahala WWTP Order of Magnitude Construction Cost Estini.it
Description
Estimated Construction Cost
Electrical and instrumentation
$1,976,000
Headworks
$906,000
Odor Control
$412,000
Lagoons
$2,222,000
Constructed Wetland
$611,000
Land Application
$925,000
On-site improvements
$6,325,000
Off-site improvements
$1,223,000
Total Estimated Construction Cost
$14,600,000
5.6 Future Expansion
5.6.1 Full Buildout Flows
Full buildout wastewater flow projections were developed using the Draft Ka'u Community
Development Plan (March 2015) and the CCH's current (2017) wastewater standards. Table 5-4
summarizes the projected full buildout flows for the community, and Figure 2-1 shows the WWTP full
buildout service area.
I
Tabic 5-4. Pahala WWTP Full Buildout Flow Projection
Description
Value
Peaking Factor
Average dry weather flow
360,000 gallons per day '
1.0
Peak day wet weather flow
1,260,000 gallons per day
3.5
Peak hour wet weather flow
1 1,200 gallons perminute )
4.8
5.6.2 Improvements
To accommodate the flow increase anticipated from the full buildout of the Pahala wastewater
collection system, the WWTP will require facility upgrades. The recommended upgrades include
headworks and odor control expansion within the 14.9-acre site.
Additionally, the lagoon system will require modifications. Lagoon 1 will be converted to a complete
mix aerated lagoon environment to accommodate wastewater treatment needs. In a complete mix
aerated lagoon, sufficient mixing energy is provided to maintain the lagoon solids in suspension
always. A completely mixed aerated lagoon system performs as an activated sludge process without
solids recycle. The higher mixing energy, as compared to a partial mix lagoon, creates greater
|^own AND
5-8
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Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 5
opportunity for contact between the naturally-occurring micro-organisms in the lagoon and dissolved
organic matter. As a result, complete mix lagoons provide greater levels of treatment within a
smaller volume than partial mix lagoons. However, facilities must be provided downstream of
complete mixed lagoons to allow removal of settleable solids from the water column. To provide a
place for solids settling, lagoons 2 through 4 will continue to act as partial mix aerated lagoons
downstream of the complete mix lagoon 1. Lagoon 4 will require no aeration and will continue to be
covered to deprive algae of sunlight and allow suspended solids to settle out of the system effluent.
Utilizing this lagoon system approach, the Pahala WWTP will require modifications at full buildout
flows, but is not anticipated to expand beyond the initial build 14.9 acres.
Brown AND Caldwell «
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Implementation
Table 6-1 provides the implementation schedule for the WWTP. The LCCs will be closed following
connection of the existing sewer system to the WWTP.
Table 6-1. Implementation Schcdnl
Description
Milestone
Complete design ofWWTP
September 18,2019
Com plete construction of WWTP I May 20,2021
Connect existing collection system to WWTP June 30,2021
Brown AND Caldwell «
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Section 7
Alternative Treatment Options
Evaluation
Several other treatment alternatives were considered for the Pahala WWTP, as summarized below.
7.1 Option Descriptions
7.1.1 Option 1: Aerated Lagoons/Constructed Wetland/Land Application
Option 1 consists of an aerated lagoon treatment system with a constructed wetland and
disinfection, followed by land application for effluent management, as described previously
throughout this report. Figure 7-1 is a schematic diagram for Option 1.
Wastewater
Aerated Lagoons
+
Wetland
+
Disinfection
Land Application
Figure 7-1. Option 1 Schematic Diagram
7.1.2 Option 2: R-l Treatment/Land Application
Option 2 consists of constructing a membrane bioreactor (MBR) or an activated sludge treatment
process followed by cloth media filtration, followed by UV disinfection, to produce recycled water that
meets DOH R-l recycled water criteria. R-l recycled water is effluent that has undergone oxidation,
filtration, and disinfection. R-l is considered the highest grade of recycled water and can be used for
irrigation of golf courses, parks, schools, and all types of agricultural crops. The R-l treatment
system would be followed by land application as per Option 1. Figure 7-2 is a schematic diagram for
Option 2.
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 7
R-1 Treatment
Land Application
Figure 7-2. Option 2 Schematic Diagram
7.1.3 Option 3: R-1 Treatment/Seasonal Water Recycling
Option 3 consists of a treatment system similar to Option 2 to produce R-1 recycled water. The
recycled water would be used to irrigate nearby macadamia nut orchards. Figure 7-3 provides a
schematic diagram of Option 3.
Figure 7-3. Option 3 Schematic Diagram
A water recycling analysis was prepared to assess the potential seasonal demand for recycled water
produced by the WWTP. Figure 7-4 is an irrigation demand assessment for the Pahala area based
on published climate data. The graph shows precipitation, estimated evapotranspiration, and the
irrigation demand for each month of the year. As shown in the figure, irrigation is typically needed
from April through September, reaching a peak demand in June. The graph shows that no irrigation
is typically needed between October and March, because precipitation exceeds evaporation during
those months.
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 7
JAN FEB MAR APR MAY JUN JUL
Month
AUG SEP OCT NOV DEC
^^—Precipitation Evapotranspiration Irrigation Requirement
Figure 7-4. Irrigation Demand Assessment
The potential demand for recycled water produced by the Pahala WWTP was assessed, as shown in
Figure 7-5. The WWTP could potentially provide irrigation water for approximately 62 acres, based
on the peak month irrigation demand in June. During June, all the recycled water produced by the
WWTP would be used on the 62 acres. During all other months the supply of recycled water will
typically exceed the demand, and the excess water would be land applied on the WWTP property as
per the previous alternatives.
7.0
6.0
LO
5.0
£
_o
"S
4.0
£
O
3.0
I
2.0
1.0
0.0
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
Month
Recycled Water Use Effluent Disposal
Figure 7-5. Option 3 Recycled Water Demand Assessment
The Pahala climate makes it possible to only recycle only about 25 percent of the annual flow in this
scenario, due to the long wet season and relatively low evapotranspiration rate during the dry
season. This is in stark contrast to the Kailua-Kona area on the leeward side of the island, where the
climate will allow approximately 88 percent of the recycled water produced at the Kealakehe WWTP
Brown and CatdweU •
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 7
throughout the year to be recycled. Figure 7-6 provides a comparison of the irrigation demand in
Pahala with the irrigation demand at Kealakehe.
10,000
9,000
-5- 8,000
0
fO
^ 7,000
CL
-u 6,000
c
03
1 5,000
Q
.1 4,000
m
op
't 3,000
5 2,000
1,000
0
JAN
FEB
MAR
APR
MAY
JUN JUL
Month
AUG
SEP
OCT
NOV
DEC
•¦¦¦¦Kealakehe (Parks and Golf Course) •"¦¦¦¦Pahala (Macadamia Nuts)
Figure 7-6. Comparison of Irrigation Demands at Pahala and Kealakehe
7.1.4 Option 4: R-l Treatment and Storage for 100% Water Recycling
Option 4 adds a seasonal storage reservoir, as shown schematically in Figure 7-7.
Brown AND Caldwell «
7-4
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Storage
Reservoir
Section 7
Reuse
Figure 7-7. Option 4 Schematic Diagram
Implementation of a seasonal storage reservoir would make it possible to recycle 100 percent of the
R-l water produced by the Pahala WWTP in a typical year. The seasonal storage reservoir would
make it possible to save recycled water produced during the wet season for use during the dry
season. An annual water balance was prepared to assess the seasonal storage reservoir needs for
the Pahala WWTP. Figure 7-8 provides a summary of the evaluation, and shows recycled water
supply, use, and storage throughout a typical year. As shown in the graph, peak storage of
approximately 40 million gallons (Mgal) would occur during April, and by August the storage reservoir
would be dry and ready for another wet season. Under this scenario it would be possible to irrigate
approximately 253 acres of macadamia nut trees. The lined, 20-foot-deep storage reservoir would
have a water surface area of approximately 7 acres.
Storage of recycled water is not without its challenges. Recycled water contains nutrients that allow
algae to grow. The algae can cause odors if stagnant water conditions are allowed to develop.
Recycled water that is stored in open reservoirs must often be re-treated to improve the water quality
characteristics. Recycled water reservoirs can be equipped with mixers to prevent stagnant water
conditions, and/or be equipped with floating covers to block the sunlight that fosters algal growth.
Brown AND Caldwell j
7-5
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 7
45
40
35
£ 30
_o
ra 25
| 20
I 15
10
5
0
Recycled Water Supply Recycled Water Use Storage Volume
Figure 7-8. Seasonal Storage Reservoir Analysis
Implementation of a seasonal storage reservoir and recycling program would not eliminate the need
for a land application system at the WWTP, as described previously. HAR 11-62 requires a disposal
system for all recycled water system, to provide a means for disposal of water that does not meet R-
1 standards or disposal of excess water should the seasonal storage reservoir capacity be exceeded
during an exceptionally wet year.
7.1.5 Option 5: Maximum Practical Treatment
Option 5 consist of implementing advanced wastewater treatment processes that represent
maximum practical treatment. The option is illustrated schematically in Figure 7-9. The process
treatment train consists of a 5-stage Bardenpho activated sludge treatment process, followed by
chemical addition and denitrifying filters to reliably reduce total nitrogen to less than 4 mg/L and
total phosphorus to less than 0.1 mg/L The treatment processes would be followed by a
disinfection process to create R-l recycled water. The recycled water produced would be used to
irrigate macadamia nut trees as per Option 3. A seasonal storage reservoir could also be
implemented at additional cost. A land application system would be required as per the previous
Options.
Brown and CatdweU •
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 7
Wastewater
Maximum
Practical
Treatment
Reuse
Land Application
Figure 7-9. Option 5 Schematic Diagram
7.2 Cost Comparisons
Planning-level cost estimates were prepared for the five options, as described below.
7.2.1 Capital Costs
Table 7-1 summarizes the capital costs associated with the options described above. Additional
detail can be found in Appendix A. The capital costs shown in the table do not include costs
associated with collection system improvements or closure of the existing LCCs.
Table 7-1. Summary of Capital Cost Estimat
Option
Name
Estimated Capital Cost
1
Aerated lagoons/constructed wetland/land application
$14.6 million
2
R-l treatment/land application
$18.4 million
3
R-l treatment/seasonal water recycling
$20.2 million
4
R-1 treatment and storage for 100% water recycling
$30.4 million
5
Maximum practical treatment
$26.0 million
Comparison of options 1 and 2 shows that providing R-l treatment instead of the aerated lagoon
and wetland natural treatment system will increase the capital cost by approximately $3.8 million.
Option 3 shows that addition of water recycling to reuse approximately 25 percent of the annual flow
would add an additional $1.8 million in capital costs. Option 4 shows that constructing a seasonal
storage reservoir to recycle 100 percent of the flow would add an additional $10 million in capital
costs. Comparison of options 3 and 5 shows that providing maximum practical treatment instead of
normal R-l treatment would add $5.8 million in capital costs.
7.2.2 Operation and Maintenance Costs
Operation and maintenance (O&M) costs include labor, electricity, chemicals, spare parts, sludge
management, and other costs required to operate and maintain the facility. Table 7-2 provides a
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 7
summary of the O&M cost estimates developed for the options. Additional details can be found in
Appendix A.
Tablc7-2. Siniininry of O&M Cost Estinintcs
Option
Name
Estimated Annual O&M Cost
1
Aerated lagoons/constructed wetland/land application
$236,000
2
R-l treatment/land application
$1,052,000
3
R-l treatment/seasonal water recycling
$1,055,000
4
R-1 treatment and storage for 100% water recycling
$1,063,000
5
Maximum practical treatment
$1,421,000
As shown in the table, option 1 incurs significantly lower O&M costs than the other options. The
significant cost differential is due to the simple aerated lagoon natural treatment system that
requires less labor, electricity, chemical, and maintenance that the other options.
7.2.3 Recycled Water Sale Proceeds
Options 3, 4, and 5 will produce a marketable product in the form of R-l recycled water that could be
sold to users for irrigation purposes. The value of recycled water is a function of the value of the
water that it replaces. In general, recycled water is sold to users at a fraction of the price of the
water that is being replaced to provide a financial incentive to use the product. The typical recycled
water price is 25 percent to 90 percent of the water it replaces.
The Pahala WWTP will be located at elevation 750 feet MSL. The cost to pump groundwater from
the basal lens to the ground surface at the WWTP is approximately $1,078 per million gallons. Table
7-3 provides a summary of a recycled water sales assessment of each option, assuming the recycled
water is sold for 90 percent of the cost of the irrigation water it would replace. Additional detail is
provided in Appendix A.
Tabic 7-3. Summary of Annual Recycled Water Sale Proceeds
Option
Name
Annual Volume Recycled
(Mgal)
Maximum Annual
Sales Proceeds
1
Aerated lagoons/constructed wetland/land application
0
$0
2
R-l treatment/land application
0
$0
3
R-l treatment/seasonal water recycling
17
$17,000
4
R-1 treatment and storage for 100% water recycling
70
$68,000
5
Maximum practical treatment
17
$17,000
7.2.4 Life-Cycle Costs
Life-cycle costs represent the total costs to the community to construct and operate the wastewater
treatment system over a 30-year period. The life-cycle cost evaluation includes capital and O&M
costs, and recycled water sales proceeds as described above. In addition, equipment replacement
allowances are included after 20-years of operation. The life-cycle cost evaluation includes an
|^own AND
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Pahaia Wastewater Treatment Plant Preliminary Engineering Report
Section 7
inflationary factor to account for long-term changes in the vaiue of money. The life-cycle costs are
expressed as the Net Present Value (NPV). The NPV represents the amount of money that the
County would need to set aside now in an interest-bearing account to cover all of the costs over the
defined life-cycle. Table 7-4 provide a summary of the life-cycle cost evaluation. Additional detail
can be found in Appendix A.
Table 7-4. Summary of Life-Cycle Cost Estimates
Option
Name
Estimated Life-Cycle Cost
1
Aerated iagoons/constructed wetiand/iand application
$21.2 million
2
R-l treatment/land application
$43.0 million
3
R-l treatment/seasonal water recycling
$44.5 million
4
R-1 treatment and storage for 100% water recycling
$54.0 million
5
Maximum practical treatment
$59.0 million
As shown in the table, option 1 incurs the lowest life-cycle costs, and the other options would all
incur over double to nearly triple the cost over the 30-year life-cycle. The life-cycle cost estimates are
shown graphically in Figure 7-10. The operating costs shown in the figure include benefits (i.e., cost
reductions) from recycled water sales where applicable.
a 1111
m 0
1 2 3 4 5
Option
¦ Capital Costs ¦ Operating Costs
Figure 7-10. Life-Cycle Costs of Options
As shown in the graph, the operating cost differential between option 1 and the other options is the
ieading contributor to the lower life-cycle cost of option 1. The major operating cost differences are
discussed below.
7.3 Non-Economic Discussion
The options are discussed on a non-economic basis below.
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 7
7.3.1 Labor Requirements
The Pahala WWTP will be operated by the COH DEM, Wastewater Division that is based in Hilo. The
Hilo-based WWTP operators will regularly visit to facility to check the system status, make
operational adjustments, and draw samples for required laboratory testing. In addition,
maintenance personnel will visit the WWTP as needed to conduct equipment and electrical system
repairs.
A major difference between option 1 and the other options is the frequency of routine operator visits
required, and the number of personnel routinely required. Option 1 will require a single operator to
normally visit the site once per week. The other options will require daily operator visits to conduct
sampling that is required for R-l compliance. In addition, options 2 through 5 consist of mechanical
treatment technology that required more operator attention than option 1. Table 7-5 compares the
operational labor differences for the options, as expressed as full-time equivalents (FTEs).
Table 7-5. Comparison of Operational Labor Requirements
Option
Name
Estimated Operational Labor
Requirement (FTEs)
1
Aerated lagoons/constructed wetland/land application
0.3
2
R-l treatment/land application
3.7
3
R-l treatment/seasonal water recycling
3.7
4
R-1 treatment and storage for 100% water recycling
3.7
5
Maximum practical treatment
5.6
!
!
7.3.2 Operational Complexity
HAR 11-61 establishes operator certification requirements for WWTPs. The DOH requires that
certified operators operate municipal WWTPs. The larger and/or more complex the wastewater
treatment process, the higher grade of operator required at the facility. Options 1 through 5 were
evaluated for operator certification requirements based on the criteria established in HAR 11-61.
Table 7-6 summarizes the results of the evaluation. As shown in the table, option 1 would require a
Grade I operator, while the other options would require a Grade IV operator (the highest grade). The
higher requirements for options 2 through 5 are due to the complexity of the treatment processes
compared to option 1. In general, the County has difficulty attracting and retaining Grade IV
operators.
Table 7-6. Comparison of Operator Certification Requirements per HAR 11-61
Option
Name
Operator Certification Level Requirement
1
Aerated lagoons/constructed wetland/land application
1
2
R-l treatment/land application
IV
3
R-l treatment/seasonal water recycling
IV
4
R-1 treatment and storage for 100% water recycling
IV
5
Maximum practical treatment
IV
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Ji
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 7
7.3.3 Energy Consumption
Figure 7-11 provides a comparison of the electrical energy requirements of the five options. As
shown in the graph, option 1 will require significantly less electrical energy to operate, due to the use
of natural treatment systems (aerated lagoons) instead of mechanical treatment processes that
require more aeration and process pumping.
ro
(D
-C
c
(D
E
(D
s_
'5
0-
(D
CC
>
"u
1—
4->
o
LU
Figure 7-11. Comparison of Electrical Energy Requirements
7.3.4 Sludge Management
Sludge management for Option 1 is significantly different than the other options. The partial-mix
aerated lagoon treatment system allows wastewater solids to accumulate at the bottom of the
lagoon, forming a sludge blanket that slowly anaerobically digests. Sludge removal is infrequent,
typically on the order once every 15 to 20 years. The resulting solids are well-digested and
inoffensive due to the long retention time in the lagoons.
Options 2 through 5 would require an aerobic digester to stabilize and store waste solids from the
activated sludge treatment process. The solids would need to be dewatered and trucked to a landfill
on a weekly basis.
7.4 Living Machine®
Living Machine® technology was suggested during community outreach meetings. Living Machine®
is a proprietary technology by Worrell Water Technologies that incorporates aerated tanks planted
with vegetation to provide an attractive wastewater treatment process. In colder climates the
aerated tanks are housed in a greenhouse for protection. In addition, subsurface flow wetlands with
continuous and/or batch flow can be included in the process to provide desired treatment.
The Living Machine® technology has been implemented in "green" buildings like the San Francisco
Public Utilities Commission building, the Port of Portland Headquarters, and others. Review of the
company's website did not reveal any municipal projects completed on the scale of what would be
needed for Pahala. Therefore, the technology is considered to be not feasible.
1,200,000
1,000,000
800,000
600,000
400,000
200,000
0
I
Brown and CatdweU •
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 7
It should be noted that the proposed non-proprietary treatment system (aerated lagoons and
subsurface flow wetland) uses essentially the same natural treatment processes as the Living
Machine®, but on a municipal scale.
7.5 Septic Tank Alternatives
A previous assessment recommended installation of a community septic tank and repurposing one
of the existing LCCs to serve as a seepage pit (SSFM, July 2007), in accordance with Alternative 1
proposed to the community by the County in 2004 (County of Hawaii, November 5, 2004). This and
other options that have been raised during the community outreach process that incorporate septic
tank technology are discussed below.
7.5.1 Community Septic Tank
The effectiveness of a septic tank is directly related to the amount of hydraulic detention time
provided by the tank volume. The previous study (SSFM, July 2007) suggested a 24-hour detention
time would be adequate. Applying the current flow projections for the project indicate a 190,000-
gallon tank would be appropriate if this criterion is used. However, for large community septic tanks
it has been found that longer detention times are needed to optimize treatment performance, avoid
the need for frequent septage pumping, and to account for peak flow rates that are developed by
community wastewater collection systems. Applying appropriate design criteria (Crites and
Tchobanoglous, 1998), to the project results in the need for an 800,000-gallon tank, which would
require pumping on a 3-year interval. The area required for an appropriately-sized community septic
tank would be approximately rA acre.
The use of a community septic tank would require the DOH to issue a variance to HAR 11-62, which
requires WWTPs with design capacities greater than 100,000 gallons per day to produce effluent
containing less than 30 mg/L of both BODs and TSS - septic tanks are not able to produce effluent
of this quality. A secondary treatment process is needed to comply with the effluent quality
requirements contained in the DOH regulations. The County would need to reapply for the variance
every 5-years, and if not renewed then secondary treatment would need to be provided.
Additionally, odors from a community septic tank present a significant concern. A septic tank is an
anaerobic treatment process that produces hydrogen sulfide, reduced sulfur compounds, and other
odorous gases. Odors emanating from septic tanks at individual residences are typically dispersed
to the atmosphere throughout the community via the household plumbing roof vents. A community
septic tank would concentrate the community's emissions to a single point source that would require
foul air collection and treatment to avoid nuisance odor conditions. A dual-stage scrubber capable of
treating approximately 3,600 cubic feet per minute of foul air would be required to avoid nuisance
odor conditions. The dual-stage scrubber would consist of a biotrickling filter, followed by a granular
activated scrubber.
7.5.2 Converting LCC to Seepage Pit
A previous study (SSFM, July 2007) suggested that the existing LCC located on the County-owned
parcel TMK 9-6-002:024 could be converted to a seepage pit that would be regulated by DOH as an
injection well. HAR 11-23-07 allows injection wells located mauka of the UIC line that were in
existence prior to July 6,1984 to continue to operate. However, the flow to the wells cannot
increase, nor can a new well be constructed. Therefore, the earlier plan to convert the existing LCC
to a seepage pit is not feasible for the following reasons:
• Closing LCC No. 2 that is located on private property would not be allowed, as it would
increase the flow to LCC No. 1 (converted to a seepage pit that is regulated as an injection
well) that is located on County property.
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 7
• The capacity, structure, and condition of the existing LCC No. 1 is not known. The LCC could
either be a lava tube or a large conventional cesspool. A geotechnical investigation
conducted on the site to depths of 30 to 35 feet did not reveal the presence of lava tubes
(Masa Fujioka & Associates, January 9, 2007), therefore it is likely a large conventional
cesspool. The County attempted to determine the structure and condition of the LCC via
closed circuit TV inspection, but could not ascertain either due to technological limitations. It
is not known if the LCC could accommodate the flow from the existing service area if LCC No.
2 is closed.
• HAR 11-62-25 requires new and proposed effluent disposal systems to have a backup
disposal system capable of handling the peak flow. A second seepage pit cannot be
constructed to comply with the regulatory requirement because the site is located mauka of
the UIC line. If the existing seepage pit were to fail then a replacement cannot be
constructed.
• The Kau Community Development Plan requires the County to provide for eventual
construction of sewers throughout the community. Providing sewers for the entire
community will increase wastewater flows considerably, as presented in Section 5.
Increasing flow to the existing LCC (converted to a seepage pit) would not be allowed.
Therefore, the use of the existing LCC as a disposal system could prevent the County from
providing the community's desired future wastewater needs.
For these reasons, converting the existing LCC to a seepage pit is considered to be not feasible.
7.5.3 Leachfield Disposal
Leachfields are effluent disposal systems consisting of buried gravel-filled absorption trenches.
Significant treatment occurs as septic tank effluent percolates through the soil surrounding the
leachfield trenches. Leachfields are an integral part of residential septic systems, and DOH has
established trench design criteria applicable to both residential and municipal-scale leachfields. In
particular, HAR 11-62-34 requires trenches to be sized based on bottom area only. Application of
the DOH criteria to the project yields a need for at least 30 acres of land to satisfy DOH hydraulic
loading rate and redundancy requirements. Achieving even distribution of effluent over a leachfield
of this size would be challenging at best. Therefore, leachfield disposal for the project is considered
to be not feasible.
7.5.4 Conversion to Individual Wastewater Systems
The concept of a community wastewater system could be abandoned and all houses be required to
construct individual wastewater systems comprised of a septic tank and leachfield. However, many
of the lots in the community are small (less than 10,000 square feet) and significantly improved,
making the feasibility of constructing individual wastewater systems on every lot uncertain. HAR 11-
62-34 allows construction of seepage pits where there is insufficient land area to install absorption
trenches (i.e., a leachfield), but prohibits construction in soils having percolation rates slower than
10 minutes per inch or where rapid percolation through such soils may result in contamination of
water-bearing formations. The soils in the community are classified as Puueo-Naalehu complex, 3 to
10 percent slopes in the National Resource Conservation Service soil survey. This soil type consists
of approximately 18 inches of extremely cobbly medial silt loam over cobbles and bedrock. This soil
profile is too thin for conventional soil absorption trenches, so residents with sufficient space would
be required to import fill soil to create elevated mound systems in accordance with HAR 11-62-34 to
achieve adequate soil depth. Residents without sufficient space could potentially install seepage
pits if suitable subsurface geology could be located. However, previous subsurface investigations in
the community (Masa Fujioka & Associates, January 9, 2007, and Geolabs-Hawaii, September 23,
|^own AND CaMwellJ
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Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 7
1998) revealed extremely permeable clinker layers and numerous lava tubes, both of which would
not meet HAR 11-62-34 requirements for seepage pits. For these reasons, conversion to individual
wastewater systems is considered to be not feasible.
7.5.5 Gray Water Systems/Composting Toilets
The DOH has published guidelines for the reuse of gray water (DOH, June 22, 2009). The DOH
defines black water as wastewater discharged from toilets and urinals and kitchen sinks. Gray
water is defined as wastewater discharged from showers and bathtubs, lavatories, wastewater that
has not contacted toilet waste, sinks not used for food preparation.
Composting toilets are a type of dry toilet that treats human excreta by a biological process called
composting. The process leads to the decomposition of organic matter and turns the human
excreta into a compost-like material but does not destroy all pathogens. Composting toilets do not
require a connection to a septic tank or sewer system (Wikipedia).
The combination of a gray water system and composting toilet cannot replace an individual
wastewater system or a sewer connection, because black water from the kitchen sink in a residence
requires either an individual wastewater system or sewer connection.
7.6 Package Plant
Package plants are commercially-available prefabricated wastewater treatment plants. Package
plants are commonly used for small WWTPs with capacity requirements less than 250,000 gallons
per day. Package plants are generally based on the extended aeration activated sludge process.
Use of a package plant in lieu of aerated lagoons at Pahala could potentially save some capital cost
but would require daily visits by WWTP operators to monitor and adjust the process, and to waste
sludge. In addition, weekly or bi-weekly sludge dewatering and disposal would be required. The
results of an economic analysis of a package plant alternative for Pahala are:
• Capital cost: $12.6 million
• Annual O&M cost: $1.1 million
• Life-cycle cost: $37 million.
Comparison of these values to the results shown in Tables 7-1, 7-2, and 7-4 show that a package
plant at Pahala would incur significantly higher life-cycle costs compared to the recommended
aerated lagoon approach.
Brown AND Caldwell «
» m il
7-14
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Alternative Site Evaluation
Nine sites were evaluated as potential locations for the Pahala WWTP. Each site was assessed for
twenty-one criteria, in four broad categories: environmental, social and cultural; location and site;
land use and availability; and collection system and service area.
8.1 Methodology
The site evaluation was performed according to the following process:
1. Potential sites for the Pahala WWTP were initially identified by the Department of
Environmental Management. Additional sites were identified based on feedback from the
Pahala community obtained during Community Outreach meetings that took place in
December 2017.
2. Four general categories and twenty-one criteria were established and defined for the
analysis.
3. Six "fatal flaw" conditions were identified. Sites with a fatal flaw were eliminated from
further consideration.
4. Relative weighting factors were established for each category and criteria.
5. Sites were mapped using GIS. Data such as soil type, location of subsurface and surface
water, topography, zoning and prevailing wind direction were determined.
6. Each site was evaluated and scored for the twenty-one criteria.
7. A weighted ranking was determined for each site, based on the weighting factors established
in Step 4.
8. A preferred site was identified, based on the weighted high score.
8.2 Site Locations
Ownership, location, and proximity to the existing LCCs for all siting alternatives considered is
illustrated in Figure 8-1.
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Pahaia Wastewater Treatment Plant Preliminary Engineering Report
Section 8
Figure 8-1. Pahaia Site Alternatives
Brown Caldwell •
8-2
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 8
8.3 Criteria
The criteria used for the analysis are presented for each of four categories in Tables 8-1, 8-2, 8-3
and 8-4. A score was assigned to each criterion based on definitions included in the tables. A score
of five represents a preferred or positive condition, and a score of one a less preferred or negative
condition. A score of zero indicates a fatal flaw; six fatal flaw conditions were identified during the
analysis are identified in the corresponding table.
Table 8-1 outlines the environmental, social, and cultural criteria considered in the analysis.
Criteria
5
4
Scoring and Definitions
3 2
1
0 = Fatal Flaw
Presence of or proximity to
archaeological/cultural
sites
No known or
suspected sites
Confirmed or
suspected sites
and mitiga table
No information
available
Suspected sites
and mitigation
ability unknown
Confirmed sites
and mitigation
ability unknown
Confirmed sites
and
unmitiga table
Proximity of treatment
units to existing occupied
buildings
More than 1000
ft. from any
occupied
building
Between 50 and
1000 ft. from
non-school
building
Between 50 and
1000 ft of
school
Less than 50 ft
from any
occupied
building
Prevailing wind direction
Site is downwind
ofmostofttie
community
Site is central
Site is upwind of
most of the
community
Biology
Endangered or
threatened
species not
present
Presence of
endangered or
threatened
species unknown
Endangered or
threatened
species known to
be present
Endangered or
threatened
species known to
be presentand
unmitiga table
Visual impact
Natural visual
mitigation (hill,
berm,
vegetation,
remoteness)
exists
Visible location,
mitigatablewith
trees or other
engineered
buffers
Visible location,
unmitiga table
Contamination from prior
land use
No suspected
industry-related
contamination
issues
Presence of
contamination
unknown
Suspected or
confirmed
contamination
issues
Previously disturbed or
developed
Yes
Partial
No previous
development or
disturbance
The circumstance where a cultural or historical site is known to exist within the treatment facility
footprint and mitigation to relocate, protect, or preserve that site is not possible, was identified as a
fatal flaw condition.
From an environmental perspective, the presence of endangered or threatened species was
considered negative. A site previously disturbed or developed was viewed as positive, unless
contamination from a previous land use was suspected.
Considerations specific to social impact include proximity to occupied buildings (including
residences, school, commercial establishments and others), prevailing wind direction, and visual
impact.
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 8
Table 8-2 outlines the location and site characteristics considered in the analysis.
Tabic 8-2. Location and Site Characteristics
Criteria
5
4
Scoring and Definitions
3 2
1
0 - Fatal Flaw
Parcel size
More than 14.9
acres
Less than 14.9
acres
Soils type
Good soil and in
sufficient
amounts in area
of parcel useable
for disposal
Good soil but
over limited area
and disposal
modification
required
Marginal soil in
area of parcel
useable for
disposal
No soil in area of
parcel useable
for disposal
Topography
Gentle slopes
(less than 8%)
Moderate slopes
(8%-18%) or
localized
high/low points
Steep slopes
(18%-20%)
Extreme slopes
(greater than
20%)
Proximity to water well
Outside of both
1000 ft. radius
and upgradient
influence zone of
any well
Outside of 1000
ft. but suspected
within
upgradient
influence zone of
non-potable well
Within 1000 ft
orwithin
upgradient
influence zone of
non-potable well
Within 1000 ft
orwithin
upgradient
influence zone of
potable well
Presence of lava tubes
None
Possible or
unknown
Known
Proximity to surface water,
intermittent stream or
coastline
Treatment and
disposal more
than 500 ft.
away
Treatment and
disposal
between 50 to
500 ft
Treatment and
disposal less
than 50 ft away
Flood control / drainage
No risk of
flooding
Flood risk
unknown
Prone to flooding
orwithin flood
zone
Vehicle access
Vehicle access
currently exists
Existing
easement, but
new road or
significant road
upgrades
required in orvia
county/private
right if way
Existing
easement, but
new road or
significant road
upgrades
required in orvia
state right-of-
way
No current
vehicle access or
easement,
access legally
restricted, or
significant
obstruction to
access
Power and potable water
availability
Utilities currently
available at
property line and
within 400 ft of
site, no new
easement
required, no
known
significant
obstructions (i.e.
- culverts,
streams, cultural
sites)
Utilities
available within
400 yds. of
property or
unknown
Potable water
and/or power
not currently
available within
400 yds. of
property and/or
significant
obstruction to
utility
construction
Brown AND Caldwell j
8-4
-------
Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 8
Three fatal flaw conditions were identified for the location and site characteristics category in Table
8-2:
• Sites less than 14.9 acres in size, which is the least amount of land needed for treatment,
disposal, and future growth.
• Average slopes greater than 20 percent, which significantly increase the cost of construction
and limit design options.
• Location within a 1000-foot radius surrounding a potable water well, which is prohibited by
HAR 11-62 for the protection of drinking water in the State of Hawaii.
Table 8-3 outlines the collection system and service area characteristics considered in the analysis.
Scoring and Definitions
Criteria
5:43:2:1
Distance from LCC collection
area
Parcel is adjacent
to existing LCC or
less than 0.25
miles away
Parcel is 0.25-0.5
mile away from
existing LCC
Parcel is 0.5-1.0
miles away from
existing LCC
Parcel is 1.0 - 1.5
miles away from
existing LCC
Parcel is more than
1.5 miles away from
existing LCC
Gravity flow possible or
pumping required
Gravity flow
possible
Pumping required
for wastewater
transmission from
collection area to
site
Number of properties newly
accessible
Commercial areas
become accessible
Additional
individual
residential
properties become
accessible outside
of LCC service area
No additional
properties become
accessible
A site location requiring large transmission distances of more than two miles are less preferable due
to both initial capital cost and future operations and maintenance requirements. Similarly, sites
where wastewater can flow via gravity from the collection area are preferable to those requiring a
pump station.
Newly accessible refers to properties within the service area that are not currently connected to the
LCC, but will become accessible to the County-owned sewer system when the collection lines are
relocated into the roadways fronting the property. Hawaii County Code requires connection of these
properties once the new collection system is constructed, and their individual wastewater systems
(cesspools or septic tanks) properly removed from service. All individual cesspools in the State of
Hawaii must be converted or closed by the year 2050.
Brown AND Caldwell j
8-5
-------
Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 8
Table 8-4 outlines the land use and availability characteristics considered in the analysis.
I
Criteria
Current zoning and land use
Table 8-4. Land Use nnd Availability Critcri
WWTP currently
permitted in zoning
without Special
Permit
Scoring and Definitions
3
WWTP possible i
onsite Special
Permit required
WWTP not
recommended on
site
Land availability
Owner willing and
able to sell or land
currently
government (state,
county) owned
Subdivision
required or friendly
condemnation
required
Difficult or lengthy
approval process
expected or owner
willingness to sell
unknown
Owner unwilling to
sell or unfriendly
condemnation of
land required
(private corporate
owner)
Owner unwilling to
sell or unfriendly
condemnation
required (private
family owner)
Although public facilities are permitted in any zoning in the County of Hawaii, construction of a
wastewater treatment facility requires a Special Permit within some zones. No fatal flaws were
identified for the land use and availability category.
Brown AND Caldwell «
-------
Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 8
8.4 Criteria Weighting Factors
To consider the relative importance to the categories and criteria, each was assigned a weighting
factor for the analysis. Weighting allows for appropriate consideration of all factors - both the
technical and non-technical - associated with siting. Relative weighting is summarized in Table 8-5.
1 Table 8-5. Relative Weighting Factors
Category
Category Weight Criteria
Criteria Weight
Environmental, social and cultural
35% Presence of and/or proximity to archaeological/cultural sites
25%
Proximity of treatment units to existing occupied buildings
25%
Prevailing wind direction
25%
Biology
10%
Visual impact
5%
Contamination from prior land use
5%
Previously disturbed or developed
5%
100%
Location and site characteristics
35% Parcel size
25%
Soils type
25%
Topography
15%
Proximity to water well
10%
Presence of lava tubes
8%
Proximity to surface water, intermittent stream or coast line
6%
Flood control / drainage
5%
Existingvehicle access
3%
Power and potable water availability
3%
100%
Collection system and service area
20% Distance from LCC collection area
50%
Gravity flow possible or pumping required
30%
Number of properties newly accessible
20%
100%
Land use and availability
10% Current ownership
55%
Current zoning and land use
45%
100%
Brown AND Caldwell j
8-7
-------
Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 8
8.5 Raw Scores
For the nine sites identified in Figure 8-1, raw scores were assigned for each of the twenty-one
criteria according to the definitions in Section 8.3. The results are presented in Table 8-6.
Table 8-6. Alternatives Analysis - Raw Scores
Category
Criteria
Site Raw Score
l
2
3
4
5
6
7
8
9
Environmental, social
and cultural
Presence of and/or proximity to archaeological/cultural sites
5
1
2
3
3
3
4
3
3
Proximity of treatment units to existing occupied buildings
3
3
5
5
5
5
5
5
5
Prevailing wind direction
5
5
5
5
5
5
5
5
5
Biology
3
3
3
3
3
3
3
3
3
Visual impact
3
3
3
5
5
5
3
3
3
Contamination from prior land use
3
1
3
1
3
3
3
3
3
Previously disturbed or developed
5
5
5
3
3
3
5
5
5
Location and site
characteristics
Parcel size3
0
5
0
5
5
5
5
5
5
Soils type
5
1
1
3
5
1
5
5
5
Topography
3
5
3
5
3
5
3
3
5
Proximity to water wellb
0
5
5
3
5
5
5
5
5
Presence of lava tubes
1
1
3
3
3
3
3
3
3
Proximity to surface water, intermittent stream or coast line
5
5
5
5
3
5
5
1
5
Flood control / drainage
3
3
3
3
3
1
3
3
3
Existingvehicle access
5
5
2
2
2
5
5
5
2
Power and potable water availability
3
3
3
1
1
1
3
3
1
Collection system and
service area
Distance from LCC collection area
5
5
4
3
3
2
5
4
3
Gravity flow possible or pumping required
5
5
5
5
1
1
5
5
5
Number of properties newly accessible
3
3
3
3
3
3
3
3
3
Land use and availability
Current zoning and land use
3
3
3
3
3
3
3
3
3
Current ownership
5
5
3
3
5
5
4
4
4
Raw score totals (maximum possible=105) FF 75 FF 72 72 72 85 79 79
a Fatal flaw condition for Sites 1 and 3.
" Fatal flaw condition for Site 1.
As indicated in Table 8-6, fatal flaw conditions were identified for Site 1 (due to both parcel size and
proximity to a drinking water well) and Site 3 (due to parcel size). These two sites were removed
from further analysis.
Brown and CatdweU •
8-8
-------
Pahala Wastewater Treatment Plant Preliminary Engineering Report
Section 8
8.6 Weighted Analysis
The weighted analysis is presented in Table 8-7.
Table 8-7. Alternatives Analysis - Weighted Sco
Category
Criteria
Site Weighted Score
1 2
3
4
5
6
7
8
9
Presence of and/or proximity to archaeological/culture •" ¦
0.25
0.75
0.75
0.75
1.00
0.75
0.75
Proximity of treatment units to existing occupied buile" ¦'
0.75
1.25
1.25
1.25
1.25
1.25
1.25
Environmental,
Prevailing wind direction
1.25
1.25
1.25
1.25
1.25
1.25
1.25
social and
Biology
0.30
0.30
0.30
0.30
0.30
0.30
0.30
cultural
Visual impact
0.15
0.25
0.25
0.25
0.15
0.15
0.15
Contamination from prior land use
0.05
).05
0.15
0.15
0.15
0.15
0.15
Previously disturbed or developed
0.25
).15
0.15
0.15
0.25
0.25
0.25
Parcel size3
1.25
1.25
1.25
1.25
1.25
1.25
1.25
Soils type
0.25
0.75
1.25
0.25
1.25
1.25
1.25
Topography
0.75
0.75
0.45
0.75
0.45
0.45
0.75
Proximity to water wellb
0.50
).30
0.50
0.50
0.50
0.50
0.50
Location and site
characteristics
Presence of lava tubes
0.08
).24
0.24
0.24
0.24
0.24
0.24
Proximity to surface water, intermittent stream or coas
0.30
0.30
0.18
0.30
0.30
0.18
0.30
Flood control / drainage
0.15
).15
0.15
0.05
0.15
0.15
0.15
Existingvehicle access
0.15
0.06
0.06
0.15
0.15
0.15
0.06
Power and potable water availability
0.09
).03
0.03
0.03
0.09
0.09
0.03
Collection
Distance from LCC collection area
2.50
1.50
1.50
1.00
2.50
2.00
1.50
system and
Gravity flow possible or pumping required
1.50
1.50
0.30
0.30
1.50
1.50
1.50
service area
Number of properties newly accessible
0.60
0.60
0.60
0.60
0.60
0.60
0.60
Land use and
Current zoning and land use
1.35
1.35
1.35
1.35
1.35
1.35
1.35
availability
Current ownership
2.75
1.65
2.75
2.75
2.20
2.20
2.20
Overall weighted totals (maximum possil
FF 3.61
FF
3.76
3.76
3.46
4.33
4.06
4.10
a Fatal flaw condition for Sites 1 and 3.
b Fatal flaw condition for Site 1.
Brown AND Caldwell «
-------
Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 8
8.7 Results
The results of the analysis are presented in Table 8-8. Two sites were identified as having fatal flaws
and the remaining seven were ranked in accordance with the overall weighted score.
Tabic 8-8. Alternative Site Rankin
Rank
1
2
3
Site
7
9
8
FF
FF
The top three sites for the Pahala WWTP are:
1. Site 7 (TMK 9-6-002:18)
2. Site 9 (TMK 9-6-002:49)
3. Site 8 (TMK 9-6-002:21)
Site 7 is preferred to the second and third ranked sites for the following reasons:
• A preliminary Archaeological Inventory Survey has been performed for Site 7, indicating no
unmitigable cultural sites on the property.
• Site 8 is bisected by an intermittent stream bed, and a steep gulch borders the property to
the west.
• Site 7 is closer to the existing collection area than both Site 8 and Site 9.
• Power and potable water are more readily available to Site 7. Site 9 will require the utilities
to cross the highway.
8.8 Conclusion
Based on the analysis, Site 7 (TMK 9-6-002:18) was selected as the preferred location for the
Pahala WWTP.
Brown AND Caldwell «
» m il
8-10
-------
References
CH2MHILL. Kau High School and Pahala Elementary School Connection to County Sewer. July 2017.
County of Hawaii. Letter to Community Homeowners, signed by Mayor Harry Kim. November 5, 2004.
Crites, Ron, and George Tchobanoglous. Small and Decentralized Wastewater Management Systems. WCB McGraw-
Hill, 1998.
Crites, Ronald W., E. Joe Middlebrooks, Robert K. Bastian, and Sherwood C. Reed. "Natural Wastewater Treatment
Systems, Second Edition". CRC Press, 2014.
Crites, Ronald W., E. Joe Middlebrooks, Sherwood C. Reed. Natural Wastewater Treatment Systems. CRC Taylor &
Francis, 2006.
Crites, Ronald W., Sherwood C. Reed, and Robert K. Bastian. "Land Treatment Systems for Municipal and Industrial
Wastes". McGraw-Hill, 2000.
Department of Planning, County of Hawaii. Kau Community Development Plan. October 2017.
Department of Wastewater Management, City and County of Honolulu, State of Hawaii. Design Standards of the
Department of Wastewater Management, Volume 1 and 2. July 2017.
Great Lakes - Upper Mississippi River Board of State and Provincial Public Health and Environmental Managers.
Recommended Standards for Wastewater Facilities. 1997.
Hawaii Administrative Rules (HAR), Title 11, Department of Health Administrative Rules.
Masa Fujioka & Associates. Letter Report, Probing for Large Cavities (Lava Tubes), Naalehu and Pahala Large
Capacity Cesspool Sewerage System. January 9, 2007.
M&E Pacific, Inc. Kau Sewer System Evaluation, Kau, Island of Hawaii, Hawaii. December 2004.
Reed, Sherwood C., Ronald W. Crites, E. Joe Middlebrooks. Natural Systems for Waste Management and Treatment.
McGraw-Hill, Inc. 1995.
Rich, Linvil G. High Performance Aerated Lagoon Systems. American Academy of Environmental Engineers, 1999.
SSFM International, Inc. Final Preliminary Engineering Report for Naalehu and Pahala Large Capacity Cesspool
Conversion Projects, July 2007.
USEPA. "Process Design Manual, Land Treatment of Municipal Wastewater Effluents". EPA/625/R-06/016.
September 2006.
Water Environment Federation. Wastewater Disinfection, Manual of Practice FD-10. Water Environment Federation,
1996.
Water Pollution Control Federation. Aeration, Manual of Practice FD-13. 1988.
White, George Clifford, Handbook of Chiorination and Alternative Disinfectants, John Wiley & Sons Inc., New York,
1999.
-------
Pahala Wastewater Treatment Plant Preliminary Engineering Report
Appendix A: Cost Estimates
Brown AND Caldwell j
A-l
-------
County of Hawaii Department of Environmental Management
Pahala WWTP
Preliminary Design - Order of Magnitude Construction Cost
Electrical and instrumentation
$
1,976,000
Headworks
$
906,000
Odor Control
$
412,000
Lagoons
$
2,222,000
Wetland
$
611,000
Land Application
$
925,000
On-site improvements
$
6,325,000
Off-site improvements
$
1,223,000
Total Estimated Construction Cost
$
14,600,000
Description
Quantity
Units
Unit Cost
Extension
Clear and grub
18.0
AC
$5,995
$107,910
BMP's
18.0
AC
$13,080
$235,440
Archaeological Monitoring
18
AC
$2,507
$45,126
Earthwork
52,000
CY
$25
$1,300,000
Sewerline extension
700
LF
$218
$152,600
Operations building
1,500
SF
$500
$750,000
Generator and tank
1
LS
$250,000
$250,000
Fencing
3,200
LF
$164
$523,200
Paving
38,000
SY
$55
$2,071,000
Off-site waterline
2,500
LF
$327
$817,500
On-site waterline
900
LF
$164
$147,150
On-site fireline
750
LF
$218
$163,500
Off-site overhead electrical
1
LS
$50,000
$50,000
Trees (landscaping & Irrigation)
10
EA
$2,500
$25,000
Headworks
1
EA
$501,339
$501,339
Odor control unit
1
EA
$329,797
$329,797
Lagoons
1
LS
$1,816,902
$1,816,902
Constructed Wetland
1
LS
$489,000
$489,000
Chlorine contact tank
1
LS
$150,000
$150,000
Chlorine feed system
1
LS
$26,577
$26,577
Land Application piping
2,700
LF
$125
$337,500
Land Application trees/ground cover
5.5
AC
$5,000
$27,500
Effluent flow meter and sampler
1
LS
$154,780
$154,780
Subtotal
$10,472,000
On-site electrical
15%
$1,570,800
Mobilization/Demoblization
1.0%
$104,720
Total $12,148,000
Contingency 20% $2,430,000
TOTAL ORDER OF MAGNITUDE CONSTRUCTION COST $14,600,000.00
-------
County of Hawaii Department of Environmental Management
Pahala WWTP
Preliminary Options Assessment - Capital Costs
Wetlands
Description
Quantity
Units
Unit Cost
Extension
linear
13,100
SF
$4
$52,400
gravel
1,000
CY
$50
$50,000
piping
500
LF
$100
$50,000
Effluent Structure
1
EA
$50,000
$50,000
Standpipe
1
EA
$25,000
$25,000
plantings
13,100
sf
$20
$262,000
Subtotal
$489,000
A-3
-------
County of Hawaii Department of Environmental Management
Pahala WWTP
Options Assessment Cost Summary
Capital Costs
Option
Capital Cost ($M)
Total
No.
Treatment
Disposal
Recycling
Lagoons
R-l
Limit of TT
Disposal
Reservoir
Diurnal Tank
R-l Pumps
R-l Pipelines
($M)
1
Aerated lagoons/wetland/disinfection
Land application
None
10.8
3.8
14.6
2
MBR (R-l)
Land application
None
14.6
3.8
18.4
3
MBR (R-l)
Land application
Seasonal (25% of total annual flow)
14.6
3.8
0.8
0.5
0.5
20.2
4
MBR (R-l)
Land application
Annual storage reservoir (100% of flow)
14.6
3.8
6.1
3.5
1.0
1.5
30.4
5
Limit of treatment technology
Land application
Seasonal (25% of total annual flow)
20.4
3.8
0.8
0.5
0.5
26.0
Annual O&M Costs
No.
Treatment
Disposal
Recycling
Annual O&M Costs ($)
Labor
Electricity
Chemicals
Maintenance
Sludge Mgmt
Total
1
Aerated lagoons/wetland/disinfection
Land application
None
$42,000
$118,000
$12,000
$54,000
$10,000
$236,000
2
MBR (R-l)
Land application
None
$582,000
$345,000
$10,000
$73,000
$42,000
$1,052,000
3
MBR (R-l)
Land application
Seasonal (25% of total annual flow)
$582,000
$348,000
$10,000
$73,000
$42,000
$1,055,000
4
MBR (R-l)
Land application
Annual storage reservoir (100% of flow)
$582,000
$356,000
$10,000
$73,000
$42,000
$1,063,000
c
Limit of treatment technology
Land application
Seasonal (25% of total annual flow)
$874,000
$348,000
$35,000
$102,000
$62,000
$1,421,000
Annual Recycled Water Sales
No.
Treatment
Disposal
Recycling
Annual R-l Water Sales
High Price
Low Price
1
Aerated lagoons/wetland/disinfection
Land application
None
$0
$0
2
MBR (R-l)
Land application
None
$0
$0
3
MBR (R-l)
Land application
Seasonal (25% of total annual flow)
$17,000
$9,000
4
MBR (R-l)
Land application
Annual storage reservoir (100% of flow)
$68,000
$38,000
5
Limit of treatment technology
Land application
Seasonal (25% of total annual flow)
$17,000
$9,000
Equipment Replacement at 20-Years
No.
Treatment
Disposal
Recycling
Equipment
Replacement
1
Aerated lagoons/wetland/disinfection
Land application
None
$2,693,000
2
MBR (R-l)
Land application
None
$3,653,000
3
MBR (R-l)
Land application
Seasonal (25% of total annual flow)
$3,653,000
4
MBR (R-l)
Land application
Annual storage reservoir (100% of flow)
$3,653,000
5
Limit of treatment technology
Land application
Seasonal (25% of total annual flow)
$5,097,000
-------
County of Hawaii Department of Environmental Management
Pahaia WWTP
Preliminary Options Assessment - Capital Costs
Common Capital Inputs
Current ENRCCI:
Area markup factor:
Contingency factor:
Project soft costs factor:
10870
30%
20%
25%
Lagoon-Wetland Treatment
Description
Quantity
Units
Unit Cost
Extension
Clear and grub
8
AC
$15,000
$120,000
BMPs
8
AC
$13,000
$104,000
Earthwork
9,500
CY
$25
$237,500
Sewer extension
700
LF
$160
$112,000
Head works
1
EA
$500,000
$500,000
Lagoons
1
LS
$1,800,000
$1,800,000
Wetlands
1
LS
$350,000
$350,000
Chlorine contact tank
1
LS
$100,000
$100,000
Chlorine feed system
1
LS
$30,000
$30,000
Operations building
1,500
SF
$500
$750,000
Generator and tank
1
LS
$250,000
$250,000
Fencing
1,500
LF
$100
$150,000
Paving
15,000
SY
$55
$825,000
Water line extension
1,500
LF
$160
$240,000
Yard piping
1
LS
$200,000
$200,000
Miscellaneous site work
1
LS
100,000
$100,000
HELCO power
1
LS
50,000
$50,000
Hawaiian Telcom
1
LS
20,000
$20,000
Archeological monitoring
8
AC
2,500
$20,000
Visual buffer trees and irrigation
10
EA
2,500
$25,000
Subtotal
Electrical and instrumentation
Total construction
Contingency
Total construction
Project soft costs
Total project cost:
$5,983,500
20% $1,196,700
$7,180,200
$1,436,040
$8,616,240
$2,154,060
$10,770 million
Land Application
Description
Quantity
Units
Unit Cost
Extension
Clear and grub
6
AC
$15,000
$82,500
BMPs
6
AC
$13,000
$71,500
Earthwork
33,500
CY
$25
$837,500
Fencing
1,700
LF
$100
$170,000
Paving
23,000
SY
$30
$690,000
Yard piping
3,500
LF
$160
$560,000
Planting
6
AC
10,000
$60,000
Effluent flow meter and sampler
1
LS
50,000
$50,000
Archeological monitoring
6
AC
2,500
$15,000
Subtotal $2,536,500
Electrical and instrumentation 0% $0
Total construction $2,536,500
Contingency $507,300
Total construction $3,043,800
Project soft costs $760,950
Total project cost: $3,805 million
-------
R-l Treatment
Capacity:
Mainland cost at current ENRCCI:
Local construction cost:
Construction estimate:
Contingency:
Total construction cost:
Project soft costs:
Total project cost:
mgd
$39.44 /gpd
$51.27
$9.7
$1.9
$11.7
$2.9
$14.6
/ gpd
million
million
million
million
million
from R-l WWRF capital regression. y=24.003*(x*-0.299)
Limit of Treatment Technology
ENRCCI of estimate:
10 mgd WWTP cost:
10 mgd WWTP cost at current ENRCCI:
Local 10 mgd WWTP cost:
Small flow escalation:
Construction estimate:
Contingency:
Total construction cost:
Project soft costs:
Total project cost:
$16.76
$21.78
$71.54
$13.6
$2.7
$16.3
$4.1
$20.4
/gpd
/gpd
/gpd
/gpd
million
million
million
million
million
y=43.47xA-0.3 Per WERF analysis. BNR + advanced nutrient removal
Seasonal Storage Reservoir
Volume:
Mainland construction cost:
Subtotal:
Local construction cost:
Contingency:
Total construction cost:
Project soft costs:
Total project cost:
124 ac-ft
Q(jo|/ac-ft
$3.1 million
$4.0 million
$0.8 million
$4.8 million
$1.2 million
$6.1 million
Diurngl R-l Tgnk - Seasonal Progrgm
Volume:
Local construction cost:
Subtotal:
Contingency:
Total construction cost:
Project soft costs:
Total project cost:
0.19 mgal
_]/ga||on
$0.6 million
$0.1 million
$0.7 million
$0.1 million
$0.8 million
1 peak day
Diurngl R-l Tgnk - Reservoir Progrgm
Volume:
Local construction cost:
Subtotal:
Contingency:
Total construction cost:
Project soft costs:
Total project cost:
0.77 mgal
,1/gallon
$2.3 million
$0.5 million
$2.8 million
$0.69 million
$3.5 million
1 peak day
-------
R-l Delivery Pumps - Seasonal Program
Peak day flow 0.19 mgal
Delivery time: "' hours
Pumping capacity: 396 gpm
Mainland construction cost @ ENRCCI 4500:
Current mainland construction cost: $242,000
Local construction cost: $315,000
Contingency: $63,000
Total construction cost: $378,000
Project soft costs: $94,500
Total project cost: $0.5 million
R-l Delivery Pumps - Reservoir Storage
Peak day flow 0.77 mgal
Delivery time: S hours
Pumping capacity: 1604 gpm
Mainland construction cost @ ENRCCI 4500: _
Current mainland construction cost: $483,000
Local construction cost: $628,000
Contingency: $125,600
Total construction cost: $753,600
Project soft costs: $188,400
Total project cost: $1.0 million
R-l Pipelines - Seasonal Progrgm
Peak delivery rate: 396 gpm
Pipeline diameter: inches
Hawaii construction cost: i/in-ft
Estimated length: Ifeet
Local construction cost: $300,000
Contingency: $60,000
Total construction cost: $360,000
Project soft costs: $90,000
Total project cost: $0.5 million
R-l Pipelines - Reservoir Storoge
Peak delivery rate: 1604 gpm
Pipeline diameter: inches
Hawaii construction cost: 'in-ft
Estimated length: feet
° L.—:—; —i
Local construction cost: $1,000,000
Contingency: $200,000
Total construction cost: $1,200,000
Project soft costs: $300,000
Total project cost: $1.5 million
-------
County of Hawaii Department of Environmental Management
Pahaia WWTP
Preliminary Options Assessment
O&M Costs
Common O&M Inputs
Labor cost:
$100
/hr (loaded)
FTE effective labor:
1,560
hours/year
Chlorine tab cost:
$4
/lb
Alum cost:
$2
/lb
Electricity cost:
$0.35
/kWh
Maintenance cost:
2%
/year of equipment capital
Sludge management cost:
$1,500
/dry ton, dewatering, hauling, tip fee
Average flow: 0.19 mgd
1
Lagoon Treatment/Wetlands/Disinfection
Labor
Normal requirement:
Operators/visit:
Time per visit:
Weekly labor hours:
1
visit/week
hours/visit
8 hours/week
Annual labor hours:
416 hours/year
FTEs:
0.3
FTEs
Annual labor cost:
$41,600|/yr
Electricity
Load
Equiv hp
Percent
kWhr/mo
$/month
Aerators
50
100%
26,845
$9,396
Screens
2
10%
107
$38
Chlorine pumps
0.5
30%
81
$28
Effluent pumps
2
100%
1,074
$376
Totals
$9,837
Annual power cost:
$118,049
Annual power consumption
337283 kWh/yr
Chemicals
Chlorine dose:
5|mg/L
Daily use:
8
Ibs/d
Annual use:
2892 Ibs/d
Annual cost:
oo
KD
LD
T—1
T—1
w
/yr
Maintenance
Equipment cost:
$2,692,575
(assume 25% of capital cost)
Annual maintenance:
$53,852
/yr
Sludge Management
dry tons/mga
Production rate:
0.1
Annual production:
6.935 /dry tons
Sludge management cost:
$10,403 /year (deferred for 20 years)
R-l Treatment
Labor
Normal requirement:
Operators/visit:
Time per visit:
Weekly labor hours:
Annual labor hours:
FTEs:
Annual labor cost:
visits/week
8 hours/visit
112 hours/week
5824 hours/year
3.7 FTEs
$582,400
-------
Electricity
Daily power use:
Annual power use:
Annual power cost:
Chemicals
Annual chemical cost:
Maintenance
Equipment cost:
Annual maintenance:
Sludge Management
Sludge production:
Annual production:
Sludge management cost:
2,700|kWh/d
985,500 kWh/yr
$344,925 |/yr
$10,000
$3,652,973 (assume 25% of capital cost)
$73,059 |/yr
0.4|dry tons/mgal
28 /dry tons
$41,610|/year
Limit of Treatment Technology
Labor
Normal requirement:
Operators/visit:
Time per visit:
Weekly labor hours:
Annual labor hours:
FTEs:
Annual labor cost:
visits/week
8 hours/visit
168 hours/week
8736 hours/year
5.6 FTEs
$873,6001
Electricity
Daily power use:
Annual power use:
Annual power cost:
Chemicals
Alum dose
Alum use:
Alum cost:
Maintenance
Equipment cost:
Annual maintenance:
Sludge Management
Sludge production:
Annual production:
Sludge management cost:
2,700|kWh/d
985,500 kWh/yr
$344,925 |/yr
30|mg/L
48 Ibs/d
$34,703 |/yr
$5,097,397 (assume 25% of capital cost)
$101,948 |/yr
0.6|dry tons/mgal
42 /dry tons
$62,415|/year
Seasonal Water Recycling 125%)
Load
Equiv hp
Percent
kWhr/mo
$/month
R-l delivery pumps
5
25%
671
$235
Totals
$235
Annual power cost:
$2,819
Annual power consumption: 8054 kWh/yr
Annual Water Recycling 1100%)
Load
Equiv hp
Percent
kWhr/mo
$/month
R-l delivery pumps
5
100%
2,685
$940
Totals
$940
Annual power cost:
$11,275
Annual power consumption: 32214 kWh/yr
-------
County of Hawaii Department of Environmental Management
Pahala WWTP
R-l Sales Assessment
Avoided Cost of Pumping Irrigation Water
Assume pumping from basal lens
Elevation at WWTP:
Flow rate:
Pump efficiency:
Motor efficiency:
Power cost:
BHP:
Motor draw:
Unit volume:
Time to pump unit vol:
Power to pump unit vol:
$0.35 /kWh
223 hp
185 kW
1 mgal
16.7 hours
3080 kWh
Cost to pump unit vol: $1,078
Recycled Water Pricing
High price:
Low price:
90%
50%
of avoided cost
of avoided cost
Recycled Wgter Sales
High price: $970 /mgal
Low price: $539 /mgal
Segsongl Recycling Sgles
Annual reuse volume: 17 mgal
High price sales: $16,661 /year
Low price sales: $9,256 /year
100% Recycling Sgles
Annual reuse volume: 70 mgal
High price sales: $67,987 /year
Low price sales: $37,770 /year
-------
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-------
County of Hawaii Department of Environmental Management
Pahala WWTP
Preliminary Options Assessment
Operator Requirement Evaluation
No.
Treatment
Disposal
Recycling
1
Aerated lagoons/disinfection
Land application
None
2
MBR (R-l)
Land application
None
3
MBR (R-l)
Land application
Seasonal (25% of total annual flow)
4
MBR (R-l)
Land application
Annual storage reservoir (100% of flow)
5
Limit of treatment technology
Land application
Seasonal (25% of total annual flow)
Criteria per HAR 11-61
Option
1
2
3
4
5
Population served
1
1
1
1
1
Design average flow
1
1
1
1
1
Effluent discharge
2
2
6
6
6
Variation on raw wastes
0
0
0
0
0
Pretreatment
5
10
10
10
10
Primary treatment
0
0
0
0
0
Secondary treatment
8
15
15
15
20
Advanced waste treatment
0
12
12
12
22
Additional treatment processes
7
7
7
7
7
Solids handling
0
19
19
19
19
Disinfection
5
10
10
10
10
Laboratory control bacteriological
0
0
0
0
0
Laboratory control chemical/physical
0
0
0
0
0
Total points
29
77
81
81
96
WWTP Classification per 11-61
IV
-------
County of Hawaii Department of Environmental Management
Pahala WWTP
Water Recycling Assessments
Seasonal Recycling with Disposal
Average flow: 0.19 mgd
Irrigated acreage: :res
Month
Days
WW Flow
(mgal)
Irrig Demand
Disposal
(mgal)
(gpd/ac)
(mgal)
Jan
31
5.9
0
0.0
5.9
Feb
28
5.3
0
0.0
5.3
Mar
31
5.9
0
0.0
5.9
Apr
30
5.7
644
1.2
4.5
May
31
5.9
2,244
4.3
1.6
Jun
30
5.7
3,043
5.7
0.0
Jul
31
5.9
1,348
2.6
3.3
Aug
31
5.9
1,452
2.8
3.1
Sep
30
5.7
334
0.6
5.1
Oct
31
5.9
0
0.0
5.9
Nov
30
5.7
0
0.0
5.7
Dec
31
5.9
0
0.0
5.9
Totals
365
69.35
17
52
Recycling efficiency: 25%
Recycling with Annual Storage Reservoir
Average flow:
Irrigated acreage:
Reservoir surface area:
Reservoir pan coefficient:
0.19 mgd
25b acres
G.i- acres
Reservoir Storage
Month
Days
WW Flow
(mgal)
Irrig Demand
WW in
Precipitation in
Pan Evap
(inches)
Evap out
Delta Storage
(mgal)
Cumulative Storage
Water Depth
(feet)
(gpd/ac)
(mgal)
(mgal)
(inches)
(mgal)
Inches
(mgal)
(mgal)
(ac-ft)
Jan
31
5.9
0
0.0
5.9
5.98
1.0
4.55
3.2
0.6
6.4
28.1
86.3
13.5
Feb
28
5.3
0
0.0
5.3
3.77
0.7
4.54
3.2
0.6
5.4
33.5
102.9
16.1
Mar
31
5.9
0
0.0
5.9
5.45
0.9
4.97
3.5
0.6
6.2
39.8
122.0
19.1
Apr
30
5.7
644
4.9
0.8
3.23
0.6
5.4
3.8
0.7
0.7
40.5
124.2
19.4
May
31
5.9
2244
17.6
-11.7
1.94
0.3
5.6
3.9
0.7
-12.1
28.4
87.3
13.6
Jun
30
5.7
3043
23.1
-17.4
1.56
0.3
5.94
4.2
0.7
-17.8
10.6
32.5
5.1
Jul
31
5.9
1348
10.6
-4.7
3.27
0.6
6.37
4.5
0.8
-4.9
5.7
17.5
2.7
Aug
31
5.9
1452
11.4
-5.5
3.08
0.5
6.23
4.4
0.8
-5.7
0.0
0.0
0.0
Sep
30
5.7
334
2.5
3.2
3.6
0.6
5.55
3.9
0.7
3.1
3.1
9.6
1.5
Oct
31
5.9
0
0.0
5.9
3.98
0.7
5.05
3.5
0.6
6.0
9.1
27.9
4.4
Nov
30
5.7
0
0.0
5.7
6.7
1.2
4.49
3.1
0.5
6.3
15.4
47.3
7.4
Dec
31
5.9
0
0.0
5.9
5.82
1.0
4.62
3.2
0.6
6.3
21.7
66.7
10.4
Totals
365
69.35
70
48.4
8.4
63.3
7.7
0.0
Recycling efficiency: 101% MaxVolume: 40 Mgal
124 acft
Peakdemand: 23.1 mgal/mo
0.77 mgd
-------
Pahala Wastewater Treatment Plant Preliminary Engineering Report
Appendix B: Collection System Plan
Brown AND Caldwell j
B-l
-------
FUKUf* k ASSOCIATES, INC.
LTING ENGINEERS
MEMORANDUM
TO: Michelle Sorensen. Brown and Caldwell
Craig Lekven, Brown and Caldwell
FROM: Andrew Amuro
DATE: June 20, 2018
SUBJECT: Pahala Collection System Description
County of Hawaii
1. GENERAL PROJECT DESCRIPTION
This County of Hawaii (COH) is scheduled to close two large capacity cesspools (LCCs) in the town
of Pahala on the southeast side of the Big Island. To accomplish the closure, the COH has tasked
Brown and Caldwell (B&C) with designing a wastewater treatment plant (WWTP) to serve the
properties impacted by the LCC closure. Fukunaga and Associates, Inc. (FAI) has been tasked with
designing the collection system to convey the wastewater from the impacted properties to the
proposed WWTP. The collection system and properties to be served is shown on Figure 1. The
County will be the owner of the collection system; therefore, the sewer system must meet County
standards and must be accessible for maintenance. Preference is to construct sewers within the
County right-of-way as much as possible unless other factors make placing the pipes within
easements much more practical from economic and engineering standpoints. In addition, the County
will not allow construction of sewers in smaller residential "backward" casements. These easements
are difficult to access for maintenance and can also hinder the home owner's ability to enjoy or
benefit from their proper tv as they see fit.
The focus of the project is to close the LCCs as expediently and economically as possible; however,
the COH desires to eventually expand the wastewater system of this project to service the entire
community of Pahala. Therefore, the collection system will be sized to accommodate the anticipated
wastewater from the entire community to the extent that can be reasonably predicted at this early
stage in the system development. The benefit of flexibility for future plans outweighs the cost of
providing larger pipes at this time.
:0 1 Ph: 808.944.1821 I *• '• • jgaenglneers.com
I Fax: 808.946.9339 1 kunagaengineers.com
-------
Memorandum
Pahala Collection System Description
June 20, 2018
Page 2
2. PROJECT PHASING
The project will be implemented in two phases to expedite the LCC closure. The collection system
phasing is indicated on Figure 2 and 3.
Phase 1 consists of the portions of the collection system required to divert wastewater from the LCCs
to the proposed WWTP. To accomplish this as quickly as possible, the existing collection system will
be intercepted before entering the LCCs and diverted into the new Phase 1 collection system. There
will be a portion of the sewer within an existing roadway (Pikake St. extension) on private property
owned by Edmund Olsen. The County will obtain an easement for the approximately 350 linear feet
of sewer within this private road. The LCC closures will be part of the Phase 1 work.
Phase 2 will consist of the necessary sewers and pumps needed to de-commission the aging plantation
collection system and construct a municipal sewer system that meets current County standards. The
plantation system crosses through private properties and under some residences, making the system
difficult to access for maintenance. This phase will place the new sewers mostly within the County
right-of-way for ease of access and connect the individual properties impacted by the LCC closures to
these sewers. There will be an 1,100 linear feet portion of the sewer that follows the existing
plantation sewer route within an industrial area between Ilima and Maile Streets. The property at
TMK 9-6-005:036 is owned by Edmund Olsen and leased to M L Macadamia Orchards. The County
will obtain an easement within this area to maintain the sewer.
3. TOPOGRAPHY AND SOILS
Pahala slopes down at about 6-percent from the northwest to the southeast, from an elevation of 1000
ft above mean sea level (MSL) to 800 ft MSL over a distance of 3,500 feet. A topographic map of the
area is provided in Figure 4. Available information on soil condition indicates shallow soils in the
residential areas over basalt. Soils as shallow as 12" are reported in some areas. The soil cover
appears to get deeper in the downhill direction.
Several roads in Pahala roughly follow contour lines to maintain level or appropriately sloped grades
for vehicles. This is the case for Hinano Street and Pikake Street. This results in houses on the
downhill side of the roads to be several feet below the road surface while uphill houses are several
feet above the road surface. The laterals coming from downhill dwellings would result in a deep
gravity sewer in these areas. If it is not feasible to construct deep sewers in these streets due to
unavoidable subsurface conditions or unreasonably deep pipes and manholes, an alternative such as
individual pump stations or different sewering method may be needed. A more detailed discussion of
the areas requiring pumps is presented in the next section.
-------
Memorandum
Pahala Collection System Description
June 20, 2018
Page 3
4. PUMP STATIONS
The design of the collection system will minimize the use of pump stations as much as possible. This
will serve to enhance reliability and minimize operation and maintenance costs. There is one property
currently connected to the sewer system that will require a pump station. The Methodist preschool
located at TMK 9-6-015:033 is located on the downhill side of Huapala Street, approximately 20 feet
below the elevation of the street. It would not be practical to lower the sewer to this extent to service
this property.
There are also four properties on the downhill side of Hinano Street that are connected to the sewer
system that may require pumps. The intent of the design is to lower the sewer on Hinano Street to
service these properties by gravity; however, the subsurface conditions will have to be verified before
a final determination can be made.
There are also several newly accessible properties on Pikake Street that require pumps if the sewer is
not constructed deep. Based on what has been reported of subsurface conditions at the Kau High
School, it is suspected that the sewer on Pikake Street would not be able to be set low enough to serve
these properties; therefore, the assumption is most of the newly accessible properties east of Pikake
Street will require pumps.
5. PIPE SIZING
Sewer pipe sizing is based on the flow estimates provided by B&C and a best guess of how the entire
community will be eventually serviced. It is assumed that the sewer on Maile Street will eventually
convey the flow from the entire community. It is also anticipated that the sewer on Pikake Street will
eventually have other sewers feeding into them from surrounding areas. Similarly, for the sewers to
be constructed in Phase 2, there will be surrounding areas eventually feeding into the sewers on
Puahala/Kamani Streets. It is assumed future sewers would not be feeding into Huapala Street. It is
assumed the areas northeast of Huapala Street can be served by the sewers system to the east;
therefore, the sewer is not up-sized for future flows. A summary of the estimated pipe sizes and
lengths is presented in Table 1.
-------
Memorandum
Pahala Collection System Description
June 20, 2018
Page 4
Table 1: Approximate Pipe Size and Lengths
Location
Start
End
Size
Length
Phase 1
Waterline
Pikake St
Pikake
WWTP
6
2200
SLA
Maile St (deep to normal)
Huapala
WWTP
16
1730
SL CI
Pikake St Ph 1
Ohia
Maile
14
780
Phase 2
SL B-l
llima St
Huapala
llima
8
335
SL B-2
Huapala St
Hinano
Pikake
8
410
SLC2
Pikake St
Pakalana
Ohia
14
1569
SL D
Puahala St & Kamani St
Pakalana
Pikake
12
1150
SL E
Hinano St (deep)
Hapu
Huapala
8
700
SL F
Hala St
End
Hinano
8
250
SL G
Huapala St
Pakalana
llima
8
1650
SL H
llima St
End
Huapala
8
1750
SL 1
Easement thru Olson Land
llima
Maile
12
875
Pipe material will be AWWA C900 PVC for corrosion resistance. Although this application is for
gravity service, the thick wall C900 pressure pipe is preferred for durability in service and during
installation.
6. COST
The 0% cost estimates for Phase 1 and Phase 2 are based on recent bid tabs. Costs from a recent
project were much higher than originally anticipated. Phase 1 using recent bid cost is approximately
$4 million. Phase 2 using the same basis is $9 million. These costs will be refined further as the
design is develop.
-------
o
O
O
cl
o
o
o
Ka'u High & Pahala
Elementary School
Proposed Pahala
WWTP Site
fm
ITMK 9-6-017:038 will riot |
connect to system
LEGEND
I Existing Condition to Large Capacity Cesspool (LCC)
I Initial Build Condition to WWTP
| Proposed Pahala WWTP Site
~ Existing Large Capacity Cesspool
> Pahala Future County Sewer System
Existing Large Capacity
Cesspool (LCC 2)
Ka'u
Hospital
NOTE: Deep sewers mav riot be acceptable oendin
Properties That Can Be
Connected by Deep Sewer
Sewer w/in Easements
Properties Req. Pump
resuns ot geoiecnnicai investigation ana cultural stuaies
Brown
AND
Caldwell i
SCALE: AS SHOWN
JOB NO: 150440
FIGURE
2-1
1.000
2,000
'm s
/V—" I
PAHALA WASTEWATER TREATMENT PLANT
PAHALA WWTP SERVICE AREA
Sewer w/in Temp. Easements to Close
LCCs Before Collection System Completed
Existing Large Capacity
Cesspool (LCC 1)
-------
Easement
Intercept "existing sewers
Phase 1 Sewers (Purple)
LCC 1
Legend
o
Naalehu-Pahala LCCs
Naalehu-Pahala Sewer Manholes
Naalehu-Pahala Sewer Lines
Elec Permits Pahala "Cancelled" (1)
Elec Permits Pahala "Complete" (4)
)ing^Permits Pahala "Cancelled" (1)
Plumbing Permits Pahala "Complete" (93)
Plumbing Permits Pahala "No R'ibord" (4)
Parcels
SeiWices
tatus
Connected (1)
• Assumed Connection (100)
x Not Connected" (0)
N
WKfiEyfl E
S
0 100 200 400 600
I Feet
800
PERMIT STATUS Figure 2
Electrical (Transfer Switch & Pump) and Plumbing Collection System Phase 1
Pahala
Oct. 05, 2016
-------
KOAUSr
PUMEUST
HOLEI ST
Phase 2 Sewers (Greerr
KAMANtST
1699©H'A ST
HINANOST
396023025
Legend
Figure 3
Collection System Phas<
Oct. 05, 2016
and Plumbing
Naalehu-Pahala LCCs
Naalehu-Pahala Sewer Manholes
Naalehu-Pahala Sewer Lines
Elec Permits Pahala "Cancelled" (1)
Elec Permits Pahala "Complete" (4)
)ing^Permits Pahala "Cancelled" (1)
Plumbing Permits Pahala "Complete" (93)
Plumbing Permits Pahala "No R'ibord" (4)
Parcels
SeiWices
tatus
Connected (1)
• Assumed Connection (100)
x Not Connected" (0)
PERMIT STATUS
Electrical (Transfer Switch & Pump)
Pahala
2
-------
Pahaia
Landing Strip
iaging Station
Ri«h Sc£
Approx Scale: 1" = 1500 feet
Figure 4
Topographic Map
-------
Cost Estimate
Pahala Phase 1, Option B
Connect Brewer Collection System to WWTP, Olson Easements, Minimal Plans for Future Connections
QTY
UM
MATERIAL
LABOR
EQUIPMENT
UNIT COST
TOTAL
GENERAL
Mobilization
1
LS
$ 220,000.00
$
220,000.00
Traffic Control
1
LS
$
30,000.00
$
30,000.00
Staging Area
1
LS
$
25,000.00
$
25,000.00
BMPs, Erosion Control
1
LS
$
65,000.00
$
65,000.00
Archaeological Monitoring
260
day
$
2.00
$
880.00
$
5.00
$
887.00
$
230,620.00
Job Shack and Supplies
24
mo
$
250.00
$ 10,000.00
$
250.00
$
10,500.00
$
252,000.00
Temp Utilities
24
mo
$
3,000.00
$
72,000.00
Demobilization
1
LS
$
30,000.00
$
30,000.00
WATER DISTRIBUTION
Trenching
916.67
cy
$
$
500.00
$
175.00
$
675.00
$
618,750.00
Haul Exc Material
916.67
cy
$
$
13.00
$
7.53
$
20.53
$
18,819.17
Bedding
306.00
cy
$
46.60
$
28.56
$
11.85
$
87.01
$
26,625.06
Backfill
610.67
cy
$
8.00
$
28.56
$
11.85
$
48.41
$
29,562.53
Haul to Job Site
916.67
cy
$
$
13.00
$
7.53
$
20.53
$
18,819.24
6" Dl Pipe
2200
If
$
40.66
$
25.19
$
3.80
$
69.65
$
153,230.00
Fittings
1200
lb
$
6.19
$
2.20
$
0.33
$
8.72
$
10,464.00
Valves, ARVs
4
ea
$
3,065.25
$
2,882.30
$
436.51
$
6,384.06
$
25,536.24
Temp Trench Patch
5500
sf
$
8.00
$
5.00
$
3.00
$
16.00
$
88,000.00
SEWERLINE A
Trenching
1174.69
cy
$
$
500.00
$
175.00
$
675.00
$
792,916.67
Haul Exc Material
1174.69
cy
$
$
13.00
$
7.53
$
20.53
$
24,116.41
Bedding
500.00
cy
$
46.60
$
28.56
$
11.85
$
87.01
$
43,505.00
Backfill
674.69
cy
$
8.00
$
28.56
$
11.85
$
48.41
$
32,661.81
Haul to Job Site
1174.69
cy
$
$
13.00
$
7.53
$
20.53
$
24,116.41
16" PVC Pipe
1730
If
$
28.60
$
6.47
$
1.47
$
36.54
$
63,214.20
Manhole
7
ea
$
12,000.00
$
7,500.00
$
6,000.00
$
25,500.00
$
178,500.00
Temp Trench Patch
5800
sf
$
8.00
$
5.00
$
3.00
$
16.00
$
92,800.00
-------
.00
00
,86
.73
,36
,86
,80
,00
,00
,00
,00
,00
,00
,00
,90
,00
,30
,70
,00
,00
,00
,00
,00
,00
,00
,71
,30
,00
ea
$ 1,200.00
$ 2,000.00
200.00
$ 3,400.00
686.11
686.11
cy_
cy
$
$
$ 500.00
$ 13.00
$ 175.00
$ 7.53
675.00
20.53
198.25
cy
46.60
$
28.56
$
11.85
87.01
487.86
cy
8.00
$
28.56
$
11.85
48.41
686.11
780
cy_
If
$
$
21.00
$ 13.00
$ 4.85
7.53
1.11
20.53
26.96
ea
$ 12,000.00
$ 7,500.00
$ 6,000.00
$ 25,500.00
2470
sf
$
8.00
$
5.00
$
3.00
$
16.00
ea
$ 1,800.00
$ 2,000.00
200.00
$ 4,000.00
300
sq ft
$
5.50
1.50
7.00
130.00
24.00
cy_
hr
$
$
$ 23.00
$ 300.00
9.60
90.00
32.60
390.00
3000.00
gal
$
6.00
0.75
6.75
90.00
cy
46.60
$
28.56
11.85
87.01
300.00
130
sq ft
cy
10.00
$ 25.00
$ 28.56
5.00
11.85
40.00
40.41
90
cy
$
13.00
7.53
20.53
ea
70.00
$
160.00
20.00
250.00
1
300
ea
sf
$
$
1.75
$ 4,000.00
$ 2.50
100.00
1.00
4,100.00
5.25
300
130.00
sq ft
cy
$
$
5.50
23.00
1.50
9.60
7.00
32.60
8.00
hr
300.00
90.00
390.00
500.00
gal
6.00
0.75
6.75
8.33
130
cy
cy
ea
750.00
70.00
225.00
28.56
160.00
12.00
11.85
20.00
987.00
40.41
250.00
-------
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-lo-
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300
13770
255.00
255.00
1530
Final Completion Report
Landscaping
SITE RESTORATION
Remove Temp Trench Patch
Haul Exc Material
Subbase & Base Course
AC Pavement
SUBTOTAL
-------
Cost Estimate
Pahala Phase 2, Option B
Connect Brewer Properties to New Sewer System, Olson Easements
Use Deep Sewers on Hinano St, Olson Easements, Minimal Plans for Future Connections
QTY
UM
MATERIAL
LABOR
EQUIPMENT
UNIT COST
TOTAL
GENERAL
Mobilization
1
LS
$ 220,000.00
$
220,000.00
Traffic Control
1
LS
$
30,000.00
$
30,000.00
Staging Area
1
LS
$
25,000.00
$
25,000.00
BMPs, Erosion Control
1
LS
$
65,000.00
$
65,000.00
Archaeological Monitoring
260
day
$
2.00
$
880.00
$
5.00
$
887.00
$
230,620.00
Job Shack and Supplies
24
mo
$
250.00
$ 10,000.00
$
250.00
$
10,500.00
$
252,000.00
Temp Utilities
24
mo
$
3,000.00
$
72,000.00
Demobilization
1
LS
$
30,000.00
$
30,000.00
5EWERLINE B-l
Trenching
248.98
cy
$
$
500.00
$
175.00
$
675.00
$
168,058.33
Haul Exc Material
248.98
cy
$
$
13.00
$
7.53
$
20.53
$
5,111.46
Bedding
56.00
cy
$
46.60
$
28.56
$
11.85
$
87.01
$
4,872.56
Backfill
192.98
cy
$
8.00
$
28.56
$
11.85
$
48.41
$
9,341.93
Haul to Job Site
248.98
cy
$
$
13.00
$
7.53
$
20.53
$
5,111.46
8" PVC Pipe
335
If
$
21.00
$
4.85
$
1.11
$
26.96
$
9,031.60
Manhole
2
ea
$
12,000.00
$
7,500.00
$
6,000.00
$
25,500.00
$
51,000.00
Temp Trench Patch
894
sf
$
8.00
$
5.00
$
3.00
$
16.00
$
14,304.00
SEWERLINE B-2
Trenching
263.21
cy
$
$
500.00
$
175.00
$
675.00
$
177,666.67
Haul Exc Material
263.21
cy
$
$
13.00
$
7.53
$
20.53
$
5,403.70
Bedding
68.00
cy
$
46.60
$
28.56
$
11.85
$
87.01
$
5,916.68
Backfill
195.21
cy
$
8.00
$
28.56
$
11.85
$
48.41
$
9,450.11
Haul to Job Site
263.21
cy
$
$
13.00
$
7.53
$
20.53
$
5,403.70
8" PVC Pipe
410
If
$
21.00
$
4.85
$
1.11
$
26.96
$
11,053.60
Manhole
2
ea
$
12,000.00
$
7,500.00
$
6,000.00
$
25,500.00
$
51,000.00
Temp Trench Patch
1094
sf
$
8.00
$
5.00
$
3.00
$
16.00
$
17,504.00
-------
.75
,25
.07
,65
,25
,24
,00
,00
,00
,03
,56
,51
,03
,00
00
,00
33
,89
,16
,01
,89
,00
,00
,00
33
,68
1380.14
cy
$
500.00
$ 175.00
675.00
1380.14
307.00
cy_
cy
$
$
46.60
$ 13.00
$ 28.56
7.53
11.85
20.53
87.01
1073.14
cy
$
8.00
$
28.56
$
11.85
$
48.41
1380.14
cy
$
$
13.00
$
7.53
$
20.53
1569.00
6
ea
$ 21.00
$ 12,000.00
$ 4.85
$ 7,500.00
$ 1.11
$ 6,000.00
$ 26.96
$ 25,500.00
4968.5
sf
$
8.00
$
5.00
$
3.00
$
16.00
702.78
cy
500.00
175.00
675.00
702.78
cy
$
13.00
7.53
20.53
256.00
cy
46.60
$
28.56
11.85
87.01
446.78
702.78
cy_
cy
$
$
8.00
$ 28.56
$ 13.00
11.85
7.53
48.41
20.53
1150.00
$
21.00
$
4.85
$
1.11
$
26.96
ea
$ 12,000.00
$ 7,500.00
$ 6,000.00
$ 25,500.00
3450
sf
$
8.00
$
5.00
$
3.00
$
16.00
1035.31
cy
$
500.00
$ 175.00
675.00
1035.31
115.23
cy_
cy
$
$
46.60
$ 13.00
$ 28.56
7.53
11.85
20.53
87.01
920.08
cy
$
8.00
$
28.56
$
11.85
$
48.41
1035.31
cy
$
$
13.00
$
7.53
$
20.53
700.00
2
ea
$ 9.70
$ 12,000.00
$ 2.91
$ 7,500.00
$ 0.66
$ 6,000.00
$ 13.27
$ 25,500.00
1867
sf
$
8.00
$
5.00
$
3.00
$
16.00
234.57
234.57
cy_
cy
500.00
13.00
175.00
7.53
675.00
20.53
-------
.46
.36
.68
.50
.00
.00
.00
.41
.34
.58
.41
.50
.00
.00
.00
.56
.24
.60
.56
.20
.00
.00
.67
.74
.95
.70
.74
.25
41.15
193.42
234.57
250.00
1
cy_
cy
cy_
ea
$ 46.60
$ 8.00
$
$ 9.70
$ 12,000.00
28.56
28.56
13.00
$ 2.91
$ 7,500.00
11.85
11.85
7.53
$ 0.66
$ 6,000.00
87.01
48.41
20.53
$ 13.27
$ 25,500.00
792
sf
$
8.00
$
5.00
$
3.00
$
16.00
1140.74
cy
500.00
175.00
675.00
1140.74
cy
$
13.00
7.53
20.53
322.53
cy
46.60
$
28.56
11.85
87.01
818.21
1140.74
cy_
cy
$
$
8.00
$ 28.56
$ 13.00
11.85
7.53
48.41
20.53
1650.00
$
9.70
$
2.91
$
0.66
$
13.27
ea
$ 12,000.00
$ 7,500.00
$ 6,000.00
$ 25,500.00
4400
sf
$
8.00
$
5.00
$
3.00
$
16.00
755.56
cy
$
500.00
$ 175.00
675.00
755.56
224.00
cy_
cy
$
$
46.60
$ 13.00
$ 28.56
7.53
11.85
20.53
87.01
531.56
cy
$
8.00
$
28.56
$
11.85
$
48.41
755.56
cy
$
$
13.00
$
7.53
$
20.53
1360.00
6
ea
$ 9.70
$ 12,000.00
$ 2.91
$ 7,500.00
$ 0.66
$ 6,000.00
$ 13.27
$ 25,500.00
3627
sf
$
8.00
$
5.00
$
3.00
$
16.00
607.10
cy
500.00
175.00
675.00
607.10
cy
13.00
7.53
20.53
195.00
cy
46.60
28.56
11.85
87.01
412.10
607.10
875.00
cy_
cy
$
$
8.00
9.70
28.56
13.00
2.91
11.85
7.53
0.66
48.41
20.53
13.27
-------
Manhole
5
ea
$ 12,000.00
$ 7,500.00
$ 6,000.00
$ 25,500.00
$ 127,500.00
Temp Trench Patch
2625
sf
$ 8.00
$ 5.00
$ 3.00
$ 16.00
$ 42,000.00
INSTALL PUMP STATION AT PRESCHOOL
Excavation
235
cy
$
$ 500.00
$ 175.00
$ 675.00
$ 158,625.00
Haul Exc Material
235
cy
$
$ 13.00
$ 7.53
$ 20.53
$ 4,824.55
Bedding
23.00
cy
$ 46.60
$ 28.56
$ 11.85
$ 87.01
$ 2,001.23
Backfill
12.00
cy
$ 8.00
$ 28.56
$ 11.85
$ 48.41
$ 580.92
Pump Housing
1.00
ea
$ 8,000.00
$ 6,400.00
$ 3,500.00
$ 17,900.00
$ 17,900.00
Pumps
2.00
ea
$ 900.00
$ 280.00
$ 85.00
$ 1,265.00
$ 2,530.00
Electrical
1.00
Is
$ 3,000.00
$ 7,500.00
$ 1,200.00
$ 11,700.00
$ 11,700.00
LATERAL CONNECTIONS
Trenching (18" cover, no rock)
1157.00
cy
$
$ 23.00
$ 9.60
$ 32.60
$ 37,718.20
Haul Exc Material
1157.00
cy
$
$ 13.00
$ 7.53
$ 20.53
$ 23,753.21
Bedding
694.00
cy
$ 46.60
$ 28.56
$ 11.85
$ 87.01
$ 60,384.94
Backfill
463.00
cy
$ 8.00
$ 28.56
$ 11.85
$ 48.41
$ 22,413.83
Haul to Job Site
694.00
cy
$
$ 13.00
$ 7.53
$ 20.53
$ 14,247.82
4" Lateral, house to street
8325
If
$ 5.62
$ 75.00
$ 2.00
$ 82.62
$ 687,811.50
Connect 6" Laterals
111
ea
$ 1,800.00
$ 2,000.00
$ 200.00
$ 4,000.00
$ 444,000.00
SITE RESTORATION
Remove Temp Trench Patch
23717.5
sf
$
$ 2.50
$ 1.65
$ 4.15
$ 98,427.63
Haul Exc Material
439.21
cy
$
$ 13.00
$ 7.53
$ 20.53
$ 9,017.04
Subbase & Base Course
439.21
cy
$ 50.00
$ 100.00
$ 35.00
$ 185.00
$ 81,254.40
AC Pavement
2635.278
sy
$ 30.00
$ 5.00
$ 3.00
$ 38.00
$ 100,140.56
SUBTOTAL
$ 9,035,588.69
-------
Pahala Wastewater Treatment Plant Preliminary Engineering Report
Appendix C: Wastewater Flow Calculations
Brown AND Caldwell j
C-l
-------
Pahala WWTP Flows 2017 STDS.
Calculated Flows
Design Flows
Status Quo - Envirnomental Loadings
Service Area Summary
Avgerage Daily
Dry Weather Flow
gpd
Peak Wet
Weather Flow
gpd
Average Dry
Weather Flow
gpd
Peak day wet
weather flow
(peaking
factor = 3.5)
gpd
Peak hour
wet weather
flow (peaking
factor = 4.8)
gpm
BODs TSS N P
lbs/year lbs/day lbs/year lbs/day lbs/year lbs/day lbs/year
Persons
Total Area
Dwellings
tots
Com m ents/Assumptions
Existing Condition
45,780
248,183
50,000
175,000
167
45,675
45,675
6,090
1,066
CCH WW STDS 2017
• Without loading of applicable Industrial Lots
• 1 dwelling/RS
• Agricultural lots will have IWS and not contribute
• 2010 census shows population at 1356
Initial Condition
138,165
796,146
140,000
490,000
467
127,890
350
127,890
350
17,052
50
2,984
10 1,564
178
293
177
Initial Buildout
189,130
900,300
190,000
661,955
630
173,565
480
173,565
480
23,142
60
4,050
10
2,007
178
293
177
• With loading of Industrial Lots, assuming 800 gal/acre
Full Buildout
359,380
1,814,258
360,000
1,260,000
1,200
328,860
900
328,860
43,848
7,673
3,699
335
636
*
Assumes that waste characteristics are based on section 43.3,
Vol 2, 0.2LBS/cap-day
Influent BOD5 TSS N P
rrig/i mgfl mgfl mg/l
300 300 40 7
1 i
170818 Pahala WWTP Flows 2017
-------
Pahala WWTP
Initial Flows
Pahala WWTP
Project 150440
Dwelling School
25
Population Initial
w/o industrial 1564
1 dwelling/ RS
****2010 census shows population at 1356
QUANTITY OF WASTEWATER: Per CCH WWTP Stds 1993, chpt20.
AVERAGE DAILY PER CAPITA FLOW:
Average Daily Flow: 80 gal/day/capita
Residential SF occupancy: 4 capita/dwelling
*per Craig assume Residential lots are 1 dwelling/lot ONLY
Apartment MF occupancy: 2.8 capita/dwelling
AVERAGE DAILY PER LAND USE:
Neighborhood Business: 40 capita per acre
General Industry 100 capita per acre - NOT INCLUDED
School: 25 gal/capita/day
Institution: 200 gal/capita/day
Agricultural: assume IWS
LOT
COUNT
Acreage (Tax Acres)
'assumed Neighborhood Business 40 Capita
396016034
396016035
396017001
396015034
396005049
396015032
41395.068
7657.848
16339.356
5140.08
2888.028
44953.92
0.9503
0.1758
0.3751
0.118
0.0663
1.032
Google earth image: lot looks semi developed
with possible farm facility.
^assume neighborhood business
* assumed 1 dwelling per lot
*used RS-10 assumptions, since open defined
by adjacent land use
552123
441698.4
110424.6
17859.6
12.675
10.14
2.535
0.41
ML-20
RS-10
MG-la
*assumed apartment 2.8 per dwelling
396017002
396017003
396017038
88078.32
22899.492
26806.824
2.022
0.5257
0.6154
RM-1.5
RM-1.5
RM-1.5
396005044
21505.572
0.4937
ROAD
396021031
396015033
396014069
396014070
396014071
396014072
396021001
396020031
396020032
396014053
396014054
396014055
396014056
396014057
396014058
396014059
396014060
396014061
396014062
396014063
396014064
396014065
396020033
396020034
396016036
396016039
396016040
396016041
396016042
396016043
12736.944
58021.92
11961.576
13290.156
15002.064
16452.612
13629.924
13673.484
13381.632
14440.14
14440.14
14440.14
13128.984
12462.516
16896.924
12000.78
12000.78
10497.96
10497.96
10497.96
10497.96
10497.96
9822.78
11007.612
17424
13142.052
28775.736
27264.204
27887.112
18700.308
0.2924
1.332
0.2746
0.3051
0.3444
0.3777
0.3129
0.3139
0.3072
0.3315
0.3315
0.3315
0.3014
0.2861
0.3879
0.2755
0.2755
0.241
0.241
0.241
0.241
0.241
0.2255
0.2527
0.4
0.3017
0.6606
0.6259
0.6402
0.4293
RS-10
RS-10
RS-10
RS-10
RS-10
RS-10
RS-10
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
Dry l/l Wet l/l
£ 4350
2017 WW OS
per Vol 2:
average ww flow rate during
24-hour period
54,740 138,165
is the highest ir
wastewater flow rate during
prolonged period of wet weather
532,843 796,146
Max Flow Factor
Design Ave Flow (god)
(avg WW flow + dry i/i)
Average dry weather fli
Design Peak Flow (gpd)
(max WW flow + dry i/i + wet i/i)
Peak Wet weather flow
1225 245 735 527.4 1997.4
2625 525 1575 1125.3 4275.3
0 0 0 354 354
0 0 0 198.9 198.9
0 0 0 3096 3096
38025 38025
30420 31260
7605 8445
1230 1230
1.1550 2.5 28875 5775 17325 6066 40716
2940 2.5 7350 1470 4410 1577.1 10397.1
3500 2.5 8750 1750 5250 1846.2 12346.2
877.2 1717.2
3996 4836
823.8 1663.8
915.3 1755.3
1033.2 1873.2
1133.1 1973.1
938.7 1778.7
941.7 1781.7
921.6 1761.6
994.5 1834.5
994.5 1834.5
994.5 1834.5
904.2 1744.2
858.3 1698.3
1163.7 2003.7
826.5 1666.5
826.5 1666.5
723 1563
723 1563
723 1563
723 1563
723 1563
676.5 1516.5
758.1 1598.1
1200 2040
905.1 1745.1
1981.8 2821.8
1877.7 2717.7
1920.6 2760.6
1287.9 2127.9
-------
2115.
1919.
1596.
1626
1441.
1815.
1903.
1703.
3090.
1510.
1517.
1389.
1497.
1521.
1521.
2764.
1671
1879.
1338.
2540.
1868.
1721.
1557.
1740
1609.
1722
1579.
1871.
1980.
1896.
2213.
1969.
1110;
5843.9
5843.9
90070.
10007.
90070.
1814.
1572.
1988.
1885.
1721.
1686
1796.
1653
1682.
1563
1718.
1571.
1521
1652.
1698.
1744.
1834.
1834.
1761.
0
13723C
19321
1317.
1335
1336.
1335.
1327.
1341.
1333.
1359.
1374.
1379.
1369.
1372.
1756.
1622.
1666.
1582.
396016044
396016045
396016046
396015018
396015019
396015020
396015021
396015022
396016011
396015011
396015012
396015013
396015014
396015015
396015016
396015009
396015005
396015006
396015007
396015008
396020058
396015017
396020030
396015003
396015004
396020056
396020057
396016023
396016024
396016025
396016026
396016027
396002056
18526.068
15672.888
10990.188
11412.72
8738.136
14170.068
15437.664
12540.924
32683.068
9740.016
9835.848
7984.548
9543.996
9892.476
9892.476
27943.74
12066.12
15089.184
7239.672
24685.452
14936.724
12802.284
10419.552
13068
11173.14
12806.64
10737.54
14971.572
16565.868
15341.832
19946.124
16404.696
149018.76
0.4253
0.3598
0.2523
0.262
0.2006
0.3253
0.3544
0.2879
0.7503
0.2236
0.2258
0.1833
0.2191
0.2271
0.2271
0.6415
0.277
0.3464
0.1662
0.5667
0.3429
0.2939
0.2392
0.3
0.2565
0.294
0.2465
0.3437
0.3803
0.3522
0.4579
0.3766
3.421
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
1275.9
1079.4
756.9
786
601.8
975.9
1063.2
863.7
2250.9
670.8
677.4
549.9
657.3
681.3
681.3
1924.5
831
1039.2
498.6
1700.1
1028.7
739.5
1031.1
1140.9
1056.6
1373.7
1129.8
10263
72656.991
72656.991
1.667975
1.667975
Multiple
RS-10
RS-15
5003.925
5003.925
145313.982
1307825.838
3.33595
30.02355
A-20a
MG-la
10007.85
90070.65
396015023
396015024
396015025
396015026
396015027
396015028
396015029
396015030
396015031
396014066
396014067
396015001
396015002
396015010
396014048
396014049
396014050
396014051
396014052
14143.932
10641.708
16679.124
15180.66
12802.284
12283.92
13886.928
11804.76
12236.004
10497.96
12754.368
10619.928
11800.404
12462.516
13128.984
14440.14
14440.14
13385.988
0.3247
0.2443
0.3829
0.3485
0.2939
0.282
0.3188
0.271
0.2809
0.241
0.2928
0.2438
0.227
0.2709
0.2861
0.3014
0.3315
0.3315
0.3073
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
RS-15
974.1
732.9
1148.7
1045.5
858.3
904.2
994.5
994.5
921.9
0
396014020
396014021
396014022
396014023
396014024
396014025
396014026
396014002
396014003
396014004
396014005
396014006
396018001
396018002
396018003
396018004
6930.396
7187.4
7204.824
7196.112
7082.856
7287.588
7169.976
7540.236
7758.036
7832.088
7683.984
7727.544
13303.224
11356.092
11996.424
10785.456
0.1591
0.165
0.1654
0.1652
0.1626
0.1673
0.1646
0.1731
0.1781
0.1798
0.1764
0.1774
0.3054
0.2607
0.2754
0.2476
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
477.3
495
496.2
495.6
487.8
501.9
493.8
519.3
534.3
539.4
529.2
532.2
916.2
782.1
826.2
742.8
-------
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1
2
3
4
5
6
7
8
9
10
11
11
12
13
14
15
16
17
18
19
20
21
Pa ha la WWTP
Initial Buildout Flows
Paha la WWTP
WW per capita (gpd)
Population Initial
w/industrial @ 40capita/ac
1 dwelling/RS
Dry l/l
Wet l/l
Above GWT (gpcd) / (gad)
QUANTITY OF WASTEWATER: Per CCH WWTP Stds 1393, chpt 20.
AVERAGE DAILY PER CAPITA FLOW:
Average Daily Flow: 80 gal/day/capita
Residential SF occupancy: 4 capita/dwelling
Apartment MF occupancy: 2.8 capita/dwelling
Small and Decentralized WW
Management Systems, Crites
page 170, Commerical Areas of
Unknown Use: 800 gal/acre
Table 4-3, Hospital, bed : 165 gcd,
employee: 10 gcd
AVERAGE DAILY PER LAND USE:
Neighborhood Business: 40 capita per acre
School: 25 gal/capita/day
Agricultural: assume IWS
per Vol 2:
average ww flow rate
ring 24-hour period
178
293
2,007
118,885
297,212
70,245
189,130
Design Avg Flow (gpd)
(avg WW flow + dry
i/i)
notes
TMK
Area (soft)
Acreage (Tax Acres)
LUO
Dwellings
Capita
Avg Flow (gcd)
Max Flow Factor
Max Flow (gpd)
Dry l/l (KPd)
aka
Average dry weather
flow
*assumed Neighborhood
Business 40 Capita per acre
396016034
41395.068
0.9503
CV-10
38
2660
2.5
6650
1330
3990
396016035
7657.848
0.1758
CV-10
7
490
2.5
1225
245
735
396017001
16339.356
0.3751
CV-7.5
15
1050
2.5
2625
525
1575
396015034
5140.08
0.118
ML-20
1
94.4
2.5
236
35
129.4
396005049
2888.028
0.0663
ML-20
1
53.04
2.5
132.6
35
88.04
396015032
44953.92
1.032
ML-20
10
825.6
0
2.5
2.5
2064
0
350
0
1175.6
0
Google earth image: lot looks
semi developed with possible
396005036
1104246
25.35
farm facility.
552123
12.675
ML-20
127
10140
2.5
25350
4445
14585
*assumed 1 dwelling per lot
441698.4
10.14
RS-10 1
4
280
2.5
700
140
420
*used RS-10 assumptions,
since open defined by
110424.6
2.535
Open 1
4
280
2.5
700
140
420
adjacent land use
396002024
17859.6
0.41
MG-la
4
328
2.5
820
140
468
*assumed apartment 2.8 per
dwelling
396017002
88078.32
2.022
RM-1.5 59
165
11550
2.5
28875
5775
17325
396017003
22899.492
0.5257
RM-1.5 15
42
2940
2.5
7350
1470
4410
396017038
26806.824
0.6154
RM-1.5 18
50
3500
2.5
8750
1750
5250
396005044
21505.572
0.4937
ROAD
396021031
12736.944
0.2924
RS-10 1
4
280
2.5
700
140
420
396015033
58021.92
1.332
RS-10 1
4
280
2.5
700
140
420
396014069
11961.576
0.2746
RS-10 1
4
280
2.5
700
140
420
396014070
13290.156
0.3051
RS-10 1
4
280
2.5
700
140
420
396014071
15002.064
0.3444
RS-10 1
4
280
2.5
700
140
420
396014072
16452.612
0.3777
RS-10 1
4
280
2.5
700
140
420
396021001
13629.924
0.3129
RS-10 1
4
280
2.5
700
140
420
396020031
13673.484
0.3139
RS-15 1
4
280
2.5
700
140
420
396020032
13381.632
0.3072
RS-15 1
4
280
2.5
700
140
420
396014053
14440.14
0.3315
RS-15 1
4
280
2.5
700
140
420
Initial Buildout WWTP flow
-------
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1698.
1744.
1834.
1834.
1761.
0
13723C
19321
1317.
1335
1336.
1335.
1327.
1341.
1333.
1359.
1374.
1379.
1369.
1372.
1756.
1622.
1666.
1582.
1821
1702.
1354.
1333.
1341.
1345.
1332.
1327.
1324.
1312.
1314.
1328.
1342.
1342.
1337.
1337.
1339.
144S
1510.
1583.
1502.
1504.
1304.
1288.
1322.
1289.
133S
1349.
1338.
1343.
1329.
1362.
1379.
1377.
1379.
1377.
1384.
1590.
1486.
1514.
1411.
1764.
1322.
1308.
1308.
12462.516
13128.984
14440.14
14440.14
13385.988
0.2861
0.3014
0.3315
0.3315
0.3073
280
280
280
280
280
700
700
700
700
700
140
140
140
140
140
420
420
420
420
420
1172896.56
6930.396
7187.4
7204.824
7196.112
7082.856
7287.588
7169.976
7540.236
7758.036
7832.088
7683.984
7727.544
13303.224
11356.092
11996.424
10785.456
14244.12
12519.144
7466.184
7161.264
7287.588
7335.504
7148.196
7082.856
7034.94
6865.056
6886.836
7087.212
7291.944
7291.944
7222.248
7222.248
7257.096
8842.68
9740.016
10794.168
9618.048
9648.54
6747.444
6512.22
7008.804
6529.644
7230.96
7400.844
7235.316
7305.012
7113.348
7583.796
7832.088
7801.596
7832.088
7801.596
7901.784
10903.068
9382.824
9792.288
8302.536
13429.548
7008.804
6799.716
6808.428
0.1591
0.165
0.1654
0.1652
0.1626
0.1673
0.1646
0.1731
0.1781
0.1798
0.1764
0.1774
0.3054
0.2607
0.2754
0.2476
0.327
0.2874
0.1714
0.1644
0.1673
0.1684
0.1641
0.1626
0.1615
0.1576
0.1581
0.1627
0.1674
0.1674
0.1658
0.1658
0.1666
0.203
0.2236
0.2478
0.2208
0.2215
0.1549
0.1495
0.1609
0.1499
0.166
0.1699
0.1661
0.1677
0.1633
0.1741
0.1798
0.1791
0.1798
0.1791
0.1814
0.2503
0.2154
0.2248
0.1906
0.3083
0.1609
0.1561
0.1563
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
Initial Buildout WWTPflow
-------
-------
Pahala WWTP
Full Buildout Flows
Pahala WWTP
Project 150440
Dwelling
capita (gpd)
Population Initial
Population Full
w/industrial @ 40capita/ac
1 dwelling/RS
2007
3699
QUANTITY OF WASTEWATER: Per CCH WWTP Stds 1993, chpt 20.
AVERAGE DAILY PER CAPITA FLOW:
Average Daily Flow: 80 gal/day/capita
Residential SF occupancy: 4 capita/dwelling
Apartment MF occupancy: 2.8 capita/dwelling
AVERAGE DAILY PER LAND USE:
Neighborhood Business: 40 capita per acre
General Industry 100 capita per acre
School: 25 gal/capita/day
Institution: 200 gal/capita/day
Small and Decentralized WW
Management Systems, Crites
page 170, Commerical Areas of Unknown
Use: 800 gal/acre
Table 4-3, Hospital, bed : 240 gcd,
employee: 15 gcd
335 636
3,699
LOT
COUNT
Acreage (Tax Acres)
396002044
396002043
396023035
658670.76
195845.76
90879.228
15.121
4.496
2.0863
A-la
A-la
A-la
972433.44
486216.72
486216.72
22.324
11.162
11.162
Multiple
A-20a
RS-10
umed Neighborhood
less 40 Capita per acre
396016033
396016037
396016038
396016032
396016003
396017006
396017007
396017008
396017009
23513.688
17267.184
14300.748
32665.644
30605.256
10114.632
9809.712
9483.012
9705.168
0.5398
0.3964
0.3283
0.7499
0.7026
0.2322
0.2252
0.2177
0.2228
CV-10
CV-10
CV-10
CV-10
CV-10
CV-7.5
CV-7.5
CV-7.5
CV-7.5
396017036
396017037
14779.908
62491.176
0.3393
1.4346
RM-1.5
RM-1.5
*Obtain Ka'u Hospital Patient
and Staff Info
396023019
396023020
396023021
11338.668
15272.136
11377.872
0.2603
0.3506
0.2612
RS-10
RS-10
RS-10
396021009
396021011
396021022
11721.996
16496.172
11282.04
0.2691
0.3787
0.259
RS-10
RS-10
RS-10
Full Flow WWTP flow
Above GWT (gpcd) / (god)
2017 WWDS
Dry l/l
&
35
Wet l/l
3000
229,915
574,787
per Vol 2:
average ww flow rate
during 24-hour period
129,465 359,380
1,110,006
is the highest
instantaneous
wastewater flow rate
during prolonged
period of wet weather
1,814,258
Max Flow Factor
Dry l/l (gpd)
Design Ave Flow (gpd)
(avg WW flow + dry i/i)
aka
Average dry weather
flow
Wet l/l (gpd)
Design Peak Flow
(gpd)
(max WW flow + dry
i/l + wet i/i)
aka
Peak Wet weather
flow
45363
13488
6258.9
45363
13488
6258.9
66972
33486
33486
66972
33486
34326
1540
1120
910
2100
1960
630
630
630
630
3850
2800
2275
5250
4900
1575
1575
1575
1575
0
560
455
1050
980
315
315
315
315
2310
1680
1365
3150
2940
945
945
945
945
0
1619.4
1189.2
984.9
2249.7
2107.8
696.6
675.6
653.1
668.4
0
6239.4
4549.2
3714.9
8549.7
7987.8
2586.6
2565.6
2543.1
2558.4
0
1960
8260
4900
20650
2940
12390
1017.9
4303.8
6897.9
29083.8
280
280
280
700
700
700
140
140
140
420
420
420
780.9
1051.8
783.6
1620.9
1891.8
1623.6
3180
280
280
280
7950
700
700
700
7420
140
140
140
10600
420
420
420
807.3
1136.1
777
15370
1647.3
1976.1
1617
1 OF 8
-------
25
396021023
11299.464
0.2594
RS-10
1
4
280
2.5
700
140
420
778.2
1618.2
26
396023022
10005.732
0.2297
RS-10
1
4
280
2.5
700
140
420
689.1
1529.1
27
396023023
10502.316
0.2411
RS-10
1
4
280
2.5
700
140
420
723.3
1563.3
28
396023024
12148.884
0.2789
RS-10
1
4
280
2.5
700
140
420
836.7
1676.7
29
396023025
12493.008
0.2868
RS-10
1
4
280
2.5
700
140
420
860.4
1700.4
30
396023026
12418.956
0.2851
RS-10
1
4
280
2.5
700
140
420
855.3
1695.3
31
396023027
13063.644
0.2999
RS-10
1
4
280
2.5
700
140
420
899.7
1739.7
32
396023028
11112.156
0.2551
RS-10
1
4
280
2.5
700
140
420
765.3
1605.3
33
396023029
11020.68
0.253
RS-10
1
4
280
2.5
700
140
420
759
1599
34
396023030
10532.808
0.2418
RS-10
1
4
280
2.5
700
140
420
725.4
1565.4
35
396023031
10532.808
0.2418
RS-10
1
4
280
2.5
700
140
420
725.4
1565.4
36
396023032
15324.408
0.3518
RS-10
1
4
280
2.5
700
140
420
1055.4
1895.4
37
396021010
12645.468
0.2903
RS-10
1
4
280
2.5
700
140
420
870.9
1710.9
38
*Can be subdivided in the
future
396023044
227339.64
5.219
RS-10
1
4
280
2.5
700
140
420
15657
16497
39
396021030
10798.524
0.2479
RS-10
1
4
280
2.5
700
140
420
743.7
1583.7
41
396023001
10384.704
0.2384
RS-10
1
4
280
2.5
700
140
420
715.2
1555.2
42
396023002
10005.732
0.2297
RS-10
1
4
280
2.5
700
140
420
689.1
1529.1
43
396023003
10005.732
0.2297
RS-10
1
4
280
2.5
700
140
420
689.1
1529.1
44
396023004
10005.732
0.2297
RS-10
1
4
280
2.5
700
140
420
689.1
1529.1
45
396023005
10005.732
0.2297
RS-10
1
4
280
2.5
700
140
420
689.1
1529.1
46
396023006
10005.732
0.2297
RS-10
1
4
280
2.5
700
140
420
689.1
1529.1
47
396021024
10389.06
0.2385
RS-10
1
4
280
2.5
700
140
420
715.5
1555.5
48
396021025
10389.06
0.2385
RS-10
1
4
280
2.5
700
140
420
715.5
1555.5
49
396021026
10389.06
0.2385
RS-10
1
4
280
2.5
700
140
420
715.5
1555.5
50
396021027
12824.064
0.2944
RS-10
1
4
280
2.5
700
140
420
883.2
1723.2
51
396021028
10833.372
0.2487
RS-10
1
4
280
2.5
700
140
420
746.1
1586.1
52
396021029
10798.524
0.2479
RS-10
1
4
280
2.5
700
140
420
743.7
1583.7
53
396021012
11769.912
0.2702
RS-10
1
4
280
2.5
700
140
420
810.6
1650.6
54
396021013
11251.548
0.2583
RS-10
1
4
280
2.5
700
140
420
774.9
1614.9
55
396021014
11251.548
0.2583
RS-10
1
4
280
2.5
700
140
420
774.9
1614.9
56
396021015
11251.548
0.2583
RS-10
1
4
280
2.5
700
140
420
774.9
1614.9
57
396021016
11251.548
0.2583
RS-10
1
4
280
2.5
700
140
420
774.9
1614.9
58
396021017
10328.076
0.2371
RS-10
1
4
280
2.5
700
140
420
711.3
1551.3
59
396021018
10328.076
0.2371
RS-10
1
4
280
2.5
700
140
420
711.3
1551.3
60
396021019
10328.076
0.2371
RS-10
1
4
280
2.5
700
140
420
711.3
1551.3
61
396021020
10328.076
0.2371
RS-10
1
4
280
2.5
700
140
420
711.3
1551.3
62
396021021
10341.144
0.2374
RS-10
1
4
280
2.5
700
140
420
712.2
1552.2
63
396021002
12000.78
0.2755
RS-10
1
4
280
2.5
700
140
420
826.5
1666.5
64
396021003
12000.78
0.2755
RS-10
1
4
280
2.5
700
140
420
826.5
1666.5
65
396021004
12083.544
0.2774
RS-10
1
4
280
2.5
700
140
420
832.2
1672.2
66
396021005
14387.868
0.3303
RS-10
1
4
280
2.5
700
140
420
990.9
1830.9
67
396021006
12423.312
0.2852
RS-10
1
4
280
2.5
700
140
420
855.6
1695.6
68
396021007
12519.144
0.2874
RS-10
1
4
280
2.5
700
140
420
862.2
1702.2
69
396021008
11600.028
0.2663
RS-10
1
4
280
2.5
700
140
420
798.9
1638.9
70
~Church
396023045
100632.312
2.3102
RS-10
1
4
280
2.5
700
140
420
6930.6
7770.6
71
396023007
10001.376
0.2296
RS-10
1
4
280
2.5
700
140
420
688.8
1528.8
72
396023008
10001.376
0.2296
RS-10
1
4
280
2.5
700
140
420
688.8
1528.8
73
396023009
10328.076
0.2371
RS-10
1
4
280
2.5
700
140
420
711.3
1551.3
74
396023010
10367.28
0.238
RS-10
1
4
280
2.5
700
140
420
714
1554
75
396023011
10001.376
0.2296
RS-10
1
4
280
2.5
700
140
420
688.8
1528.8
76
396023012
10001.376
0.2296
RS-10
1
4
280
2.5
700
140
420
688.8
1528.8
77
396023013
10166.904
0.2334
RS-10
1
4
280
2.5
700
140
420
700.2
1540.2
78
396023014
10206.108
0.2343
RS-10
1
4
280
2.5
700
140
420
702.9
1542.9
79
396023015
10933.56
0.251
RS-10
1
4
280
2.5
700
140
420
753
1593
80
396023016
11586.96
0.266
RS-10
1
4
280
2.5
700
140
420
798
1638
81
396023017
13220.46
0.3035
RS-10
1
4
280
2.5
700
140
420
910.5
1750.5
82
396023018
10097.208
0.2318
RS-10
1
4
280
2.5
2.5
700
0
140
0
420
0
695.4
0
1535.4
0
83
396023034
572779.152
13.1492
Multiple
0
2.5
0
0
0
39447.6
39447.6
286389.576
6.5746
RS-10
1
4
280
2.5
700
140
420
19723.8
20563.8
286389.576
6.5746
A-la
0
0
2.5
2.5
0
0
0
0
0
0
19723.8
0
19723.8
0
84
396020035
12858.912
0.2952
RS-15
1
4
280
2.5
700
140
420
885.6
1725.6
85
396020036
13320.648
0.3058
RS-15
1
4
280
2.5
700
140
420
917.4
1757.4
86
396020037
10123.344
0.2324
RS-15
1
4
280
2.5
700
140
420
697.2
1537.2
87
396020038
10123.344
0.2324
RS-15
1
4
280
2.5
700
140
420
697.2
1537.2
88
396020039
10123.344
0.2324
RS-15
1
4
280
2.5
700
140
420
697.2
1537.2
89
396020040
10123.344
0.2324
RS-15
1
4
280
2.5
700
140
420
697.2
1537.2
90
396020041
10123.344
0.2324
RS-15
1
4
280
2.5
700
140
420
697.2
1537.2
91
396020042
9905.544
0.2274
RS-15
1
4
280
2.5
700
140
420
682.2
1522.2
92
396020043
13538.448
0.3108
RS-15
1
4
280
2.5
700
140
420
932.4
1772.4
Full Flow WWTP flow
2 OF 8
-------
93 396019012
94 396019013
95 396019014
96 396019015
97 396019016
98 396019017
99 396016005
100 396016006
101 396016007
102 396016008
103 396016009
104 396016010
105 396019001
106 396019002
107 396019003
108 396019004
109 396019005
110 396019006
111 396020044
112 396020045
113 396020046
114 396020047
115 396020048
116 396020049
117 396019007
118 396019008
119 396019009
120 396019010
121 396019011
122 396016031
123 396020050
124 396020051
125 396016004
126 396023036
127 396023037
128 396023038
129 396023039
130 396023040
131 396023041
132 396023042
133 396019018
134 396019019
135 396019020
136 396019021
137 396019022
138 396016029
139 396016030
140 396016002
141 396020059
142 396020060
143 396020061
144 396016001
145 396016012
146 396016013
147 396016014
148 396016015
149 396016016
150 396020055
151 396016017
152 396016018
153 396016019
154 396016020
155 396016022
156 396016028
157 396020062
158 396020063
159 396020064
160 396020065
161 396020066
162 396020052
163 396020053
164 396020054
11848.32 0.272 RS-15
11922.372 0.2737 RS-15
11970.288 0.2748 RS-15
12305.7 0.2825 RS-15
12493.008 0.2868 RS-15
12519.144 0.2874 RS-15
20399.148 0.4683 RS-15
17402.22 0.3995 RS-15
13477.464 0.3094 RS-15
14644.872 0.3362 RS-15
11613.096 0.2666 RS-15
12357.972 0.2837 RS-15
15912.468 0.3653 RS-15
17484.984 0.4014 RS-15
17698.428 0.4063 RS-15
13359.852 0.3067 RS-15
11190.564 0.2569 RS-15
11190.564 0.2569 RS-15
15672.888 0.3598 RS-15
15141.456 0.3476 RS-15
13294.512 0.3052 RS-15
10271.448 0.2358 RS-15
9983.952 0.2292 RS-15
10497.96 0.241 RS-15
19780.596 0.4541 RS-15
16605.072 0.3812 RS-15
14653.584 0.3364 RS-15
13150.764 0.3019 RS-15
12501.72 0.287 RS-15
11752.488 0.2698 RS-15
11356.092 0.2607 RS-15
11486.772 0.2637 RS-15
57412.08 1.318 RS-15
17302.032 0.3972 RS-15
15002.064 0.3444 RS-15
15002.064 0.3444 RS-15
15002.064 0.3444 RS-15
15002.064 0.3444 RS-15
14740.704 0.3384 RS-15
18138.384 0.4164 RS-15
12532.212 0.2877 RS-15
11251.548 0.2583 RS-15
11251.548 0.2583 RS-15
11251.548 0.2583 RS-15
11308.176 0.2596 RS-15
11774.268 0.2703 RS-15
11721.996 0.2691 RS-15
12614.976 0.2896 RS-15
12928.608 0.2968 RS-15
12532.212 0.2877 RS-15
12135.816 0.2786 RS-15
12445.092 0.2857 RS-15
11268.972 0.2587 RS-15
18508.644 0.4249 RS-15
14932.368 0.3428 RS-15
15559.632 0.3572 RS-15
15681.6 0.36 RS-15
12026.916 0.2761 RS-15
13381.632 0.3072 RS-15
12161.952 0.2792 RS-15
10402.128 0.2388 RS-15
9866.34 0.2265 RS-15
11077.308 0.2543 RS-15
13817.232 0.3172 RS-15
11421.432 0.2622 RS-15
11586.96 0.266 RS-15
10728.828 0.2463 RS-15
10240.956 0.2351 RS-15
10445.688 0.2398 RS-15
11621.808 0.2668 RS-15
11756.844 0.2699 RS-15
11891.88 0.273 RS-15
Full Flow WWTP flow
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
816
821.1
824.4
847.5
860.4
862.2
1404.9
1198.5
928.2
1008.6
799.8
851.1
1095.9
1204.2
1218.9
920.1
770.7
770.7
1079.4
1042.8
915.6
707.4
687.6
723
1362.3
1143.6
1009.2
905.7
861
809.4
782.1
791.1
3954
1191.6
1033.2
1033.2
1033.2
1033.2
1015.2
1249.2
863.1
774.9
774.9
774.9
778.8
810.9
807.3
868.8
890.4
863.1
835.8
857.1
776.1
1274.7
1028.4
1071.6
1080
828.3
921.6
837.6
716.4
679.5
762.9
951.6
786.6
798
738.9
705.3
719.4
800.4
1656
1661.1
1664.4
1687.5
1700.4
1702.2
2244.9
2038.5
1768.2
1848.6
1639.8
1691.1
1935.9
2044.2
2058.9
1760.1
1610.7
1610.7
1919.4
1882.8
1755.6
1547.4
1527.6
1563
2202.3
1983.6
1849.2
1745.7
1701
1649.4
1622.1
1631.1
4794
2031.6
1873.2
1873.2
1873.2
1873.2
1855.2
2089.2
1703.1
1614.9
1614.9
1614.9
1618.8
1650.9
1647.3
1708.8
1730.4
1703.1
1675.8
1697.1
1616.1
2114.7
1868.4
1911.6
1920
1668.3
1761.6
1677.6
1556.4
1519.5
1602.9
1791.6
1626.6
1638
1578.9
1545.3
1559.4
1640.4
1649.7
1659
3 OF 8
-------
200
201
202
203
204
205
206
207
208
209
210
211
212
213
214
215
216
217
218
219
220
221
222
223
224
225
226
227
228
229
230
231
232
233
234
235
236
396005059
396022031
396018043
396018044
396022012
396022013
396018052
396018053
396018054
396018059
396018060
396022021
396022022
396022023
396018046
396018047
396018048
396018049
396022014
396017040
396017041
396017042
396017043
396017044
396017045
396017046
396018009
396018011
396018012
396018013
396018014
396018015
396018016
396018017
396018018
396018019
396018020
396018021
396018022
396018023
396018024
396018025
396018026
396018027
396018030
396018031
396018032
396018033
396022045
396017031
396017032
396017026
396017027
396017028
396017029
396017030
396022016
396022017
396022018
396022019
396022020
396022038
396022039
396018055
396018056
396018057
396018058
396022010
396022015
396017033
396017034
396017035
1698.84
9604.98
10680.912
9740.016
10232.244
9522.216
12070.476
12484.296
13098.492
12292.632
435.6
9600.624
10053.648
8877.528
8999.496
8999.496
10315.008
10615.572
8999.496
9600.624
9600.624
9513.504
9535.284
9186.804
19758.816
10663.488
32155.992
10323.72
9779.22
8999.496
8999.496
8999.496
8999.496
8999.496
10598.148
11194.92
11029.392
10545.876
10850.796
11482.416
10724.472
10014.444
10088.496
11290.752
9870.696
11068.596
12166.308
9025.632
10380.348
13677.84
14370.444
8999.496
8999.496
8999.496
9726.948
10550.232
8999.496
8999.496
9600.624
9600.624
9600.624
8999.496
8999.496
10829.016
9622.404
9718.236
13229.172
9021.276
8999.496
9587.556
9600.624
12140.172
0.039
0.2205
0.2452
0.2236
0.2349
0.2186
0.2771
0.2866
0.3007
0.2822
0.01
0.2204
0.2308
0.2038
0.2066
0.2066
0.2368
0.2437
0.2066
0.2204
0.2204
0.2184
0.2189
0.2109
0.4536
0.2448
0.7382
0.237
0.2245
0.2066
0.2066
0.2066
0.2066
0.2066
0.2433
0.257
0.2532
0.2421
0.2491
0.2636
0.2462
0.2299
0.2316
0.2592
0.2266
0.2541
0.2793
0.2072
0.2383
0.314
0.3299
0.2066
0.2066
0.2066
0.2233
0.2422
0.2066
0.2066
0.2204
0.2204
0.2204
0.2066
0.2066
0.2486
0.2209
0.2231
0.3037
0.2071
0.2066
0.2201
0.2204
0.2787
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
Full Flow WWTP flow
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
117
661.5
735.6
670.8
704.7
655.8
831.3
859.8
902.1
846.6
30
661.2
692.4
611.4
619.8
619.8
710.4
731.1
619.8
661.2
661.2
655.2
656.7
632.7
1360.8
734.4
2214.6
711
673.5
619.8
619.8
619.8
619.8
619.8
729.9
771
759.6
726.3
747.3
790.8
738.6
777.6
679.8
762.3
837.9
621.6
714.9
942
989.7
619.8
619.8
619.8
669.9
726.6
619.8
619.8
661.2
661.2
661.2
619.8
619.8
745.8
662.7
669.3
911.1
621.3
619.8
660.3
661.2
836.1
957
1501.5
1575.6
1510.8
1544.7
1495.8
1671.3
1699.8
1742.1
1686.6
870
1501.2
1532.4
1451.4
1459.8
1459.8
1550.4
1571.1
1459.8
1501.2
1501.2
1495.2
1496.7
1472.7
2200.8
1574.4
3054.6
1551
1513.5
1459.8
1459.8
1459.8
1459.8
1459.8
1569.9
1611
1599.6
1566.3
1587.3
1630.8
1578.6
1529.7
1534.8
1617.6
1519.8
1602.3
1677.9
1461.6
1554.9
1782
1829.7
1459.8
1459.8
1459.8
1509.9
1566.6
1459.8
1459.8
1501.2
1501.2
1501.2
1459.8
1459.8
1585.8
1502.7
1509.3
1751.1
1461.3
1459.8
1500.3
1501.2
1676.1
4 OF 8
-------
237
238
239
240
241
242
243
244
245
246
247
248
249
250
251
252
253
254
255
256
257
258
259
260
261
262
263
264
265
266
267
268
269
270
271
272
273
274
275
276
277
278
279
280
281
282
283
284
285
286
287
288
289
290
291
292
293
294
295
296
297
298
299
300
301
302
303
304
305
306
307
308
396017039
396018034
396018035
396018036
396018037
396018038
396018039
396018040
396018041
396005058
396005046
396018042
396022011
396022030
396018045
396022049
396022050
396022051
396022052
396022053
396022054
396022055
396022056
396022057
396022024
396022025
396022026
396022027
396022028
396022029
396022032
396022048
396005045
396022035
396022036
396022037
396018050
396018051
396022040
396022041
396022042
396022043
396022044
396022046
396022047
396022033
396022034
396017010
396017011
396017012
396017019
396017020
396017021
396017022
396017023
396017024
396017025
396022001
396022002
396022003
396022004
396022005
396022006
396022007
396022008
396022009
396017013
396017014
396017015
396017016
396017017
396017018
10384.704
9713.88
9273.924
9404.604
11186.208
12188.088
12641.112
12540.924
12236.004
50355.36
37200.24
11299.464
9021.276
9239.076
9517.86
11726.352
16422.12
16504.884
13943.556
14035.032
12188.088
10323.72
10423.908
6912.972
9239.076
9239.076
9239.076
9239.076
9239.076
9239.076
9426.384
10432.62
134426.16
8999.496
8999.496
8999.496
12074.832
11761.2
9840.204
9456.876
12135.816
11482.416
9774.864
13634.28
12819.708
8999.496
8999.496
11983.356
11730.708
11125.224
12270.852
13385.988
15537.852
21740.796
19031.364
13011.372
9901.188
10598.148
12667.248
10023.156
10606.86
9374.112
8999.496
8999.496
9021.276
9021.276
10450.044
10097.208
10066.716
10358.568
10972.764
12693.384
0.2384
0.223
0.2129
0.2159
0.2568
0.2798
0.2902
0.2879
0.2809
1.156
0.854
0.2594
0.2071
0.2121
0.2185
0.2692
0.377
0.3789
0.3201
0.3222
0.2798
0.237
0.2393
0.1587
0.2121
0.2121
0.2121
0.2121
0.2121
0.2121
0.2164
0.2395
3.086
0.2066
0.2066
0.2066
0.2772
0.27
0.2259
0.2171
0.2786
0.2636
0.2244
0.313
0.2943
0.2066
0.2066
0.2751
0.2693
0.2554
0.2817
0.3073
0.3567
0.4991
0.4369
0.2987
0.2273
0.2433
0.2908
0.2301
0.2435
0.2152
0.2066
0.2066
0.2071
0.2071
0.2399
0.2318
0.2311
0.2378
0.2519
0.2914
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
RS-7.5
Full Flow WWTP flow
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
715.2
669
638.7
647.7
770.4
839.4
870.6
863.7
842.7
3468
2562
778.2
621.3
636.3
655.5
807.6
1131
1136.7
960.3
966.6
839.4
711
717.9
476.1
636.3
636.3
636.3
636.3
636.3
636.3
649.2
718.5
9258
619.8
619.8
619.8
831.6
810
677.7
651.3
835.8
790.8
673.2
939
882.9
619.8
619.8
825.3
807.9
766.2
845.1
921.9
1070.1
1497.3
1310.7
896.1
681.9
729.9
872.4
690.3
730.5
645.6
619.8
619.8
621.3
621.3
719.7
695.4
693.3
713.4
755.7
874.2
1555.2
1509
1478.7
1487.7
1610.4
1679.4
1710.6
1703.7
1682.7
4308
3402
1618.2
1461.3
1476.3
1495.5
1647.6
1971
1976.7
1800.3
1806.6
1679.4
1551
1557.9
1316.1
1476.3
1476.3
1476.3
1476.3
1476.3
1476.3
1489.2
1558.5
10098
1459.8
1459.8
1459.8
1671.6
1650
1517.7
1491.3
1675.8
1630.8
1513.2
1779
1722.9
1459.8
1459.8
1665.3
1647.9
1606.2
1685.1
1761.9
1910.1
2337.3
2150.7
1736.1
1521.9
1569.9
1712.4
1530.3
1570.5
1485.6
1459.8
1459.8
1461.3
1461.3
1559.7
1535.4
1533.3
1553.4
1595.7
1714.2
5 OF 8
-------
*assumed Neighborhood
310 Business 40 Capita per acre
311
312
313
314
315
316
>ks
semi developed with possible
farm facility.
*assumed 1 dwelling per lot
*used RS-10 assumptions,
since open defined by adjacer
319 dw
320
>umed apartment 2.8 per
396016034
396016035
396017001
396015034
396005049
396015032
0
396017002
396017003
396017038
41395.068
7657.848
16339.356
5140.08
2888.028
44953.92
0
1104246
552123
441698.4
110424.6
17859.6
88078.32
22899.492
26806.824
0.9503 CV-10
0.1758 CV-10
0.3751 CV-7.5
0.118 ML-20
0.0663 ML-20
1.032 ML-20
25.35 -
12.675 ML-20
2.535 Open
0.41 MG-la
2.022 RM-1.5
0.5257 RM-1.5
0.6154 RM-1.5
323
324
325
326
327
328
329
330
331
332
333
334
335
336
337
338
339
340
0
396021031
396015033
396014069
396014070
396014071
396014072
396021001
396020031
396020032
396014053
396014054
396014055
396014056
396014057
396014058
396014059
396014060
396014061
396014062
396014063
396014064
396014065
396020033
396020034
396016036
396016039
396016040
396016041
396016042
396016043
396016044
396016045
396016046
396015018
396015019
396015020
396015021
396015022
396016011
396015011
396015012
396015013
396015014
396015015
396015016
0
12736.944
58021.92
11961.576
13290.156
15002.064
16452.612
13629.924
13673.484
13381.632
14440.14
14440.14
14440.14
13128.984
12462.516
16896.924
12000.78
12000.78
10497.96
10497.96
10497.96
10497.96
10497.96
9822.78
11007.612
17424
13142.052
28775.736
27264.204
27887.112
18700.308
18526.068
15672.888
10990.188
11412.72
8738.136
14170.068
15437.664
12540.924
32683.068
9740.016
9835.848
7984.548
9543.996
9892.476
9892.476
0.4937 ROAD
0
0.2924 RS-10
1.332 RS-10
0.2746 RS-10
0.3051 RS-10
0.3444 RS-10
0.3777 RS-10
0.3129 RS-10
0.3139 RS-15
0.3072 RS-15
0.3315 RS-15
0.3315 RS-15
0.3315 RS-15
0.3014 RS-15
0.2861 RS-15
0.3879 RS-15
0.2755 RS-15
0.2755 RS-15
0.241 RS-15
0.241 RS-15
0.241 RS-15
0.241 RS-15
0.241 RS-15
0.2255 RS-15
0.2527 RS-15
0.4 RS-15
0.3017 RS-15
0.6606 RS-15
0.6259 RS-15
0.6402 RS-15
0.4293 RS-15
0.4253 RS-15
0.3598 RS-15
0.2523 RS-15
0.262 RS-15
0.2006 RS-15
0.3253 RS-15
0.3544 RS-15
0.2879 RS-15
0.7503 RS-15
0.2236 RS-15
0.2258 RS-15
0.1833 RS-15
0.2191 RS-15
0.2271 RS-15
0.2271 RS-15
Full Flow WWTP flow
2660
490
1050
94.4
53.04
825.6
0
6650
1225
2625
236
132.6
2064
0
245
525
3990
735
1575
129.4
88.04
1175.6
0
2850.9
527.4
1125.3
354
198.9
3096
0
10830.9
1997.4
4275.3
625
366.5
5510
0
10140
280
25350
700
4445
140
14585
420
38025
30420
67820
31260
280
328
11550
2940
3500
820
28875
7350
8750
140
5775
1470
1750
468
17325
4410
5250
1230
6066
1577.1
1846.2
2190
40716
10397.1
12346.2
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
0
877.2
3996
823.8
915.3
1033.2
1133.1
938.7
941.7
921.6
994.5
994.5
994.5
904.2
858.3
1163.7
826.5
826.5
723
723
723
723
723
676.5
758.1
1200
905.1
1981.8
1877.7
1920.6
1287.9
1275.9
1079.4
756.9
786
601.8
975.9
1063.2
863.7
2250.9
670.8
677.4
549.9
657.3
681.3
681.3
0
1717.2
4836
1663.8
1755.3
1873.2
1973.1
1778.7
1781.7
1761.6
1834.5
1834.5
1834.5
1744.2
1698.3
2003.7
1666.5
1666.5
1563
1563
1563
1563
1563
1516.5
1598.1
2040
1745.1
2821.8
2717.7
2760.6
2127.9
2115.9
1919.4
1596.9
1626
1441.8
1815.9
1903.2
1703.7
3090.9
1510.8
1517.4
1389.9
1497.3
1521.3
1521.3
6 OF 8
-------
368 0
369 0
370 0
371 0
372 0
373 0
374 0
375 0
376 0
377 0
378 0
379 0
380 0
381 0
382 0
383 0
384 0
385 0
0
386 0
0
0
"assume Ag utilizes IWS. No
connection to municipal sewer
0
0
0
387 0
388 0
389 0
390 0
391 0
392 0
393 0
394 0
395 0
396 0
397 0
398 0
399 0
400 0
401 0
402 0
403 0
404 0
405 0
0
'used School Assumptions
based on CH2MHill (502
406 students and 77 staff)
'Park/ball field next to Ka'u
School; assume its contribution
is accounted for in school,
since calculations provided
407 annotate bothTMKs
0
408 0
409 0
410 0
411 0
412 0
413 0
414 0
415 0
416 0
417 0
418 0
419 0
420 0
421 0
422 0
423 0
396015009
396015005
396015006
396015007
396015008
396020058
396015017
396020030
396015003
396015004
396020056
396020057
396016023
396016024
396016025
396016026
396016027
396002056
0
27943.74
12066.12
15089.184
7239.672
24685.452
14936.724
12802.284
10419.552
13068
11173.14
12806.64
10737.54
14971.572
16565.868
15341.832
19946.124
16404.696
149018.76
0
2906279.64
72656.991
72656.991
0.6415 F
0.277 F
0.3464 F
0.1662 F
0.5667 F
0.3429 F
0.2939 F
0.2392 F
0.3 F
0.2565 F
0.294 F
0.2465 F
0.3437 F
0.3803 F
0.3522 F
0.4579 F
0.3766 F
3.421 F
15
0
66.719
1.667975
1.667975
Multiple
RS-10
RS-15
0
396015023
396015024
396015025
396015026
396015027
396015028
396015029
396015030
396015031
396014066
396014067
396015001
396015002
396015010
396014048
396014049
396014050
396014051
396014052
1307825.838
145313.982
1307825.838
0
14143.932
10641.708
16679.124
15180.66
12802.284
12283.92
13886.928
11804.76
12236.004
10497.96
12754.368
10619.928
9888.12
11800.404
12462.516
13128.984
14440.14
14440.14
13385.988
0
0
30.02355 A-la
3.33595 A-20a
30.02355 MG-la
0
0.3247 RS
0.2443 RS
0.3829 RS
0.3485 RS
0.2939 RS
0.282 RS
0.3188 RS
0.271 RS
0.2809 RS
0.241 RS
0.2928 RS
0.2438 RS
0.227 RS
0.2709 RS
0.2861 RS
0.3014 RS
0.3315 RS
0.3315 RS
0.3073 RS
0
396005008 1172896.56
26.926 RS-15
0
396014020
396014021
396014022
396014023
396014024
396014025
396014026
396014002
396014003
396014004
396014005
396014006
396018001
396018002
396018003
396018004
0
6930.396
7187.4
7204.824
7196.112
7082.856
7287.588
7169.976
7540.236
7758.036
7832.088
7683.984
7727.544
13303.224
11356.092
11996.424
10785.456
0
0.1591 RS
0.165 RS
0.1654 RS
0.1652 RS
0.1626 RS
0.1673 RS
0.1646 RS
0.1731 RS
0.1781 RS
0.1798 RS
0.1764 RS
0.1774 RS
0.3054 RS
0.2607 RS
0.2754 RS
0.2476 RS
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
1924.5
831
1039.2
498.6
1700.1
1028.7
881.7
717.6
900
769.5
882
739.5
1031.1
1140.9
1056.6
1373.7
1129.8
10263
0
2764.5
1671
1879.2
1338.6
2540.1
1868.7
1721.7
1557.6
1740
1609.5
1722
1579.5
1871.1
1980.9
1896.6
2213.7
1969.8
11103
0
280
280
700
700
140
140
420
420
5003.925
5003.925
5843.925
5843.925
0
24018.84
0
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
0
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
10007.85
90070.65
0
974.1
732.9
1148.7
1045.5
881.7
846
956.4
813
842.7
723
878.4
731.4
681
812.7
858.3
904.2
994.5
994.5
921.9
0
10007.85
160617.75
0
1814.1
1572.9
1988.7
1885.5
1721.7
1686
1796.4
1653
1682.7
1563
1718.4
1571.4
1521
1652.7
1698.3
1744.2
1834.5
1834.5
1761.9
0
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
420
0
477.3
495
496.2
495.6
487.8
501.9
493.8
519.3
534.3
539.4
529.2
532.2
916.2
782.1
826.2
742.8
0
1317.3
1335
1336.2
1335.6
1327.8
1341.9
1333.8
1359.3
1374.3
1379.4
1369.2
1372.2
1756.2
1622.1
1666.2
1582.8
7 OF 8
-------
424
425
426
427
428
429
430
431
432
433
434
435
436
437
438
439
440
441
442
443
444
445
446
447
448
449
450
451
452
453
454
455
456
457
458
459
460
461
462
463
464
465
466
467
468
469
470
471
472
473
474
475
476
477
478
479
480
481
482
483
484
485
486
487
488
1702.
1354.
1333.
1341.
1345.
1332.
1327.
1324.
1312.
1314.
1328.
1342.
1342.
1337.
1337.
1339.
144£
1510.
1583.
1502.
1504.
1304.
1288.
1322.
1289.
133E
1349.
1338.
1343.
1329.
1362.
1379.
1377.
1379.
1377.
1384.
1590.
1486.
1514.
1411.
1764.
1322.
1308.
1308.
1317.
1445.
1453.
1463.
1412.
1380.
1376.
1376.
1396.
1342.
1344
1583.
1570.
171£
1344.
1342.
1392
1370.
1355.
1359.
396018028
396018029
396014001
396014027
396014028
396014029
396014030
396014031
396014032
396014033
396014034
396014035
396014036
396014037
396014038
396014039
396014040
396020014
396020015
396020016
396020017
396020018
396020019
396020020
396020021
396020022
396020023
396020010
396020011
396020012
396020013
396014007
396014008
396014009
396014010
396014011
396014012
396014013
396014014
396014015
396014016
396014017
396014018
396014019
396020024
396020025
396020026
396020027
396020028
396020001
396020004
396020005
396020006
396020003
396014043
396014044
396014045
396014046
396014047
396014041
396014042
396020002
396020007
396020008
396020009
14244.12
12519.144
7466.184
7161.264
7287.588
7335.504
7148.196
7082.856
7034.94
6865.056
6886.836
7087.212
7291.944
7291.944
7222.248
7222.248
7257.096
8842.68
9740.016
10794.168
9618.048
9648.54
6747.444
6512.22
7008.804
6529.644
7230.96
7400.844
7235.316
7305.012
7113.348
7583.796
7832.088
7801.596
7832.088
7801.596
7901.784
10903.068
9382.824
9792.288
8302.536
13429.548
7008.804
6799.716
6808.428
6934.752
8790.408
8903.664
9056.124
8306.892
7845.156
7784.172
7792.884
8084.736
7291.944
7318.08
10798.524
10606.86
12763.08
7322.436
7291.944
8015.04
7701.408
7487.964
7548.948
0.327 RS
0.2874 RS
0.1714 RS
0.1644 RS
0.1673 RS
0.1684 RS
0.1641 RS
0.1626 RS
0.1615 RS
0.1576 RS
0.1581 RS
0.1627 RS
0.1674 RS
0.1674 RS
0.1658 RS
0.1658 RS
0.1666 RS
0.203 RS
0.2236 RS
0.2478 RS
0.2208 RS
0.2215 RS
0.1549 RS
0.1495 RS
0.1609 RS
0.1499 RS
0.166 RS
0.1699 RS
0.1661 RS
0.1677 RS
0.1633 RS
0.1741 RS
0.1798 RS
0.1791 RS
0.1798 RS
0.1791 RS
0.1814 RS
0.2503 RS
0.2154 RS
0.2248 RS
0.1906 RS
0.3083 RS
0.1609 RS
0.1561 RS
0.1563 RS
0.1592 RS
0.2018 RS
0.2044 RS
0.2079 RS
0.1907 RS
0.1801 RS
0.1787 RS
0.1789 RS
0.1856 RS
0.1674 RS
0.168 RS
0.2479 RS
0.2435 RS
0.293 RS
0.1681 RS
0.1674 RS
0.184 RS
0.1768 RS
0.1719 RS
0.1733 RS
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
280
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
700
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
140
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Final EA, Pahala LCC Replacement Project
Pahala, Ka'u District, Hawai'i
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Appendix C
August 2018 Biological Survey Report
February 2020
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AECOS No. 1545
Biological survey for the Pahala Community
Large Capacity Cesspool Closure Project on lot
TMK: 9-6-002:018, Ka'u District, Hawaii Island
Prepared by:
AECOS, Inc.
45-939 Kamehameha Hwy, Suite 104
Kane'ohe, Hawai'i 96744-3221
August 16, 2018
-------
Biological survey for the Pahala Community
Large Capacity Cesspool Closure Project on lot
TMK: 9-6-002:018, Ka'u District, Hawai'i Island
August 16, 2018
Draft
AECOS No. 1545
Eric Guinther and Reginald David
AECOS, Inc.
45-939 Kamehameha Hwy, Suite 104
Kane'ohe, Hawai'i 96744
Phone: (808) 234-7770 Fax: (808) 234-7775 Email: guinther@aecos.com
Introduction
The Hawai'i County Department of Environmental Management, Wastewater
Division is proposing to construct a wastewater treatment and disposal system
("Project") to treat sewage collected in Pahala, Ka'u District. The treatment and
disposal system will be located on a property identified as TMK: 9-6-002:018,
north of the intersection of Hawaii Belt Road (Mamalahoa Highway) and Maile
Street. This report describes methods used and results of a biological survey
conducted in the Project area in August 2018. The primary purpose of the
survey was to determine whether any species currently proposed or listed as
threatened or endangered under either federal or state endangered species
statutes occur on, or could utilize resources within, the Project area.
Project and Site Descriptions
The WWTP site encompasses the lower, approximately 15 ac (6 ha) of the
subject parcel (TMK: 9-6-002:018). Presently the entire parcel is a macadamia
nut (Macadamia integrifolia) orchard, but with the margins and two narrow
windbreak tree lines dominated by other species of trees and herbaceous plants
dividing the orchard into northwest-southeast trending units. In addition to the
WWTP site, a proposed transmission pipe would be constructed to the
northwest through the orchard up to Maile Street. From Maile Street a
collection system is planned for many of the streets within Pahala town (see
Figure 1).
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0 250 500 1.000 1,500 2.000
Figure 1. Project and survey areas marked in red, Pahala.
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Macadamia nut trees form a closed crown of dense leaf growth (see cover
photo), creating deep shade within most parts of the grove. The dominant
understoiy in these deeply shaded areas is germinating mac nut trees.
Methods
Botanical Survey
The botanical survey was undertaken on August 13, 2018 and entailed a
wandering pedestrian transect that traversed the subject property, including
the area extending north to Maile Road proposed for installation of a collector
main. A "windshield" survey was conducted along all the streets proposed for
the collection system beyond the surveyed parcel. Plant species were identified
as they were encountered and notations made in a field notebook, which was
used to develop qualitative abundance values for each species as the survey
progressed. On a strictly area basis, only macadamia nut trees, Guinea grass
[Megathyrsus maximus), and perhaps a couple of other species would have a
ranking above uncommon. So, abundance values in this report are relative to
areas that support species other than the macadamia nut trees, such as the road
verges and other areas surrounding the orchard, unmaintained areas within the
orchard, including narrow windbreak lanes that divide the orchard plots into
units. The survey period encompassed the early dry season, but most of the
vegetation was in a relatively healthy state (the orchard is irrigated as needed).
However, early in the dry season found most trees and shrubs absent fruit or
flower. This slight limitation did not compromise the discovery of native
species of plants.
Plant names used herein follow Manual of the Flowering Plants of Hawai'i
(Wagner, Herbst, & Sohmer, 1990; Wagner & Herbst, 1999) for native and
naturalized flowering plants, Hawaii's Ferns and Fern Allies (Palmer, 2003) for
ferns, and^4 Tropical Garden Flora (Staples & Herbst, 2005) for ornamental and
crop plants. More recent name changes for naturalized plant species follow
Imada (2012).
Avian Survey
Six avian count stations were sited roughly equidistant from each other, four
within the WWTP area and two along the collection pipe route upslope to Maile
Street. Stations were sited approximately 150 m (490 ft) apart from each other.
A single eight-minute avian point count was made at each of the count stations.
Field observations were made with the aid of Leica 8 X 42 binoculars and by
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listening for vocalizations. The avian counts were conducted in the early
morning hours. Time not spent counting at point-count stations was used to
search the site for species and habitats not observed during the point counts.
Weather conditions were excellent with winds of between 1 and 5 kph and no
precipitation.
The avian phylogenetic order and nomenclature used in this report follows the
AOU Check-List of North American Birds (American Ornithologists' Union, 1998),
and the 42nd through the 59th supplements to the Check-List (American
Ornithologists' Union, 1998, 2000; Banks et al., 2002, 2003, 2004, 2005, 2006,
2007, 2008; Chesser et al., 2009, 2010, 2011, 2012, 2013, 2014, 2015, 2016,
2017,2018).
Mammalian Survey
With the exception of the endangered Hawaiian hoary bat (Lasiurus cinereus
semotus) or 'ope'ape'a, all terrestrial mammals currently found on the Island of
Hawai'i are alien species, and most are ubiquitous. The survey of mammals was
limited to visual and auditory detection, coupled with visual observation of scat,
tracks, and other animal sign. A running tally was kept of all terrestrial
mammalian species detected within the project area.
Results
Vegetation
Vegetation within the areas surveyed comprises a macadamia nut orchard of
mature trees, unmaintained areas dominated outside the orchard by Guinea
grass, lanes of windbreak trees oriented between orchard units, and (mostly)
mowed road verge areas. Within the orchard are scattered small plots of
ruderal herbaceous plants, in most cases dominated by nodeweed [Synedrella
nodiflora), but if generally only lightly shaded, a number of other herbaceous
species. The windbreak lanes consist of two rows of trees: silk oak (Grevelia
robusta) and paperbark (Melaleuca quinquenervia] and are used in orchard
maintenance to stack cut branches and logs. These lanes support many of the
herbaceous plants recorded from the orchard. The proposed sewerage
collection system will be installed along already paved roadways within Pahala.
The survey in these areas revealed the vegetation to be entirely maintained
yards of ornamental plants.
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Flora
A listing of the plant species recorded during the August 2018 survey is
provided as Table 1. In all, the listing has 52 species of vascular plants: 2 ferns,
one gymnosperm, and 49 species of angiosperms (flowering plants). Only two
species (4%) are regarded as native to the Hawaiian Islands and both are
indigenous (native, but also distributed elsewhere in the Pacific). Found in low
numbers are the ubiquitous, ruderal 'uhaloa (Waltheria indica) and the common
blue- or purple-flowered morning glory vine: koali 'awa (Ipomoea indica). Being
widely distributed indigenous species, neither is listed as threatened or
endangered or of any special concern.
Table 1. Plant species identified during the August 13, 2018 survey of
TMK: 9-6-002:018, Pahala, Ka'u District, Hawai'i.
Species listed by family
Common name
Status Abundance Notes
sword fern
FERNS
NEPHROLEPIDACEAE
Nephrolepis multiflora (Roxb.)
F.M. Jarrett ex C.V. Morton
PTERIDACEAE
Pityrogramma calomelanos (L.) silver fern
Link
Nat R
Nat R <1>
GYMNOSPERMS
ARAU C ARIAC EAE
Araucaria columnaris (G. Forst.)
J.D. Hook.
Cook pine
Nat O <1>
FLOWERING PLANTS
DICOTYLEDONS
AMERANTHACEAE
Amaranthus spinosus L.
APOCYNACEAE
Carissa macrocarpa (Ecklon) A.
de Cand.
Nerium oleander L.
ARALIACEAE
Schefflera actinophylla (Endl.)
Harms
ASTERACEAE (COMPOSITAE)
Ageratum conyzoides L.
spiny amaranth
natal plum
olreander
umbrella tree
maile hohono
Nat R
Orn
Orn
R
R
Nat U
Nat R <1>
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Table 1 (continued).
Species listed by family
ASTERACEAE (cont.)
Bidens pilosa L.
Calyptocarpus vialis Less.
Conyza bonariensis (L.) Cronq.
Crassocephalum crepidioides
(Benth.) S. Moore
Cyanthillium cinereum L.
Lactuca serriola L.
Indet.
Synedrella nodiflora (L.) Gaertn.
BASELLACEAE
Anredera cordifolia (Ten.) Steenis
BRASSICACEAE
Lepidium virginicum L.
CAPPARACEAE
Cleome gynandra L.
CONVOLVULACEAE
Ipomoea indica (J. Burm.) Merr.
Ipomoea obscura (L.) Ker-Gawl.
Merremia tuberosa (L.) J. Rendle
CUCURBITACEAE
Momordica charantia L.
EUPHORBIACEAE
Euphorbia heterophylla L.
Euphorbia hirta L.
Ricinus communis L.
FABACEAE
Acacia confusa Merr.
Leucaena leucocephala (Lam.)
deWit
Macroptilium atropurpureum
(DC.) Urb.
Neonotonia wightii (Wight &
Arnott) Lackey
LAMIACEAE
Leonotis nepetifolia (L.) R. Br.
MALVACEAE
Abutilon grandifolium (Willd.)
Sweet
Malvastrum coromandelianum
(L.) Garcke
Sida rhombifolia L.
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Common name Status Abundance Notes
ki; beggartick
Nat
U
<2>
—
Nat
0
<1>
hairy horseweed
Nat
C
<2>
—
Nat
R
little ironweed
Nat
U
<1>
prickly lettuce
Nat
U
<1>
ruderal weed
Nat
R
<3>
nodeweed
Nat
AA
<2>
Madeira vine
Nat
R
<3>
—
Nat
R
<2>
wild spider flower
Nat
0
<1>
koali 'awa
Ind
R
...
Nat
0
wood rose
Nat
R
wild bitter melon
Nat
0
kaliko
Nat
U
<1>
garden spurge
Nat
0
<2>
castor bean
Nat
C
<2>
Formosan koa
Nat
R
koa haole
Nat
R
<2>
—
Nat
U
<1>
glycine vine
Nat
AA
<2>
lion's ear
Nat
0
<2>
hairy abutilon
Nat
R
false mallow
Nat
0
<2>
Cuba jute
Nat
C
<2>
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Table 1 (continued).
Species listed by family
Common name
Status Abundance Notes
MALVACEAE (cont.)
Sida spinosa L.
Waltheria indica L.
MORACEAE
Ficus microcarpa L. f.
MYRTACEAE
Melaleuca quinquenervia (Cav.)
S.T. Blake
Syzygium cumini (L.) Skeels
PHYTOLACCACEAE
Rivina humilis L.
PROTEACEAE
Grevillea robusta A. Cunn. ex R.
Br.
Macadamia integrifolia Maiden &
Berche
RUBIACEAE
Spermacoce assurgens Ruiz & Pav.
prickly sida
'uhaloa
Chinese banyan
paperbark
Java plum
coral berry
silk oak
macadamia nut
buttonweed
Nat
Ind
R
U
Nat R <2>
Nat C
Nat U <2>
Nat U
Nat
Nat AA
<2>
Nat
<1>
MONOCOTYLEDONS
COMMELINACEAE
Commelina benghalensis L.
CYPERACEAE
Cyperus gracilis R. Br.
POACEAE
Axonopus compressus (Swartz) P.
Beauv.
Cenchrus purpureus (Schumach.)
Morrone
Chloris barbata (L.) Sw.
Digiteria sp.
Eleusine indica (L.) Gaertn.
Megathyrsus maximus Jacq.
Setaria verticillata (L.) P. Beauv.
hairy honohono
McCoy grass
brd.-lvd. carpet
grass
elephant grass
swollen fingergrass
wiregrass
Guinea grass
bristly foxtail
Nat R <1>
Nat U
Nat
Nat
Nat
Nat
Nat
Nat
Nat
U
R
R
A
AA
R
<1>
<2>
<2>
Legend to Table 1:
Status = distributional status
Ind = indigenous; native to Hawai'i, but not unique to the Hawaiian Islands.
Nat = naturalized, exotic, plant introduced to the Hawaiian Islands since the arrival of
Cook Expedition in 1778 and well-established outside of cultivation.
Orn = ornamental; crop or landscape plant not established outside of cultivation.
Abundance = occurrence ratings for plants on property in July 2013.
R - Rare - only one or two plants seen.
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Table 1 - Legend (continued).
U - Uncommon - several to a dozen plants observed.
0 - Occasional - found regularly, but not abundant anywhere.
C - Common - considered an important part of the vegetation and observed numerous
times.
A - Abundant - found in large numbers; may be locally dominant.
AA - Abundant - very abundant and dominant; defining vegetation type.
Notes:
<1> Characteristic or found only in the road verge immediately adjacent to the site.
<2> Species also reported from close by in David & Guinther (2013).
<3> Plant lacking flowers or fruit at time of survey; identification uncertain.
Avian Survey
A total of 175 individual birds of 13 species, representing nine separate families,
was recorded during station counts (Table 2). Avian diversity and densities
were very low, in keeping with the current usage of the site as a mature
macadamia nut orchard, with minimal ground cover and few weedy or shrubby
species. A closed canopy keeps areas beneath the trees in perpetual twilight.
Four species, Northern Cardinal (Cardinalis cardinalis), Japanese White-eye
(Zosterops japonicus), Yellow-fronted Canary (Ceithagra mozambica), and Red-
billed Leiothrix (Leiothrix luted), accounted for 52% of all birds recorded during
station counts. The most frequently recorded species was Northern Cardinal,
which accounted for 16% of the total number of individual birds recorded
during station point counts. All of the species recorded during the course of this
survey are established alien species.
Table 2. Avian species detected during point-counts for
the Pahala Community WWTP Project
Common Name
Scientific Name
ST RA
Wild Turkey
PHASIANIDAE - Pheasants & Partridges
Meleagridinae -Turkeys
Meleagris gallopavo
2.00
Spotted Dove
Zebra Dove
COLUMBIFORMES
COLUMBIDAE - Pigeons & Doves
Streptopelia chinensis
Geopelia striata
A
A
3.17
2.00
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Table 2 (continued).
Common Name
Scientific Name
ST
RA
PASSERIFORMES
ZOSTEROPIDAE - White-eyes
Japanese White-eye
Zosterops japonicus
A
3.67
TIMAUIDAE- Babblers
Chinese Hwamei
Garrulax canorus
A
2.00
Red-billed Leiothrix
Leiothrix lutea
A
3.33
STURNIDAE-Starlings
Common Myna
Acridotheres tristis
A
0.17
FRINGILUDAE - Fringilline and Carduline Finches & Allies
Carduelinae - Carduline Finches and Hawaiian
Honeycreepers
House Finch
Haemorhous mexicanus
A
1.33
Yellow-fronted Canary
Ceithagra mozambica
A
1.50
CARDINAUDAE-Cardinals & Allies
Northern Cardinal
Cardinalis cardinalis
A
4.67
THRAUPIDAE - Tanagers
Thraupinae - Core Tanagers
Yellow-billed Cardinal
Paroaria capitata
A
1.50
Saffron Finch
Sicalisflaveola
A
1.67
ESTRILDIDAE - Estrildid Finches
Scaly-breasted Munia
Lonchura punctulata
A
0.17
Key to Table 2
ST Status.
A Alien - Introduced to the Hawaiian Islands by humans.
RA Relative Abundance - Number of birds detected divided by the number of count stations (6].
Mammalian Survey
Rather remarkably, we recorded no mammalian species within the survey area.
Indeed, there was no indication that pigs (Sus scrofa) utilize the Project area.
Discussion
Botanical Resources
Although some unmaintained or infrequently maintained areas exist on the
subject parcel, the entire Project is proposed for land that is highly modified and
the flora present subject to alterations, including mowing. Thus, there is no
expectation for the site to support remnants of a native forest flora and minimal
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opportunity for native plants to become established, the 'uhaloa and koali 'awa
being exceptions due to their ability to grow in highly disturbed environments.
A previous biological survey (David and Guinther, 2013) conducted on 5 ac (2
ha) of land close by to the east yielded only 25 species of plants, the most
abundant being white shrimp plant (Justicia betonica), glycine vine, and Guinea
grass. Because that area had been highly disturbed, then not disturbed for a
long time, species such as the shrimp plant and particularly Guinea grass had
become well-established to the exclusion of other species. Sixteen species (24%
of the combined species list) were common to both surveys.
Obviously, the macadamia nut orchard is a valuable botanical resource, but a
commercial one and not an environmentally sensitive one. The same can be
said for the Cook pines (Araucaria columnaris) that line Maile Street along the
southwestern side of the parcel. These old trees are an important community
landscape element to be retained in place by the Project.
Avian Resources
The findings of the avian survey are consistent with the location of the site, and
the monoculture of macadamia nut trees present on it. No native avian species
were recorded during the course of this survey.
Although not detected during this survey, endemic Hawaiian Petrel
(Pterodroma sandwichensis) and Newell's Shearwater [Puffinus newelli) have
been recorded over-flying the general Project area between April and the end of
November each year. The petrel is listed as endangered, and the shearwater as
threatened under both federal and State of Hawai'i endangered species statutes.
The primary cause of mortality in both Hawaiian Petrel and Newell's
Shearwater is thought to be predation by alien mammalian species at the
nesting colonies (USFWS, 1983; Simons and Hodges, 1998; Ainley et al., 2001).
Collision with man-made structures is considered to be second-most significant
cause of mortality of these seabirds in Hawai'i. Nocturnally flying seabirds,
especially fledglings on their way to sea in the summer and fall, can become
disoriented by exterior lighting. When disoriented, seabirds can collide with
man-made structures and, if not killed outright, dazed or injured birds become
prey to feral mammals (Hadley, 1961; Telfer, 1979; Sincock, 1981; Reed et al.,
1985; Telfer et al., 1987; Cooper and Day, 1998; Podolsky et al., 1998; Ainley et
al., 2001; Hue et al., 2001; Day et al., 2003). Neither nesting colonies nor
appropriate nesting habitat for either of these listed seabird species occur
within or close to the current Project site.
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Mammalian Resources
No Hawaiian hoary bats were detected during the course of this survey. It is
possible that bats use resources within orchard part of the Project. Although,
no rodents were recorded during the course of this survey, it is likely that one
or more of the four alien Muridae established on Hawai'i Island—European
house mouse (Mus musculus domesticus], roof rat (Rattus rattus), brown rat
[Rattus norvegicus), and black rat (Rattus exulans hawaiiensis]—use various
resources found within the general Project area on a seasonal basis, especially
in the macadamia nut orchard. These human commensal species are drawn to
areas of human habitation and activity and all are deleterious to native
ecosystems and their dependent native fauna.
Jurisdictional Waters
The subject parcel slopes down to the southwest corner. A street culvert at that
location carries runoff in the area under Mamalahoa Highway (Hawaii Belt
Road). The National Wetlands Inventory (NWI) Wetlands Mapper (USFW, nd
(a)) shows no features occurring on the parcel and no streams are shown on
USGS topographic maps (USGS, 1923). Streams in the Pahala area of the Island
do not flow all the way to the sea, but terminate on Keone'ele'ele Flat to the
southwest.
Critical Habitat
Federally delineated Critical Habitat is not present in Pahala area (USFWS,
2012). Thus, the Project will not impinge on federally designated Critical
Habitat. No equivalent designation exists under state law
Potential Impacts to Protected Species
No species of plants or animals currently proposed for listing or listed under
either the federal or State of Hawai'i endangered species statutes (DLNR 1998,
2015; USFWS, nd (b)) were recorded by this survey. Three faunal species not
observed, may occur in the general vicinity and are discussed here.
Seabirds
The principal potential impact that the construction of the project poses to
protected seabirds is the increased threat that birds will be downed after
becoming disoriented by lights associated with the proposed action during the
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nesting season. The two activities that could pose a threat to these nocturnally
flying seabirds are: a) if during construction, it is deemed expedient or
necessary to conduct night-time construction activities during the seabird
fledging season (which runs from September 15 through December 15); or b)
exterior lighting is installed as part of the WWTP facilities. Impacts can be
minimized if all external lighting is made dark sky compliant (HDLNR-DOFAW,
2016).
Hawaiian hoary bat
The potential impact that Project construction poses to the endangered
Hawaiian hoary bat would be from clearing and grubbing of the macadamia nut
orchard. Trimming or removal of trees within the construction areas may
temporarily displace bats using this vegetation for roosting. Hawaiian bats use
multiple roosts within their home territories, so the disturbance resulting from
removal of trees is likely to be minimal. However, during pupping season,
female bats carrying pups may be less able to rapidly vacate a roost site when
the tree is felled. Additionally, adult female bats sometimes leave their pups in
the roost tree while they themselves forage, and very small pups may be unable
to flee a tree that is being felled. Adverse effects from such disturbance can be
avoided or minimized by not clearing woody vegetation taller than 4.6 m (15 ft),
between June 1 and September 15, the bat pupping season.
References
Ainley, D. G, R. Podolsky, L. Deforest, G. Spencer, and N. Nur. 2001. The Status
and Population Trends of the Newell's Shearwater on Kaua'i: Insights
from Modeling, in: Scott, J. M, S. Conant, and C. Van Riper III (editors)
Evolution, Ecology, Conservation, and Management of Hawaiian Birds: A
Vanishing Avifauna. Studies in Avian Biology No. 22. Cooper's
Ornithological Society, Allen Press, Lawrence, Kansas. Pp. 108-123.
American Ornithologist's Union. 1998. Check-list of North American Birds. 7th
edition. AOU. Washington, D.C. 829 pp.
. 2000. Forty-second supplement to the American Ornithologist's Union
Check-list of North American Birds. The Auk, 117: 847-858.
Banks, R. C., C. Cicero, J. L. Dunn, A. W. Kratter, P. C. Rasmussen, J. V. Remsen, Jr.,
J. D. Rising, and D. F. Stotz. 2002. Forty-third supplement to the American
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Ornithologist's Union Check-list of North American Birds. The Auk, 119:
897-906.
Banks, R. C., C. Cicero, J. L. Dunn, A. W. Kratter, P. C. Rasmussen, J. V. Remsen, Jr.,
J. D. Rising, and D. F. Stotz. 2003. Forty-fourth supplement to the
American Ornithologist's Union Check-list of North American Birds. The
Auk, 120:923-931.
, , , , , , , and . 2004. Forty-fifth
supplement to the American Ornithologist's Union Check-list of North
American Birds. The Auk, 121: 985-995.
, , , , , , , and . 2005. Forty-sixth
supplement to the American Ornithologist's Union Check-list of North
American Birds. The Auk, 122: 1026-1031.
, , , , , , , and . 2006. Forty-seventh
supplement to the American Ornithologist's Union Check-list of North
American Birds. The Auk, 123: 926-936.
, R. T. Chesser, C. Cicero, J. L. Dunn, A. W. Kratter, I. J. Lovette, P. C.
Rasmussen, J. V. Remsen, Jr., J. D. Rising, and D. F. Stotz. 2007 Forty-
eighth supplement to the American Ornithologist Union Check-list
of North American Birds. The Auk, 124: 1109-1115.
. . , , , , , , , , and K.
Winker. 2008 Forty-ninth supplement to the American Ornithologist
Union Check-list of North American Birds. The Auk, 125: 758-768.
Chesser, R. T., R. C. Banks, F. K. Barker, C. Cicero, J. L. Dunn, A. W. Kratter, I. J.
Lovette, P. C. Rasmussen, J. V. Remsen, Jr., J. D. Rising, D. F. Stotz, and K.
Winker. 2009. Fiftieth supplement to the American Ornithologist Union,
Check-list of North American Birds. The Auk, 126: 1-10.
and . 2010. Fifty-first supplement to the American Ornithologist
Union, Check-list of North American Birds. The Auk 127: 726-744.
and . 2011. Fifty-second supplement to the American Ornithologist
Union, Check-list of North American Birds. The Auk, 128: 600-613.
AECOS Inc. [File: 1545,docx]
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Biological Surveys
PAhala WWTP (TMK: 9-6-002: 018)
Chesser, R. T., R. C. Banks, F. K. Barker, C. Cicero, J. L. Dunn, A. W. Kratter, I. J.
Lovette, P. C. Rasmussen, J. V. Remsen, Jr., J. D. Rising, D. F. Stotz, and K.
Winker. 2012. Fifty-third supplement to the American Ornithologist
Union, Check-list of North American Birds. The Auk, 129: 573-588.
and .. 2013. Fifty-fourth supplement to the American Ornithologist
Union, Check-list of North American Birds. The Auk, 130: 558-71.
and . 2014. Fifty-fifth supplement to the American Ornithologist
Union Check-list of North American Birds. The Auk, Ornithological
Advances, 131: CSi-CSxv.
, , , , , , A. G. Navarro-Sigiienza, P. C.
Rasmussen, J. V. Remsen, Jr., J. D. Rising, D. F. Stotz, and K. Winker. 2015.
Fifty-sixth supplement to the American Ornithologist Union Check-list of
North American Birds. The Auk, Ornithological Advances, 132: 748-764.
, and . 2016. Fifty-seventh supplement to the American
Ornithologist Union Check-list of North American Birds. The Auk,
Ornithological Advances, 133: 544-560.
, K. J. Burns, C. Cicero, J. L. Dunn, A. W. Kratter, I. J. Lovette, P. C.
Rasmussen, J. V. Remsen, Jr., J. D. Rising, D. F. Stotz, and K. Winker. 2017.
Fifty-eighth supplement to the American Ornithologist Society Check-list
of North American Birds. The Auk, Ornithological Advances, 134: 751-
773.
, , , , , , , , , , B. M.
Winger, and K. Winker. 2018. Fifty-ninth supplement to the American
Ornithologist Society's Check-list of North American Birds. The Auk,
Ornithological Advances, 135: 798-813.
Cooper, B. A. and R. H. Day. 1998. Summer behavior and mortality of Dark-
rumped Petrels and Newell's Shearwaters at power lines on Kauai.
Colonial Waterbirds, 21(1): 11-19.
and R. H. Day. 1998. Summer Behavior and Mortality of Dark-rumped
Petrels and Newells' Shearwaters at Power Lines on Kauai. Colonial
Waterbirds, 21(1): 11-19.
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Biological Surveys
PAhala WWTP (TMK: 9-6-002: 018)
Day, R. H., B. A. Cooper, and T. C. Telfer. 2003. Decline of Townsend's (Newell's
Shearwaters (Puffinus auricularis newel I i) on Kauai, Hawaii. The Auk,
120: 669-679.
David, R. E. 2018. Unpublished field notes - Hawai'i 1980 - 2018.
, and E. B. Guinther. 2013. Biological surveys conducted for the Pahala
Wastewater Treatment Plant Project, Ka'u District, Island of Hawai'i.
Prep for Fukunaga and Assoc. Inc. Rana Biological Consulting, Inc., 17 pp.
Hawai'i Department of Land and Natural Resources (HDLNR). 1998. Chapter
107. Threatened and Endangered Plants. Department of Land and
Natural Resources. State of Hawai'i. Administrative Rule under Title 13.
Subtitle 5, Part 1, dated March 23,1998.
. 2015. Chapter 124. Indigenous Wildlife, Endangered, Injurious Wildlife,
Introduced Wild Birds, and Introduced Wildlife. Department of Land and
Natural Resources. State of Hawaii. Administrative Rule under Title 13.
Subtitle 5, Part 2, dated February 17, 2015. Exhibits dated November 1,
2014.
Hawai'i Department of Land and Natural Resources, Division of Forestry and
Wildlife (HDLNR-DOFAW). 2016. Wildlife Lighting. PDF available at
URL: http://dlnr.hawaii.gov/wildlife/files/2016/03/DOC439.pdf; last
accessed on January 17, 2018.
Hadley, T. H. 1961. Shearwater calamity on Kauai. Elepaio, 21: 60.
Hue, D., C. Glidden, J. Lippert, L. Schnell, J. Maclvor and J. Meisler. 2001. Habitat
Use and Limiting Factors in a Population of Hawaiian Dark-rumped
Petrels on Mauna Loa, Hawai'i. Pp. 234-242, in:: Scott, J. M, S. Conant, and
C. Van Riper III (editors) Evolution, Ecology, Conservation, and
Management of Hawaiian Birds: A Vanishing Avifauna. Studies in Avian
Biology No. 22. Cooper's Ornithological Society, Allen Press, Lawrence,
Kansas.
Imada, C. T. 2012. Hawaiian Native and Naturalized Vascular Plants Checklist
(December 2012 update). Bishop Museum Tech. Rept. 60. 380 pp.
Palmer, D. D. 2003. HawaVi's Ferns and Fern Allies. University of Hawaii Press,
Honolulu. 324 pp.
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Biological Surveys
PAhala WWTP (TMK: 9-6-002: 018)
Podolsky, R., D. G. Ainley, G. Spencer, L. de Forest, and N. Nur. 1998. Mortality
of Newell's Shearwaters Caused by Collisions with Urban Structures on
Kaua'i. Colonial Waterbirds, 21: 20-34.
Reed, J. R., J. L Sincock, and J. P. Hailman 1985. Light Attraction in Endangered
Procellariform Birds: Reduction by Shielding Upward Radiation. The Auk,
102: 377-383.
Simons, T. R., and C. N. Hodges. 1998. Dark-rumped Petrel (Pterodroma
phaeopygia). In: A. Poole and F. Gill (editors). The Birds of North
America, No. 345. The Academy of Natural Sciences, Philadelphia, PA.
and the American Ornithologists Union, Washington, D.C.
Sincock, J. L. 1981. Saving the Newell's Shearwater. Pp. 76-78 in: Proc. of the
Hawaii Forestry and Wildllife Conference, 2-4 October 1980. Department
of Land and Natural Resources, State of Hawaii, Honolulu.
Staples, G. W. and D. R. Herbst. 2005. A Tropical Garden Flora. Plants Cultivated
in the Hawaiian Islands and other Tropical Places. Bishop Museum,
Honolulu. 908 pp.
Telfer, T. C. 1979. Successful Newell's Shearwater Salvage on Kauai. 'Elepaio,
39:71
, J. L. Sincock, G. V. Byrd, and J. R. Reed. 1987. Attraction of Hawaiian
seabirds to lights: conservation efforts and effects of moon phase.
Wildlife Soc. Bull., 15: 406-413.
U.S. Fish & Wildlife Service (USFWS). 1983. Hawaiian Dark-Rumped Petrel &
Newell's Manx Shearwater Recovery Plan. USFWS, Portland, Oregon.
February 1983.
. no date (a). National Wetlands Inventory website. U.S. Department of
the Interior, Fish and Wildlife Service, Washington, D.C. Available online
at URL: http://www.fws.gov/wetlands/ Data/Mapper.html; last accessed on
July 1, 2018.
. no date (b). USFWS Endangered Species. Available online at URL:
https://www.fws.gov/endangered/; Last visited on June 3, 2018 and
Environmental Conservation Online System (ECOS), online at URL:
https://ecos.fws.gov/ecp/species-reports; last visited on June 21, 2018.
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Biological Surveys
PAhala WWTP (TMK: 9-6-002: 018)
U.S. Geological Survey (USGS). 1923.15-minute Series, Topographic Map, Pahala
Quadrangle.
Wagner, W. L., D. R. Herbst and S. H. Sohmer. 1990. Manual of the Flowering
Plants of Hawai'i: Volume I and II. Bishop Museum Special Publication
83. University of Hawai'i Press. 1853 pp.
and . 1999. Supplement to the Manual of the flowering plants of
Hawai'i, pp. 1855-1918. In: Wagner, W. L., D. R. Herbst, and S. H. Sohmer,
Manual of the flowering plants of Hawai'i. Revised edition. 2 vols.
University of Hawaii Press and B.P. Bishop Museum.
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Final EA, Pahala LCC Replacement Project
Pahala, Ka'u District, Hawai'i
Appendix C-1
Endangered Species Act Section 7 Consultation
February 2020
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Final EA, Pahala LCC Replacement Project
Pahala, Ka'u District, Hawai'i
THIS PAGE INTENTIONALLY LEFT BLANK
February 2020
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December 21, 2018
Eldridge Naboa, Fish and Wildlife Biologist
U.S. Department of the Interior
U.S. Fish and Wildlife Service
300 Ala Moana Boulevard
Room 3-122, Box 50088
Honolulu, HI 96850
Subject: Pahala Large Capacity Cesspool (LCC) Replacement Project; Pahala, Ka'u
District, Hawai'i (01EPIF00-2018-TA-0275) - Request for Concurrence
Dear Mr. Naboa:
On behalf of the United States Environmental Protection Agency (EPA) and the County of Hawai'i
(County), and as the designated non-Federal representative for consultations under Section 7 of the
Endangered Species Act, we respectfully request concurrence from the U.S. Fish and Wildlife
Service (FWS) that the above-referenced project is not likely to adversely affect federally-listed
threatened and endangered species or critical habitat This consultation addresses the project's
potential impacts to the following eight species that were identified in correspondence with FWS
dated April 23, 2018 as having the potential to occur in the vicinity of the project area: Hawaiian
hoary bat (Lasiurus cinereus semotus), Hawaiian Hawk (Buteo solitarius), Nene (Branta
sandvicensis), Hawaiian Petrel (Pterodroma sandwichensis), Band-rumped Storm-Petrel
(Oceanodroma castro), Newell's Shearwater (Puffinus newelli), Hawaiian Stilt (Himantopus
mexicanus knudseni], and Hawaiian Coot (Fulica alai).
The proposed project is located in Pahala, Ka'u District, Hawai'i. Funding for this project is provided
by a Special Appropriation Grant from EPA and a loan from the State of Hawai'i Clean Water State
Revolving Fund (SRF). The project involves replacing two large-capacity cesspools (LCCs) with a
new County-owned wastewater collection system to be constructed primarily within the existing
public right-of-way (ROW); a treatment and disposal system that will occupy a 14.9-acre site that is
currently a privately-owned macadamia nut plantation; and closure of the two LCCs. See enclosed
map of project location for reference (Site 7 on the attached Figure 1).
Project Description/Action Area
The proposed project is located in the community of Pahala, a former sugar farming and processing
operation, in the Ka'u District, Island of Hawai'i. In 1999, pursuant to the Safe Drinking Water Act,
EPA promulgated regulations (40 CFR 144.14) requiring the elimination or closure of all LCCs by
April 2005. In 2010, the C. Brewer company transferred the ownership and operation of the LCCs
to the County, which is bringing these wastewater systems into compliance with the Safe Drinking
Water Act.
14555 Avion Parkway, Suite 200, Chantilly, VA 20151-1102 • Phone (703) 633-1600 • Fax (703) 263-7280
Ann Arbor • Arlington, VA • Atlanta, GA • Austin, TX • Boston, MA • Chantilly, VA • Lexington, MA
Nashua, NH • Prairie Village, KS • Research Triangle Park, NC • Sacramento, CA
Equal Opportunity Employer • Printed on 100% Post-Consumer Recycled Paper
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The proposed project will consist of constructing a new wastewater collection system primarily
within the public ROW and a treatment and disposal system located on a 14.9-acre parcel that is
currently privately owned (TMK: 9-6-002: 018), but will be acquired by the County (Figure 1). The
wastewater collection system will consist of approximately 12,150 linear feet of 8 to 16-inch
gravity-flow piping located within eight public streets. The treatment and disposal facility will be a
land-based system consisting of a headworks with screens to remove debris and an odor control
unit; a series of three 0.4-acre aerated lagoons and a fourth, 0.8-acre aerated lagoon; an operations
building with adjacent disinfection system; a subsurface flow constructed wetland; and four slow-
rate (SR) land treatment basins, which will be surrounded by berms on all sides (Figure 2). SR land
treatment involves irrigation of land and vegetation with treated wastewater effluent Significant
additional treatment occurs as the water percolates through the soil. The facility's treatment
capacity will be approximately 190,000 gallons per day. The property will be cleared of trees and
will be enclosed by a 6-foot-high chain link security fence (Figure 2). No more than two Cook pines
(Araucaria columnaris) along Maile Street will be removed to accommodate the new driveway to
the treatment and disposal facility.
Once the new system is in place, the County will close and abandon the existing LCCs. This system
includes some lines located in the backyards of residential lots and some within public streets;
therefore, abandoning the lines in place will minimize impacts related to their excavation and
removal. The cut ends of the abandoned laterals to the collection system will be plugged with
concrete to prevent unauthorized use of the old system and to avoid the need to maintain an
unused underground hydraulic conduit. The two LCCs will also be abandoned and closed; the
specific closure methods have not yet been determined but will be consistent with the
requirements set forth in Hawai'i Administrative Rules §11-23-19.
Consultation History with FWS
Representatives of EPA and the County have conferred with FWS regarding this project In the
process of preparing the Draft Environmental Assessment (EA), the County's representative
(Wilson Okamoto Corporation) submitted a written request for comments to FWS in a letter dated
March 15, 2018. In a letter dated April 23, 2018, FWS identified the eight federally-listed species
having the potential to occur in the vicinity of the project area, as well as FWS's recommended
impact avoidance and minimization measures for each species. The project team subsequently
provided a written summary of the botanical and biological field studies that were undertaken as
part of the Draft EA in a letter to FWS dated August 20, 2018. Copies of the three corresponding
letters are enclosed. The project team also held a conference call with FWS on October 17, 2018 and
has incorporated feedback from the phone call into our assessment of potential impacts and
planned avoidance and mitigation measures.
Summary of August 2018 Biological Field Survey
Botanical and biological field surveys were conducted in August 2018 within the proposed project
area, including the streets and adjacent areas of the proposed wastewater collection system and the
14.9-acre wastewater treatment and disposal facility site. The field surveys confirmed that the
collection system will be installed along roadways within Pahala that are already paved, and that
vegetation that will be impacted consists of ornamental plants in private yards.
Surveys of the wastewater treatment and disposal facility site documented 52 species of vascular
plants; however, only two species are considered native to the Hawaiian Islands and both are
widely-distributed indigenous species that are not listed as threatened, endangered, or of special
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December 21, 2018
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concern. An avian survey of the project site recorded 13 bird species, all of which are established
alien species. While not documented during the field survey of the project area, the field survey
contractor noted in their survey report that the Hawaiian Petrel and Newell's Shearwater have
been observed flying over the general project area between April and the end of November each
year.
No species of plants or animals currently proposed for listing or listed under either the federal or
State of Hawai'i endangered species statutes were recorded by the survey.
Federally-designated Critical Habitat
ERG reviewed the FWS Environmental Conservation Online System (ECOS) and contacted FWS by
email in November 2018 to determine whether any proposed or final critical habitat of federally
listed threatened or endangered species has been designated in the vicinity of the project area. Per
ECOS, critical habitat is designated at several locations throughout the County; however, no
proposed or final critical habitat has been designated at or in the immediate vicinity of the project
area. This finding was confirmed by FWS in email correspondence dated November 29, 2018. The
project area is located approximately 3.1 miles northwest of the nearest critical habitat along the
island's shoreline, which has been designated for the federally and state-endangered Hawaiian
monk seal [Monachus schauinslandi). Based on the distance, the 600- to 900 feet elevation of the
project area, and the nature of project activities, impacts to this or other critical habitats in the
County are not anticipated.
Anticipated Impacts to Federally-listed Species and Proposed Avoidance Measures
Hawaiian Hoary Bat
Potential impacts to Hawaiian hoary bat from construction and operation of the project include
injury or mortality of young bats if woody vegetation is cleared during the pupping season and
entanglement in barbed wire fencing.
All clearing activities of trees taller than 15 feet will be scheduled to take place outside the pupping
season of the Hawaiian hoary bat, which lasts from June 1 to September 15. Additionally, to avoid
adverse impacts to Hawaiian hoary bats no barbed wire will be used on the security fence or
elsewhere on the project site.
Hawaiian Hawk
Potential impacts to Hawaiian Hawk from construction and operation of the project include
destruction of a nest by cutting a tree in which a nest is located, either during or outside of the
breeding season. Noise-related disturbance resulting from construction activities (including tree
clearing and facility construction) in the vicinity of a nest during the breeding season is a second
potential impact Noise-related disturbance in close proximity to a nest has the potential to result
in nest failure due to adult nest abandonment and increased exposure of chicks and juveniles to
inclement weather or predators.
The 14.9-acre parcel proposed for the treatment and disposal facility is currently a monotypic
macadamia nut plantation. The existing macadamia nut plantation likely does not provide suitable
nesting habitat for Hawaiian Hawks; therefore, tree clearing within this area (whether during or
outside the breeding season) is not expected to directly harm or destroy Hawaiian Hawk nests.
Additionally, the Cook pines along Maile Street are not expected to provide suitable nesting habitat
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December 21, 2018
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for Hawaiian Hawks, due in part to their location alongside a road. Removal of the one or two Cook
pines as necessary to accommodate the new driveway is not expected to directly harm or destroy
Hawaiian Hawk nests. Regardless of the time of year, no trimming or cutting of trees that contain a
Hawaiian Hawk nest will be performed.
If feasible, to avoid noise-related disturbance during the Hawaiian Hawk breeding season (which
lasts from March 1 to September 30), all tree clearing activities will be scheduled to occur outside
the breeding season. If, however, tree clearing will occur during the breeding season, the County
will seek technical assistance from FWS regarding appropriate survey methods to determine
whether nesting Hawaiian Hawks are present near the area to be cleared. Depending on the timing
of the survey, methods may include visual nest searches and/or callback surveys by a qualified
biological monitor. If surveys document the presence of an active Hawaiian Hawk nest during the
breeding season within 1,600 feet of the area to be cleared, the County will postpone tree clearing
activities until after the breeding season or until authorized in writing by FWS that activities may
proceed.
Additionally, if site preparation, construction, or other substantial noise-generating activities
(following the completion of tree clearing) will occur during the Hawaiian Hawk breeding season,
the County will seek technical assistance from FWS regarding whether any surveys of the
surrounding area are necessary. If surveys document the presence of an active Hawaiian Hawk nest
during the breeding season within 1,600 feet of the footprint of site preparation and construction
activities, the County will seek technical assistance from FWS to ensure that any noise-generating
activities do not have the potential to result in nest abandonment.
Waterbirds
Potential impacts to Nene, Hawaiian Stilt, and Hawaiian Coot are primarily related to the creation of
suboptimal habitat at the treatment and disposal facility. Specifically, the constructed lagoons may
represent an attractive nuisance due to the potential for spread of botulism, and the presence of
waterbirds and their nests at the facility may attract non-native mammalian predators to the area.
Several measures are proposed to discourage and monitor waterbird use of the facility and exclude
predators from the area. Design elements of the proposed facility expected to discourage waterbird
use of the area include the following: the total proposed acreage of new lagoon surface
(approximately 2 acres) is relatively small, as compared to approximately 20 acres of lagoons at the
Kealakehe Wastewater Treatment Plant in Kailua-Kona, Hawai'i; the subsurface-flow-constructed-
wetland will not have areas of open water, which would attract waterbird prey; asphalt rather than
gravel will be used to provide access around the lagoons; the lagoons will be lined with a high-
density polyethylene (HDPE) liner, rather than with substrate that would support vegetation
growth; shade balls will be used in the largest lagoon (Lagoon 4) to discourage algal growth, and
are also expected to discourage use of the lagoon by waterbirds; and the lagoons will be bordered
by groves rather than bare land. In addition, the security fence around the perimeter of the
treatment and disposal facility is expected to exclude larger non-native mammalian predators
including dogs and wild pigs.
For the first year following completion of construction, the County will provide for a biological
monitor to assess waterbird use of the facility on a weekly basis. Weekly post-construction
monitoring will include checking for predators, sick or dead waterbirds, and the presence of
threatened and endangered species. Following the completion of construction, the County will
coordinate with FWS to determine the specific approach for communicating the monitoring results.
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December 21, 2018
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Seabirds
Potential impacts to Hawaiian Petrel, Band-rumped Storm-Petrel, and Newell's Shearwater from
the construction and operation of the project include potential adverse effects resulting from
nighttime lighting at the facility. Outdoor, nighttime lighting during construction and operation of
the facility could result in seabird disorientation, fallout, and injury or mortality.
To avoid adverse impacts to seabirds during the construction period, the construction contract will
include a blanket statement prohibiting construction activities after dark. To avoid impacts to
seabirds during the operation of the facility, the proposed facility includes use of a down-shielded
light exterior fixture mounted below the roof overhang. The light fixture near the headworks will
also be down-shielded. The exterior lights will be used at night only in the event of an emergency
that requires an immediate response. All fixtures will meet requirements for outdoor lighting as set
forth in Hawai'i Code Chapter 14 (General Welfare).
The FWS has identified eight federally-listed threatened and endangered species which have the
potential to occur in the vicinity of the project area. The impact avoidance and minimization
measures described above have been specifically developed for the project in consultation with
FWS. EPA has reviewed and concurred with the analysis conducted and proposed measures.
Therefore, on behalf of EPA and the County, we respectfully request concurrence from the FWS that
the project is not likely to adversely affect the eight federally-listed threatened and endangered
species which have the potential to occur in the vicinity of the project area.
We greatly appreciate your input during this consultation. If you have any questions, please feel
free to contact me at (703) 615-4371 or by email at patrick.goodwin@erg.com.
Summary
Sincerely,
Patrick Goodwin
Environmental Scientist
Enclosures
5 of 5
December 21, 2018
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Figure 1 - Project Location Map
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Figure 1. Project Location Map (Site 7)
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Figure 2. Preliminary Site Plan for New Wastewater Treatment and
Disposal Facility at Site 7
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25' WibE UTILITY
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1,000' WELL
SETBACK -
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TMK: (3) 9-6-002:018
42.5 ACRES /
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(27.6 ACRES)
"DISINFECTION
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KAMEHAMEHA SCHOOLS
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(o.5 Acres) ^—
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Figure 2. Preliminary Site Plan for New Wastewater Treatment and Disposal Facility at Site 7
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Pre-consultation Letter to FWS, March 15, 2018
-------
1 WILSON OKAMOTO
[corporation
I INNOVATORS•PLANNERS•ENGINEERS
10349-01
March 15,2018
Ms. Mary Abrams, Field Supervisor
U.S. Department of the Interior
Fish and Wildlife Service
300 Ala Moana Boulevard
Room 3-122, Box 50088
Honolulu, HI 96850
Subject: Draft Environmental Assessment, Pre-Assessment Consultation;
Pahala Community Large Capacity Cesspool Replacement
Pa'au'au, Ka'u, Hawai'i
Request for Comment
Dear Ms. Abrams:
Wilson Okamoto Corporation is preparing a Draft Environmental Assessment (EA) for the
County of Hawai'i Department of Environmental Management Pahala Community Large
Capacity Cesspool Replacement, Pa'au'au, Ka'u, Hawai'i project. The Pahala Community
Large Capacity Cesspool Replacement project will be funded by a U.S. Environmental
Protection Agency (EPA) Special Appropriation Grant and by the State of Hawaii Clean Water
State Revolving Fund (SRF) loan program. A project summary sheet and location map are
enclosed for your information.
As part of the Draft EA pre-assessment consultation process, we are soliciting comments you
may have on the proposed Pahala Community Large Capacity Cesspool Replacement project.
Please submit your comments to:
Wilson Okamoto Corporation
1907 South Beretania Street, Suite 400
Honolulu, Hawaii 96826
Attn: Earl Matsukawa, AICP
We would appreciate your comments by April 16, 2018. If you have any questions, please call
me at 808.946.2277 or fax to 808.946.2253.
Project Manager
Enclosures
cc: D. Beck, DEM (w/o encl.)
K. Rao, EPA (w/o encl.)
C. Lekven, PE, BC (w/o encl.)
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
cc: ^
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PROJECT SUMMARY
Pahala Community Large Capacity Cesspool Closure
Pa'au'au, Ka'u, island of Hawai'i
Tax Map Key: 9-6-002:018
1. Introduction
The community of Pahala is located about 52 miles southeast of Hilo, in the Ka'u District, Island of
Hawai'i. Pahala is located west (mauka) of Mamalahoa Highway (State Route 11) about 3.8 miles
from the shoreline with most of the community lying between 980 feet mean sea level (msl) on the
western end and approximately 800 feet msl on the eastern end. See Figure 1. The Pahala
community had its start in 1876 with establishment of the Hawaiian Agricultural Company to develop
the sugar industry in Hawai'i. For the next 120 years or so, Pahala was a major sugar producing area.
However, by the early 1990s there was a major downturn in the sugar market. Thus, beginning in
1994, the sugar mill in the town was shut down and dismantled. By 1996, the Ka'u Sugar Company,
the successor to the Hawaiian Agricultural Company, closed and, subsequently, the sugar cane fields
were cleared and the lands now grow macadamia nut and coffee trees. The population in Pahala was
approximately 1,405 persons in 2016, the most current estimate.
Founded in 1826, C. Brewer was both the oldest company in Hawai'i and a major developer of the
sugar industry in Pahala. For about the last 60 years, approximately 50 percent of the residential
units in Pahala have been serviced by a wastewater collection and disposal system constructed,
operated and maintained by C. Brewer. The collection system consisted of sewer lines, some of
which were located in the streets and others routed in the backyards of private parcels. The disposal
system consisted of two large capacity cesspools (LCCs) within the community.
In 1998, the US Environmental Protection Agency (EPA) issued regulations (40 CFR 144.14) requiring
the elimination or closure of all large capacity cesspools used for wastewater disposal by April 5,
2005. In 2003, C. Brewer requested assistance from the County to close their LCCs. Subsequently,
the County held a community meeting to present sewer system replacement alternatives. Voting took
place by mail to choose the preferred sewer improvement alternative, resulting in 87 percent of
returned ballots in favor of installing a new sewer collection, treatment and disposal system to be
operated and maintained by the County.
In 2006, in anticipation of its dissolution, C. Brewer requested the County construct and maintain a
new community sewer system. The County subsequently agreed by way of a County Council
Resolution, to enter into a formal agreement to assume ownership of the C. Brewer constructed
collection system and the two LCCs by April 30, 2010 and to construct and maintain a new community
sewer system. As part of the County's agreement, C. Brewer agreed to install laterals to certain of the
residential properties.
In 2007, the County proposed a new collection system and a wastewater treatment system, consisting
of large capacity septic tanks and converting the existing LCCs into seepage pits for disposal of the
treated effluent. In 2008, the combination of the LCCs being in poor and failing condition and the poor
results from soil percolation tests influenced the County to consider acquiring a larger land area to
construct a secondary treatment system. Such a system could allow a higher level of wastewater
treatment and disposal, as well as accommodate existing Pahala properties not currently served by
the LCC system in addition to expanding the system to accommodate possible community growth.
2. Project Description
The County of Hawai'i. Department of Environmental Management (DEM) is proposing to construct
wastewater system improvements to replace the current system servicing Pahala, now owned by the
County. The wastewater system improvements would allow the County to comply with EPA
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PROJECT SUMMARY
Pahala Community Large Capacity Cesspool Closure
Pa'au'au, Ka'u, island of Hawai'i
Tax Map Key: 9-6-002:018
regulations requiring closure of the LCCs and to construct a system meeting current State of Hawai'i
Department of Health (DOH) and DEM design guidelines for the collection, treatment and disposal of
the treated effluent. The Pahala Community Large Capacity Cesspool Closure project improvements
would consist of a new wastewater collection system located within the public right-of-way and a
treatment and disposal system located on a currently privately-owned parcel (TMK: 9-6-002: 018)
which will be acquired by the County. The Pahala Community Large Capacity Cesspool Closure
project would be funded by an EPA Special Appropriation Grant and by the State of Hawai'i Clean
Water State Revolving Fund (SRF) loan program.
The wastewater collection system would be located within 7 public streets; Maile Street; 'llima Street;
Huapala Street; HTnano Street; Hala Street; all located in the southern portion of the community and
Puahala Street; and PTkake Street located on the eastern end. These streets serve the residential
areas and have two travel lanes with unpaved shoulders and no improved sidewalks. The collection
system would consist of approximately 11,000 linear feet of gravity flow piping ranging from 8 to 12
inches in diameter. The collection system is not anticipated to include pump stations, nor will the
system collect stormwater runoff. The number of manholes in the system will be determined during
the detail design phase. The County's sewer standards show the trenches for sewer lines would
require at least 4 feet of cover from the top of the pipe to grade and 12 inches of cushion material on
both sides of the line and 6 inches below the line. Therefore, the typical sewer trenches will be 3 feet
wide and at least 6 feet deep.
The treatment and disposal system would be a land-based system located southeast of the developed
community and would be designed to treat flows of approximately 190,000 gallons per day. The EPA
defines land treatment as "the application of appropriately pre-treated municipal and industrial
wastewater to the land at a controlled rate in a designed and engineered setting. The purpose of
the activity is to obtain beneficial use of these materials, to improve environmental quality, and to
achieve treatment goals in a cost-effective and environmentally sound manner".
The proposed treatment and disposal system would occupy about 14 acres and consist of a
headworks with screens to remove debris and an odor control unit, four lined aerated lagoons of
about 0.3 acres each, an operations building with adjacent disinfection system to remove pathogens,
a subsurface flow constructed polishing wetland to remove nitrogen and four slow rate (SR) land
treatment basins which will be surrounded by berms on all four sides. SR land treatment involves
irrigation of land and vegetation with the treated effluent. Significant additional treatment is
provided as the water percolates through the soil. The vegetation uptakes the nutrients in the
effluent as fertilizer, and transpires a portion of the applied water. A security fence will be
constructed along the perimeter of the site.
3. Anticipated Impacts
Project impacts would be primarily related to construction of the trenches for placement of the
collection system lines and construction of the land-based treatment and disposal system. These
activities would create dust and noise while work occurs in the streets and in the area of the land
treatment and disposal system, which will include removal of existing macadamia nut trees within the
14 acre project site. As the collection system is constructed, the streets will be restored for vehicle
travel. Upon completion of the treatment and disposal facilities, the project will operate without the
need for DEM employees to be on-site. Weekly monitoring visits will be sufficient to insure routine
proper operation, and a telemetry system will alert DEM employees of abnormal conditions to allow
timely response when they occur.
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FIGURE 1
PROJECT LOCATION MAP
PAHALA COMMUNITY LARGE CAPACITY CESSPOOL CLOSURE PROJECT
COUNTY OF HAWAII DEPARTMENT OF ENVIRON MENTAL MANAGMENT
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Pre-consultation Comments from FWS, April 23, 2018
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United States Department of the Interior
FISH AND WILDLIFE SERVICE
Pacific Islands Fish and Wildlife Office
300 Ala Moana Boulevard
Honolulu, Hawaii 96850
In Reply Refer To:
01EPIF00-2018-TA-0275 April 23, 2018
Mr. Earl Matsukawa, AICP
Project Manager
Wilson Okamoto Corporation
1907 South Beretania Street, Suite 400
Honolulu, HI 96826
Subject: Comments for the Draft Environmental Assessment for the County of Hawaii
Department of Environmental Management Pahala Community Large Capacity
Cesspool Replacement, Paauau, Kau, Island and County of Hawaii
Dear Mr. Matsukawa:
U.S.
FISH & WILDLIFE
SERVICE
The U.S. Fish and Wildlife Service (Service) received your correspondence on April 9, 2018,
requesting technical assistance in the preparation for the Draft Environmental Assessment for the
County of Hawaii Department of Environmental Management Pahala Community Large
Capacity Cesspool (LCC) Replacement in Paauau, Kau, (TMK: 9-6-002: 018). The Service
offers the following comments to assist you in your planning process so that impacts to trust
resources can be avoided through site preparation, construction, and operation. Our comments
are provided under the authorities of the Endangered Species Act of 1973 (ESA), as amended (16
U.S.C 1531 etseq.).
The County of Hawaii Department of Environmental Management (DEM) is proposing to
construct wastewater system improvements to replace the current system servicing Pahala, now
owned by the County. The wastewater system improvements would allow the County to comply
with Environmental Protection Agency (EPA) regulations requiring closure of the LCC's and to
construct a system meeting current State of Hawaii Department of Health and DEM design
guidelines for the collection, treatment, and disposal of the treated effluent. The Pahala
Community LCC closure project improvements would consists of a new wastewater collection
system located within the public right-of-way and a treatment and disposal system located on a
currently privately-owned parcel which would be acquired by the County. The Pahala LCC
closure project would be funded by the EPA Special Appropriation Grant and by the State of
Hawaii Clean Water State Revolving Fund loan program.
Based on information you provided and pertinent information in our files, including data
compiled by the Hawaii Biodiversity and Mapping Project, eight (8) listed species that have the
potential to either be in or fly through the vicinity of the project area: The federally endangered
Hawaiian hoary bat (Lasiurus cinereus semotus), Hawaiian hawk (Buteo solitarius), Nene
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Mr. Earl Matsukawa
2
Branta (=Nesochen) sandvicensis)), Hawaiian petrel (Pterodroma sandwichensis), Band-rumped
storm-petrel (Oceanodroma castro), the threatened Newell's shearwater (Puffinus auricularis
newelli), Hawaiian stilt (Himantopus mexicanus knudseni), and the Hawaiian coot, (Fulica alai).
Avoidance and Minimization Measures
Hawaiian hoary bat
The Hawaiian hoary bat roosts in both exotic and native woody vegetation across all islands and
will leave young unattended in trees and shrubs when they forage. If trees or shrubs 15 feet or
taller are cleared during the pupping season, there is a risk that young bats could inadvertently be
harmed or killed since they are too young to fly or may not move away. Additionally, Hawaiian
hoary bats forage for insects from as low as three feet to higher than 500 feet above the ground
and can become entangled in barbed wire used for fencing.
To avoid and minimize impacts to the endangered Hawaiian hoary bat we recommend
incorporating the following applicable measures into your project description:
• Do not disturb, remove, or trim woody plants greater than 15 feet tall during the bat
birthing and pup rearing season (June 1 through September 15).
• Do not use barbed wire for fencing.
Hawaiian hawk
The Hawaiian hawk is known to occur across a broad range of forest habitats throughout the
Island of Hawaii. Loud, irregular and unpredictable activities, such as using heavy equipment or
building a structure, near an endangered Hawaiian hawk nest may cause nest failure.
Harassment of Hawaiian hawk nesting sites can alter feeding and breeding patterns or result in
nest or chick abandonment. Nest disturbance can also increase exposure of chicks and juveniles
to inclement weather or predators.
To avoid and minimize impacts to Hawaiian hawks we recommend you consider incorporating
the following applicable measures into your project description:
• If work must be conducted during the March 1 through September 30 Hawaiian hawk
breeding season, have a biologist familiar with the species conduct a nest search of the
project footprint and surrounding areas immediately prior to the start of construction
activities.
o Pre-disturbance surveys for Hawaiian hawks are only valid for 14 days. If
disturbance for the specific location does not occur within 14 days of the survey,
conduct another survey.
• No clearing of vegetation or construction activities within 1,600 feet of any active
Hawaiian hawk nest during the breeding season until the young have fledged.
• Regardless of the time of year, no trimming or cutting trees containing a hawk nest, as
nests may be re-used during consecutive breeding seasons.
Nene
Nene are found on the islands of Hawaii, Maui, Molokai, and Kauai predominately, with a small
population on Oahu. They are observed in a variety of habitats, but prefer open areas, such as
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Mr. Earl Matsukawa
3
pastures, golf courses, wetlands, natural grasslands and shrublands, and lava flows. Threats to the
species include introduced mammalian and avian predators, wind facilities, and vehicle strikes.
To avoid and minimize potential project impacts to Nene we recommend incorporating the
following applicable measures into your project description:
• Do not approach, feed, or disturb Nene.
• If Nene are observed loafing or foraging within the project area during the Nene breeding
season (September through April), have a biologist familiar with the nesting behavior of
Nene survey for nests in and around the project area prior to the resumption of any work.
Repeat surveys after any subsequent delay of work of three or more days (during which
the birds may attempt to nest).
o Cease all work immediately and contact the Service for further guidance if a
nest is discovered within a radius of 150 feet of proposed work, or a
previously undiscovered nest is found within said radius after work begins.
• In areas where Nene are known to be present, post and implement reduced speed limits,
and inform project personnel and contractors about the presence of endangered species
on-site.
Hawaiian petrel, Band-rumped storm-petrel, and Newell's shearwater
Hawaiian seabirds may traverse the project area at night during the breeding, nesting and
fledging seasons (March 1 to December 15). Outdoor lighting could result in seabird
disorientation, fallout, and injury or mortality. Seabirds are attracted to lights and after circling
the lights they may become exhausted and collide with nearby wires, buildings, or other
structures or they may land on the ground. Downed seabirds are subject to increased mortality
due to collision with automobiles, starvation, and predation by dogs, cats, and other predators.
Young birds (fledglings) traversing the project area between September 15 and December 15, in
their first flights from their mountain nests to the sea, are particularly vulnerable.
To avoid and minimize potential project impacts to seabirds we recommend you incorporate the
following applicable measures into your project description:
• Fully shield all outdoor lights so the bulb can only be seen from below bulb height and
only use when necessary.
• Install automatic motion sensor switches and controls on all outdoor lights or turn off
lights when human activity is not occurring in the lighted area.
• Avoid nighttime construction during the seabird fledging period, September 15 through
December 15.
Hawaiian stilt and Hawaiian coot
Listed Hawaiian waterbirds are found in fresh and brackish-water marshes and natural or man-
made ponds. Hawaiian stilts may also be found wherever ephemeral or persistent standing water
may occur. Threats to these species include non-native predators, habitat loss, and habitat
degradation.
Based on the project details provided, our information suggests that your project may result in
standing water or the creation of open water, thus attracting Hawaiian waterbirds to the site. In
particular, the Hawaiian stilt is known to nest in sub-optimal locations (e.g. any ponding water),
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Mr. Earl Matsukawa
4
if water is present. Hawaiian waterbirds attracted to sub-optimal habitat may suffer adverse
impacts, such as predation and reduced reproductive success, and thus the project may create an
attractive nuisance. Therefore, we recommend you work with our office during project planning
so that we may assist you in developing measures to avoid impacts to listed species (e.g.,
fencing, vegetation control, predator management).
To avoid and minimize potential project impacts to Hawaiian waterbirds we recommend you
incorporate the following applicable measures into your project description:
• In areas where waterbirds are known to be present, post and implement reduced speed
limits, and inform project personnel and contractors about the presence of endangered
species on-site.
• If water resources are located within or adjacent to the project site, incorporate applicable
best management practices regarding work in aquatic environments into the project
design.
• Have a biological monitor that is familiar with the species' biology conduct Hawaiian
waterbird nest surveys where appropriate habitat occurs within the vicinity of the
proposed project site prior to project initiation. Repeat surveys again within 3 days of
project initiation and after any subsequent delay of work of 3 or more days (during which
the birds may attempt to nest). If a nest or active brood is found:
o Contact the Service within 48 hours for further guidance,
o Establish and maintain a 100-foot buffer around all active nests and/or broods
until the chicks have fledged. Do not conduct potentially disruptive activities
or habitat alteration within this buffer.
Have a biological monitor that is familiar with the species' biology present on the project site
during all construction or earth moving activities until the chicks fledge to ensure that Hawaiian
waterbirds and nests are not adversely impacted.
Invasive Species
To avoid and minimize the risk of the road construction introducing harmful invasive pests
including coqui, ants, and weeds into the project sites, we recommend the following measures be
implemented by project contractors:
• Vehicles, machinery, and equipment must be thoroughly pressure washed and visibly free
of mud, dirt, plant debris, frogs and frog eggs, insects and other debris. A hot water wash
is preferred. Areas of particular concern include bumpers, grills, hood compartments,
areas under the battery, wheel wells, undercarriage, cabs, and truck beds.
• The interior and exterior of vehicles, machinery, and equipment must be free of rubbish
and food. The interiors of vehicles and the cabs of machinery must be vacuumed clean.
Floor mats will be sanitized with a solution of >70% isopropyl alcohol or a freshly mixed
10% bleach solution.
• All work vehicles, machinery, and equipment may be subject to inspection.
• Any vehicles, machinery, and equipment that do not pass inspection will be turned away.
• Staging areas must be kept free of invasive pests.
Minimize Spread of Rapid Ohia Death
Rapid Ohia Death (ROD), a newly identified disease, has killed large numbers of mature ohia
trees (Metrosideros polymorpha) in forests and residential areas of Hawaii Island. The disease is
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Mr. Earl Matsukawa
5
caused by a vascular wilt fungus (Ceratocystis fimbriata). Crowns of an affected tree turn
yellowish or brown within days to weeks and dead leaves typically remain on branches for some
time. All ages of ohia trees can be affected and can have symptoms of browning of branches or
leaves. As of early 2017 the disease has been confirmed in all districts except North and South
Kohala. Additional information on ROD can be found at:
http://www2.ctahr.hawaii.edu/forestry/downloads/ROD-trifold-03.2016.pdf and
http ://www2. ctahr. hawaii. edu/forestry/di sease/ohiawilt. html.
The following avoidance and minimization measures should be followed for projects working in
ohia forests or at sites with ohia trees on Hawaii Island:
1) A survey of the proposed project site should be conducted within two weeks prior to any
tree cutting to determine if there are any infected ohia trees. If infected ohia are suspected
at the site, the following agencies should be contacted for further guidance.
a. Service - please contact the name at the bottom of this letter.
b. Dr. J.B. Friday, University of Hawaii Cooperative Extension Service,
808-969-8254 orjbfriday@hawaii.edu
c. Dr. Flint Hughes, USDA Forest Service, 808-854-2617, fhughes@fs.fed.us
d. Dr. Lisa Keith, USDA Agriculture Research Service,
808-959-4357, Lisa.Keith@ars.usda.gov
2) Both prior to cutting ohia and after the project is complete:
a. Tools used for cutting infected ohia trees should be cleaned with a 70 percent
rubbing alcohol solution. A freshly prepared 10 percent solution of chlorine
bleach and water can be used as long as tools are oiled afterwards, as chlorine
bleach will corrode metal tools. Chainsaw blades should be brushed clean,
sprayed with cleaning solution, and run briefly to lubricate the chain.
b. Vehicles used off-road in infected forest areas should be thoroughly cleaned. The
tires and undercarriage of the vehicle should be cleaned with detergent if they
have travelled from an area with ROD or travelled off-road. Use a pressure
washer with soap to clean all soil off of the tires and vehicle undercarriage.
c. Shoes and clothing used in infected forests should also be cleaned. Shoes should
be decontaminated by dipping the soles in 70 percent rubbing alcohol to kill the
ROD fungus. Other gear can be sprayed with the same cleaning solutions.
Clothing can be washed in hot water and detergent.
d. Wood of affected ohia trees should not be transported to other areas of Hawaii
Island or interisland. All cut wood should be left on-site to avoid spreading the
disease. The pathogen may remain viable for over a year in dead wood. The
Hawaii Department of Agriculture has passed a quarantine rule that prohibits
interisland movement, except by permit, of all ohia plant or plant parts.
If this project should receive federal funding, federal permit, or any federal authorization, it will
require a Section 7 consultation with the Service. The Service only conducts Section 7
consultations with the federal action agency or their designated representative.
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Mr. Earl Matsukawa
6
Thank you for participating with us in the protection of our endangered species. If you have any
further questions or concerns regarding this consultation, please contact Eldridge Naboa, Fish
and Wildlife Biologist, 808-284-0037, e-mail: eldridge naboa@fws.gov. When referring to this
project, please include this reference number: 01EPIF00-2018-TA-0275.
Sincerely,
Jodi Charrier
Acting Island Team Leader
Maui Nui and Hawaii Island
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Non-Federal Representative Designation Letter to FWS, June 7, 2018
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, CA 94105-3901
JUN 0 7 2018
Jodi Charrier
Acting Island Team Leader
Maui Nui and Hawaii Island
Pacific Islands Fish and Wildlife Office
300 Ala Moana Boulevard
Honolulu, Hawaii 96850
SUBJECT: Designation of Non-Federal Representative under Section 7 of the
Endangered Species Act (Reference: 01EPIF00-2018-TA-0275)
Dear Ms. Charrier:
The U.S. Environmental Protection Agency Region 9 (EPA) awarded a Special Appropriation
Act Project (S AAP) grant to the County of Hawaii for the Pahala Community Large Capacity
Cesspool (LCC) Replacement Project. This project triggers the application of the National
Environmental Policy Act (NEPA) and numerous Federal cross-cutting authorities including the
Endangered Species Act (ESA).
Pursuant to 50 C.F.R. §402.08, a Federal agency may designate a non-Federal representative to
conduct informal consultation or prepare a biological assessment by giving notice to the Director
of such designation. In accordance with 50 C.F.R. §402.08, EPA hereby designates Eastern
Research Group, Inc. (ERG) to act on EPA's behalf when initiating the ESA consultation process
and prepare a biological assessment if needed in connection with the Pahala Community LCC
Replacement Project. Effective immediately, ERG may consult with the Fish and Wildlife
Service (FWS) to initiate the informal consultation process under Section 7 of the ESA, with
responsibilities described herein.
EPA requires, through grant provisions for federally-assisted SAAP projects, that grant
recipients implement such measures as are ultimately determined necessary or appropriate during
the ESA Section 7 consultation process to avoid adverse effects to listed species or adverse
modification of designated or proposed critical habitat. However, EPA will continue to be
ultimately responsible for compliance with the Section 7 requirements of the ESA and will
remain responsible for participating in the consultation process if:
• there is disagreement between relevant parties regarding the scope of the area of potential
effects, identification of endangered species or habitats, or evaluation of effects; or,
Printed on 100% Postconsumer Recycled Paper. Process Chlorine Free.
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• there is an objection from consulting parties or the public regarding findings or
determinations or the implementation of agreed provisions.
If you have any questions, please contact Kate Rao, Drinking Water Protection Section, at (415)
972-3533 or via email at rao.kate@epa.gov.
Assistant Director, Water Division
cc:
William Kurcharski, County of Hawaii
Dora Beck, County of Hawaii
2
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Biological Survey Report, August 16, 2018
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AECOS No. 1545
Biological survey for the Pahala Community
Large Capacity Cesspool Closure Project on lot
TMK: 9-6-002:018, Ka'u District, Hawaii Island
Prepared by:
AECOS, Inc.
45-939 Kamehameha Hwy, Suite 104
Kane'ohe, Hawai'i 96744-3221
August 16, 2018
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Biological survey for the Pahala Community
Large Capacity Cesspool Closure Project on lot
TMK: 9-6-002:018, Ka'u District, Hawai'i Island
August 16, 2018
Draft
AECOS No. 1545
Eric Guinther and Reginald David
AECOS, Inc.
45-939 Kamehameha Hwy, Suite 104
Kane'ohe, Hawai'i 96744
Phone: (808) 234-7770 Fax: (808) 234-7775 Email: guinther@aecos.com
Introduction
The Hawai'i County Department of Environmental Management, Wastewater
Division is proposing to construct a wastewater treatment and disposal system
("Project") to treat sewage collected in Pahala, Ka'u District. The treatment and
disposal system will be located on a property identified as TMK: 9-6-002:018,
north of the intersection of Hawaii Belt Road (Mamalahoa Highway) and Maile
Street. This report describes methods used and results of a biological survey
conducted in the Project area in August 2018. The primary purpose of the
survey was to determine whether any species currently proposed or listed as
threatened or endangered under either federal or state endangered species
statutes occur on, or could utilize resources within, the Project area.
Project and Site Descriptions
The WWTP site encompasses the lower, approximately 15 ac (6 ha) of the
subject parcel (TMK: 9-6-002:018). Presently the entire parcel is a macadamia
nut (Macadamia integrifolia) orchard, but with the margins and two narrow
windbreak tree lines dominated by other species of trees and herbaceous plants
dividing the orchard into northwest-southeast trending units. In addition to the
WWTP site, a proposed transmission pipe would be constructed to the
northwest through the orchard up to Maile Street. From Maile Street a
collection system is planned for many of the streets within Pahala town (see
Figure 1).
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Biological Surveys
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0 250 500 1.000 1,500 2.000
Figure 1. Project and survey areas marked in red, Pahala.
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Biological Surveys
PAhala WWTP (TMK: 9-6-002: 018)
Macadamia nut trees form a closed crown of dense leaf growth (see cover
photo), creating deep shade within most parts of the grove. The dominant
understoiy in these deeply shaded areas is germinating mac nut trees.
Methods
Botanical Survey
The botanical survey was undertaken on August 13, 2018 and entailed a
wandering pedestrian transect that traversed the subject property, including
the area extending north to Maile Road proposed for installation of a collector
main. A "windshield" survey was conducted along all the streets proposed for
the collection system beyond the surveyed parcel. Plant species were identified
as they were encountered and notations made in a field notebook, which was
used to develop qualitative abundance values for each species as the survey
progressed. On a strictly area basis, only macadamia nut trees, Guinea grass
[Megathyrsus maximus), and perhaps a couple of other species would have a
ranking above uncommon. So, abundance values in this report are relative to
areas that support species other than the macadamia nut trees, such as the road
verges and other areas surrounding the orchard, unmaintained areas within the
orchard, including narrow windbreak lanes that divide the orchard plots into
units. The survey period encompassed the early dry season, but most of the
vegetation was in a relatively healthy state (the orchard is irrigated as needed).
However, early in the dry season found most trees and shrubs absent fruit or
flower. This slight limitation did not compromise the discovery of native
species of plants.
Plant names used herein follow Manual of the Flowering Plants of Hawai'i
(Wagner, Herbst, & Sohmer, 1990; Wagner & Herbst, 1999) for native and
naturalized flowering plants, Hawaii's Ferns and Fern Allies (Palmer, 2003) for
ferns, and^4 Tropical Garden Flora (Staples & Herbst, 2005) for ornamental and
crop plants. More recent name changes for naturalized plant species follow
Imada (2012).
Avian Survey
Six avian count stations were sited roughly equidistant from each other, four
within the WWTP area and two along the collection pipe route upslope to Maile
Street. Stations were sited approximately 150 m (490 ft) apart from each other.
A single eight-minute avian point count was made at each of the count stations.
Field observations were made with the aid of Leica 8 X 42 binoculars and by
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Biological Surveys
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listening for vocalizations. The avian counts were conducted in the early
morning hours. Time not spent counting at point-count stations was used to
search the site for species and habitats not observed during the point counts.
Weather conditions were excellent with winds of between 1 and 5 kph and no
precipitation.
The avian phylogenetic order and nomenclature used in this report follows the
AOU Check-List of North American Birds (American Ornithologists' Union, 1998),
and the 42nd through the 59th supplements to the Check-List (American
Ornithologists' Union, 1998, 2000; Banks et al., 2002, 2003, 2004, 2005, 2006,
2007, 2008; Chesser et al., 2009, 2010, 2011, 2012, 2013, 2014, 2015, 2016,
2017,2018).
Mammalian Survey
With the exception of the endangered Hawaiian hoary bat (Lasiurus cinereus
semotus) or 'ope'ape'a, all terrestrial mammals currently found on the Island of
Hawai'i are alien species, and most are ubiquitous. The survey of mammals was
limited to visual and auditory detection, coupled with visual observation of scat,
tracks, and other animal sign. A running tally was kept of all terrestrial
mammalian species detected within the project area.
Results
Vegetation
Vegetation within the areas surveyed comprises a macadamia nut orchard of
mature trees, unmaintained areas dominated outside the orchard by Guinea
grass, lanes of windbreak trees oriented between orchard units, and (mostly)
mowed road verge areas. Within the orchard are scattered small plots of
ruderal herbaceous plants, in most cases dominated by nodeweed [Synedrella
nodiflora), but if generally only lightly shaded, a number of other herbaceous
species. The windbreak lanes consist of two rows of trees: silk oak (Grevelia
robusta) and paperbark (Melaleuca quinquenervia] and are used in orchard
maintenance to stack cut branches and logs. These lanes support many of the
herbaceous plants recorded from the orchard. The proposed sewerage
collection system will be installed along already paved roadways within Pahala.
The survey in these areas revealed the vegetation to be entirely maintained
yards of ornamental plants.
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Flora
A listing of the plant species recorded during the August 2018 survey is
provided as Table 1. In all, the listing has 52 species of vascular plants: 2 ferns,
one gymnosperm, and 49 species of angiosperms (flowering plants). Only two
species (4%) are regarded as native to the Hawaiian Islands and both are
indigenous (native, but also distributed elsewhere in the Pacific). Found in low
numbers are the ubiquitous, ruderal 'uhaloa (Waltheria indica) and the common
blue- or purple-flowered morning glory vine: koali 'awa (Ipomoea indica). Being
widely distributed indigenous species, neither is listed as threatened or
endangered or of any special concern.
Table 1. Plant species identified during the August 13, 2018 survey of
TMK: 9-6-002:018, Pahala, Ka'u District, Hawai'i.
Species listed by family
Common name
Status Abundance Notes
sword fern
FERNS
NEPHROLEPIDACEAE
Nephrolepis multiflora (Roxb.)
F.M. Jarrett ex C.V. Morton
PTERIDACEAE
Pityrogramma calomelanos (L.) silver fern
Link
Nat R
Nat R <1>
GYMNOSPERMS
ARAU C ARIAC EAE
Araucaria columnaris (G. Forst.)
J.D. Hook.
Cook pine
Nat O <1>
FLOWERING PLANTS
DICOTYLEDONS
AMERANTHACEAE
Amaranthus spinosus L.
APOCYNACEAE
Carissa macrocarpa (Ecklon) A.
de Cand.
Nerium oleander L.
ARALIACEAE
Schefflera actinophylla (Endl.)
Harms
ASTERACEAE (COMPOSITAE)
Ageratum conyzoides L.
spiny amaranth
natal plum
olreander
umbrella tree
maile hohono
Nat R
Orn
Orn
R
R
Nat U
Nat R <1>
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Table 1 (continued).
Species listed by family
Common name
Status Abundance Notes
Bidens pilosa L.
ki; beggartick
Nat
U
<2>
Calyptocarpus vialis Less.
—
Nat
0
<1>
Conyza bonariensis (L.) Cronq.
hairy horseweed
Nat
C
<2>
Crassocephalum crepidioides
Nat
R
(Benth.) S. Moore
Cyanthillium cinereum L.
little ironweed
Nat
U
<1>
Lactuca serriola L.
prickly lettuce
Nat
U
<1>
Indet.
ruderal weed
Nat
R
<3>
Synedrella nodiflora (L.) Gaertn.
nodeweed
Nat
AA
<2>
BASELLACEAE
Anredera cordifolia (Ten.) Steenis
Madeira vine
Nat
R
<3>
BRASSICACEAE
Lepidium virginicum L.
—
Nat
R
<2>
CAPPARACEAE
Cleome gynandra L.
wild spider flower
Nat
0
<1>
CONVOLVULACEAE
Ipomoea indica (J. Burm.) Merr.
koali 'awa
Ind
R
Ipomoea obscura (L.) Ker-Gawl.
...
Nat
0
Merremia tuberosa (L.) J. Rendle
wood rose
Nat
R
CUCURBITACEAE
Momordica charantia L.
wild bitter melon
Nat
0
EUPHORBIACEAE
Euphorbia heterophylla L.
kaliko
Nat
U
<1>
Euphorbia hirta L.
garden spurge
Nat
0
<2>
Ricinus communis L.
castor bean
Nat
C
<2>
FABACEAE
Acacia confusa Merr.
Formosan koa
Nat
R
Leucaena leucocephala (Lam.)
koa haole
Nat
R
<2>
deWit
Macroptilium atropurpureum
Nat
U
<1>
(DC.) Urb.
Neonotonia wightii (Wight &
glycine vine
Nat
AA
<2>
Arnott) Lackey
LAMIACEAE
Leonotis nepetifolia (L.) R. Br.
lion's ear
Nat
0
<2>
MALVACEAE
Abutilon grandifolium (Willd.)
Sweet
hairy abutilon
Nat
R
Malvastrum coromandelianum
false mallow
Nat
0
<2>
(L.) Garcke
Sida rhombifolia L.
Cuba jute
Nat
C
<2>
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Table 1 (continued).
Species listed by family
Common name
Status Abundance Notes
MALVACEAE (cont.)
Sida spinosa L.
Waltheria indica L.
MORACEAE
Ficus microcarpa L. f.
MYRTACEAE
Melaleuca quinquenervia (Cav.)
S.T. Blake
Syzygium cumini (L.) Skeels
PHYTOLACCACEAE
Rivina humilis L.
PROTEACEAE
Grevillea robusta A. Cunn. ex R.
Br.
Macadamia integrifolia Maiden &
Berche
RUBIACEAE
Spermacoce assurgens Ruiz & Pav.
prickly sida
'uhaloa
Chinese banyan
paperbark
Java plum
coral berry
silk oak
macadamia nut
buttonweed
Nat
Ind
R
U
Nat R <2>
Nat C
Nat U <2>
Nat U
Nat
Nat AA
<2>
Nat
<1>
MONOCOTYLEDONS
COMMELINACEAE
Commelina benghalensis L.
CYPERACEAE
Cyperus gracilis R. Br.
POACEAE
Axonopus compressus (Swartz) P.
Beauv.
Cenchrus purpureus (Schumach.)
Morrone
Chloris barbata (L.) Sw.
Digiteria sp.
Eleusine indica (L.) Gaertn.
Megathyrsus maximus Jacq.
Setaria verticillata (L.) P. Beauv.
hairy honohono
McCoy grass
brd.-lvd. carpet
grass
elephant grass
swollen fingergrass
wiregrass
Guinea grass
bristly foxtail
Nat R <1>
Nat U
Nat
Nat
Nat
Nat
Nat
Nat
Nat
U
R
R
A
AA
R
<1>
<2>
<2>
Legend to Table 1:
Status = distributional status
Ind = indigenous; native to Hawai'i, but not unique to the Hawaiian Islands.
Nat = naturalized, exotic, plant introduced to the Hawaiian Islands since the arrival of
Cook Expedition in 1778 and well-established outside of cultivation.
Orn = ornamental; crop or landscape plant not established outside of cultivation.
Abundance = occurrence ratings for plants on property in July 2013.
R - Rare - only one or two plants seen.
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Table 1 - Legend (continued).
U - Uncommon - several to a dozen plants observed.
0 - Occasional - found regularly, but not abundant anywhere.
C - Common - considered an important part of the vegetation and observed numerous
times.
A - Abundant - found in large numbers; may be locally dominant.
AA - Abundant - very abundant and dominant; defining vegetation type.
Notes:
<1> Characteristic or found only in the road verge immediately adjacent to the site.
<2> Species also reported from close by in David & Guinther (2013).
<3> Plant lacking flowers or fruit at time of survey; identification uncertain.
Avian Survey
A total of 175 individual birds of 13 species, representing nine separate families,
was recorded during station counts (Table 2). Avian diversity and densities
were very low, in keeping with the current usage of the site as a mature
macadamia nut orchard, with minimal ground cover and few weedy or shrubby
species. A closed canopy keeps areas beneath the trees in perpetual twilight.
Four species, Northern Cardinal (Cardinalis cardinalis), Japanese White-eye
(Zosterops japonicus), Yellow-fronted Canary (Ceithagra mozambica), and Red-
billed Leiothrix (Leiothrix luted), accounted for 52% of all birds recorded during
station counts. The most frequently recorded species was Northern Cardinal,
which accounted for 16% of the total number of individual birds recorded
during station point counts. All of the species recorded during the course of this
survey are established alien species.
Table 2. Avian species detected during point-counts for
the Pahala Community WWTP Project
Common Name
Scientific Name
ST RA
Wild Turkey
PHASIANIDAE - Pheasants & Partridges
Meleagridinae -Turkeys
Meleagris gallopavo
2.00
Spotted Dove
Zebra Dove
COLUMBIFORMES
COLUMBIDAE - Pigeons & Doves
Streptopelia chinensis
Geopelia striata
A
A
3.17
2.00
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Table 2 (continued).
Common Name
Scientific Name
ST
RA
PASSERIFORMES
ZOSTEROPIDAE - White-eyes
Japanese White-eye
Zosterops japonicus
A
3.67
TIMAUIDAE- Babblers
Chinese Hwamei
Garrulax canorus
A
2.00
Red-billed Leiothrix
Leiothrix lutea
A
3.33
STURNIDAE-Starlings
Common Myna
Acridotheres tristis
A
0.17
FRINGILUDAE - Fringilline and Carduline Finches & Allies
Carduelinae - Carduline Finches and Hawaiian
Honeycreepers
House Finch
Haemorhous mexicanus
A
1.33
Yellow-fronted Canary
Ceithagra mozambica
A
1.50
CARDINAUDAE-Cardinals & Allies
Northern Cardinal
Cardinalis cardinalis
A
4.67
THRAUPIDAE - Tanagers
Thraupinae - Core Tanagers
Yellow-billed Cardinal
Paroaria capitata
A
1.50
Saffron Finch
Sicalisflaveola
A
1.67
ESTRILDIDAE - Estrildid Finches
Scaly-breasted Munia
Lonchura punctulata
A
0.17
Key to Table 2
ST Status.
A Alien - Introduced to the Hawaiian Islands by humans.
RA Relative Abundance - Number of birds detected divided by the number of count stations (6].
Mammalian Survey
Rather remarkably, we recorded no mammalian species within the survey area.
Indeed, there was no indication that pigs (Sus scrofa) utilize the Project area.
Discussion
Botanical Resources
Although some unmaintained or infrequently maintained areas exist on the
subject parcel, the entire Project is proposed for land that is highly modified and
the flora present subject to alterations, including mowing. Thus, there is no
expectation for the site to support remnants of a native forest flora and minimal
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opportunity for native plants to become established, the 'uhaloa and koali 'awa
being exceptions due to their ability to grow in highly disturbed environments.
A previous biological survey (David and Guinther, 2013) conducted on 5 ac (2
ha) of land close by to the east yielded only 25 species of plants, the most
abundant being white shrimp plant (Justicia betonica), glycine vine, and Guinea
grass. Because that area had been highly disturbed, then not disturbed for a
long time, species such as the shrimp plant and particularly Guinea grass had
become well-established to the exclusion of other species. Sixteen species (24%
of the combined species list) were common to both surveys.
Obviously, the macadamia nut orchard is a valuable botanical resource, but a
commercial one and not an environmentally sensitive one. The same can be
said for the Cook pines (Araucaria columnaris) that line Maile Street along the
southwestern side of the parcel. These old trees are an important community
landscape element to be retained in place by the Project.
Avian Resources
The findings of the avian survey are consistent with the location of the site, and
the monoculture of macadamia nut trees present on it. No native avian species
were recorded during the course of this survey.
Although not detected during this survey, endemic Hawaiian Petrel
(Pterodroma sandwichensis) and Newell's Shearwater [Puffinus newelli) have
been recorded over-flying the general Project area between April and the end of
November each year. The petrel is listed as endangered, and the shearwater as
threatened under both federal and State of Hawai'i endangered species statutes.
The primary cause of mortality in both Hawaiian Petrel and Newell's
Shearwater is thought to be predation by alien mammalian species at the
nesting colonies (USFWS, 1983; Simons and Hodges, 1998; Ainley et al., 2001).
Collision with man-made structures is considered to be second-most significant
cause of mortality of these seabirds in Hawai'i. Nocturnally flying seabirds,
especially fledglings on their way to sea in the summer and fall, can become
disoriented by exterior lighting. When disoriented, seabirds can collide with
man-made structures and, if not killed outright, dazed or injured birds become
prey to feral mammals (Hadley, 1961; Telfer, 1979; Sincock, 1981; Reed et al.,
1985; Telfer et al., 1987; Cooper and Day, 1998; Podolsky et al., 1998; Ainley et
al., 2001; Hue et al., 2001; Day et al., 2003). Neither nesting colonies nor
appropriate nesting habitat for either of these listed seabird species occur
within or close to the current Project site.
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Mammalian Resources
No Hawaiian hoary bats were detected during the course of this survey. It is
possible that bats use resources within orchard part of the Project. Although,
no rodents were recorded during the course of this survey, it is likely that one
or more of the four alien Muridae established on Hawai'i Island—European
house mouse (Mus musculus domesticus], roof rat (Rattus rattus), brown rat
[Rattus norvegicus), and black rat (Rattus exulans hawaiiensis]—use various
resources found within the general Project area on a seasonal basis, especially
in the macadamia nut orchard. These human commensal species are drawn to
areas of human habitation and activity and all are deleterious to native
ecosystems and their dependent native fauna.
Jurisdictional Waters
The subject parcel slopes down to the southwest corner. A street culvert at that
location carries runoff in the area under Mamalahoa Highway (Hawaii Belt
Road). The National Wetlands Inventory (NWI) Wetlands Mapper (USFW, nd
(a)) shows no features occurring on the parcel and no streams are shown on
USGS topographic maps (USGS, 1923). Streams in the Pahala area of the Island
do not flow all the way to the sea, but terminate on Keone'ele'ele Flat to the
southwest.
Critical Habitat
Federally delineated Critical Habitat is not present in Pahala area (USFWS,
2012). Thus, the Project will not impinge on federally designated Critical
Habitat. No equivalent designation exists under state law
Potential Impacts to Protected Species
No species of plants or animals currently proposed for listing or listed under
either the federal or State of Hawai'i endangered species statutes (DLNR 1998,
2015; USFWS, nd (b)) were recorded by this survey. Three faunal species not
observed, may occur in the general vicinity and are discussed here.
Seabirds
The principal potential impact that the construction of the project poses to
protected seabirds is the increased threat that birds will be downed after
becoming disoriented by lights associated with the proposed action during the
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nesting season. The two activities that could pose a threat to these nocturnally
flying seabirds are: a) if during construction, it is deemed expedient or
necessary to conduct night-time construction activities during the seabird
fledging season (which runs from September 15 through December 15); or b)
exterior lighting is installed as part of the WWTP facilities. Impacts can be
minimized if all external lighting is made dark sky compliant (HDLNR-DOFAW,
2016).
Hawaiian hoary bat
The potential impact that Project construction poses to the endangered
Hawaiian hoary bat would be from clearing and grubbing of the macadamia nut
orchard. Trimming or removal of trees within the construction areas may
temporarily displace bats using this vegetation for roosting. Hawaiian bats use
multiple roosts within their home territories, so the disturbance resulting from
removal of trees is likely to be minimal. However, during pupping season,
female bats carrying pups may be less able to rapidly vacate a roost site when
the tree is felled. Additionally, adult female bats sometimes leave their pups in
the roost tree while they themselves forage, and very small pups may be unable
to flee a tree that is being felled. Adverse effects from such disturbance can be
avoided or minimized by not clearing woody vegetation taller than 4.6 m (15 ft),
between June 1 and September 15, the bat pupping season.
References
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and Population Trends of the Newell's Shearwater on Kaua'i: Insights
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Quadrangle.
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Summary of Biological Survey Report, August 20, 2018
-------
WILSON OKAMOTO
CORPORATION
INNOVATORS - PLANNERS ¦ ENGINEERS
10349-01
August 20, 2018
Ms. Jodi Charrier, Acting Team Leader
Maui Nui and Hawaii Island
Fish and Wildlife Service
U.S. Department of the Interior
300 Ala Moana Boulevard
Room 3-122, Box 50088
Honolulu, HI 96850
Attention: Eldridge Naboa, Fish and Wildlife Biologist
Subject: Draft Environmental Assessment, Pre-Assessment Consultation;
Pahala Community Large Capacity Cesspool Replacement
Pa'au'au, Ka'u Ka'u, Hawai'i
Response to Comment (01EPIF00-2018-TA-0275)
Dear Ms. Charrier:
Thank you for your April 23, 2018 comment letter (01EPIF00-2018-TA-0275) and the April 10,
2018 e-mail message from Eldridge Naboa regarding the County of Hawai'i Department of
Environmental Management Pahala Community Large Capacity Cesspool Replacement project.
As stated in the Project Summary, the Pahala Community Large Capacity Cesspool Replacement
project would be funded by an Environmental Protection Agency (EPA) Special Appropriation
Grant and by the State of Hawai'i Clean Water State Revolving Fund (CSRF) loan program. As
such, we understand consultation will need to be conducted by a federal agency or by a
designated non-federal representative.
On June 7, 2018, EPA Region 9 Water Division, designated Eastern Research Group, Inc. (ERG)
as the non-federal representative for undertaking the consultation for this project.
As part of the Draft EA, in August 2018, botanical and biological field studies were undertaken
along the streets and adjacent areas of wastewater collection system and at the 14.9-acre
wastewater treatment and disposal facility project site. The results of the field surveys showed
the collection system will be installed along already paved roadways within Pahala. They also
revealed that vegetation is located entirely within yards and consist of ornamental plants.
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
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10349-01
Letter to Ms. Jodi Charrier, Acting Team Leader
Page 2
August 20, 2018
The field survey showed 52 species of vascular plants: 2 ferns, one gymnosperm, and 49 species
of angiosperms (flowering plants). Only two species (4%) are regarded as native to the
Hawaiian Islands and both are indigenous (native, but also distributed elsewhere in the Pacific).
Being widely distributed indigenous species, neither is listed as threatened or endangered or of
any special concern.
The avian survey recorded a total of 175 individual birds of 13 species, representing nine
separate families during station counts. Avian diversity and densities were very low, in keeping
with the current usage of the site as a mature macadamia nut orchard, with minimal ground cover
and few weedy or shrubby species. All of the species recorded during the course of the survey
are established alien species. No native avian species were recorded during the course of this
survey.
The field survey report indicated that, although not detected during the survey, the endemic
Hawaiian Petrel (Pterodroma sandwichensis) and Newell's Shearwater (Puffmus newelli) have
been recorded over-flying the general area between April and the end of November each year.
The petrel is listed as endangered, and the shearwater as threatened under both federal and State
of Hawai'i endangered species statutes.
No species of plants or animals currently proposed for listing or listed under either the federal or
State of Hawai'i endangered species statutes were recorded by the survey.
The Draft EA, will include a discussion of the avoidance and minimization measures as set forth
in your April 23, 2108 letter.
We appreciate your participation in the Draft EA process.
Vice President, Director - Planning
cc: D. Beck, DEM
K. Rao, EPA
B. Rosen, ERG
C. Lekven, PE, BC
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United States Department of the Interior
FISH AND WILDLIFE SERVICE
Pacific Islands Fish and Wildlife Office
300 Ala Moana Boulevard
Honolulu, Hawaii 96850
In Reply Refer To: February 15, 2019
01EPIF00-2018-TA-0275
01EPIF00-2019-1-0153
Mr. Patrick Goodwin
Environmental Scientist
14555 Avion Parkway, Suite 200
Chantilly, Virginia 20151 -1102
Subject: Informal Consultation for the Pahala Large Capacity Cesspool Replacement
Project; Pahala, Kau District, Island and County of Hawaii
Dear Mr. Patrick Goodwin:
The U.S. Fish and Wildlife Service (Service) received your correspondence on December 28,
2018, requesting our concurrence with your determination that the proposed Pahala Large
Capacity Cesspool Replacement Project, may affect but is not likely to adversely affect the
federally endangered Hawaiian hoary bat (Lasiurus cinereus semotus), Hawaiian Hawk (Buteo
solitarius), Hawaiian goose (Branta (=Nesochen) sandvicensis), Hawaiian Petrel (Pterodroma
sandwichensis), Band-rumped Storm-Petrel (Oceanodroma castro), Hawaiian Stilt
(Himantopus mexicanus knudseni). and Hawaiian Coot (Fulica alai), and the threatened
Newell's Shearwater (Puffinus newelli). This response is in accordance with Section 7 of the
Endangered Species Act (ESA) of 1973, as amended (16 U.S.C 1531 et seq.).
Project Description
The proposed project is located in Pahala, Kau District, Hawaii. Funding for this project is
provided by a Special Appropriation Grant from Environmental Protection Agency (EPA) and
a loan from the State of Hawaii Clean Water State Revolving Fund. The project involves
replacing two large-capacity cesspools (LCCs) with a new County-owned wastewater
collection system to be constructed primarily within the existing public right-of-way; a
treatment and disposal system that will occupy a 14.9-acre site that is currently a privately-
owned macadamia nut plantation; and closure of the two LCCs.
The proposed project is located in the community of Pahala, a former sugar farming and
processing operation, in the Kau District, Island of Hawaii. In 1999, pursuant to the Safe
Drinking Water Act, EPA promulgated regulations (40 CFR 144.14) requiring the elimination
or closure of all LCCs by April 2005. In 2010, the C. Brewer Company transferred the
ownership and operation of the LCCs to the County, which is bringing these wastewater
systems into compliance with the Safe Drinking Water Act.
a
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Mr. Patrick Goodwin
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Once the new system is in place, the County will close and abandon the existing LCCs. This
system includes some lines located in the backyards of residential lots and some within public
streets; therefore, abandoning the lines in place will minimize impacts related to their
excavation and removal. The cut ends of the abandoned laterals to the collection system will
be plugged with concrete to prevent unauthorized use of the old system and to avoid the need
to maintain an unused underground hydraulic conduit. The two LCCs will also be abandoned
and closed; the specific closure methods have not yet been determined but will be consistent
with the requirements set forth in Hawaii Administrative Rules §11-23-19.
Avoidance and Minimization Measures
Hawaiian hoary bat
The Hawaiian hoary bat roosts in both exotic and native woody vegetation across all islands and
will leave young unattended in trees and shrubs when they forage. If trees or shrubs 15 feet (ft)
or taller are cleared during the pupping season, there is a risk that young bats could inadvertently
be harmed or killed since they are too young to fly or may not move away. Additionally,
Hawaiian hoary bats forage for insects from as low as three feet to higher than 500 ft above the
ground and can become entangled in barbed wire used for fencing.
To avoid and minimize impacts to the Hawaiian hoary bat, the project:
• Will not disturb, remove, or trim woody plants greater than 15 ft tall during the bat
birthing and pup rearing season (June 1 through September 15).
• Will not use barbed wire for fencing.
Hawaiian hawk
The Hawaiian hawk is known to occur across a broad range of forest habitats throughout the
Island of Hawaii. Loud, irregular and unpredictable activities, such as using heavy equipment or
building a structure, near an endangered Hawaiian hawk nest may cause nest failure. Harassment
of Hawaiian hawk nesting sites can alter feeding and breeding patterns or result in nest or chick
abandonment. Nest disturbance can also increase exposure of chicks and juveniles to inclement
weather or predators.
To avoid and minimize impacts to Hawaiian hawks, the project:
• If work must be conducted during the March 1 through September 30 Hawaiian hawk
breeding season, a biologist familiar with the species will conduct a nest search of the
project footprint and surrounding areas immediately prior to the start of construction
activities.
o Pre-disturbance surveys for Hawaiian hawks are only valid for 14 days. If
disturbance for the specific location does not occur within 14 days of the survey,
another survey will be conducted.
• Will not clear vegetation or conduct construction activities within 1,600 ft of any active
Hawaiian hawk nest during the breeding season until the young have fledged.
• Regardless of the time of year, no trimming or cutting trees containing a hawk nest will
occur, as nests may be re-used during consecutive breeding seasons.
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Mr. Patrick Goodwin
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Hawaiian goose
Hawaiian goose are found on the islands of Hawaii, Maui, Molokai, and Kauai predominately,
with a small population on Oahu. They are observed in a variety of habitats, but prefer open
areas, such as pastures, golf courses, wetlands, natural grasslands and shrublands, and lava flows.
Threats to the species include introduced mammalian and avian predators, wind facilities, and
vehicle strikes.
To avoid and minimize impacts to the Hawaiian goose, the project:
• Will not approach, feed, or disturb Hawaiian goose.
• If Hawaiian goose are observed loafing or foraging within the project area during the
breeding season (September through April), a biologist familiar with the nesting behavior
will survey for nests in and around the project area prior to the resumption of any work.
Surveys will be repeated after any subsequent delay of work of three or more days
(during which the birds may attempt to nest).
o All work will cease immediately and the Service will be contacted for further
guidance if a nest is discovered within a radius of 150 ft of proposed work, or
a previously undiscovered nest is found within said radius after work begins.
• In areas where Hawaiian goose are known to be present, the project will post and
implement reduced speed limits, and inform project personnel and contractors about the
presence of endangered species on-site.
Hawaiian petrel, Band-rumped storm-petrel, and Newell's shearwater
Hawaiian seabirds may traverse the project area at night during the breeding, nesting and
fledging seasons (March 1 to December 15). Outdoor lighting could result in seabird
disorientation, fallout, and injury or mortality. Seabirds are attracted to lights and after circling
the lights they may become exhausted and collide with nearby wires, buildings, or other
structures or they may land on the ground. Downed seabirds are subject to increased mortality
due to collision with automobiles, starvation, and predation by dogs, cats, and other predators.
Young birds (fledglings) traversing the project area between September 15 and December 15, in
their first flights from their mountain nests to the sea, are particularly vulnerable.
To avoid and minimize potential project impacts to seabirds, the project:
• Will fully shield all outdoor lights so the bulb can only be seen from below bulb height
and only use when necessary.
• Will install automatic motion sensor switches and controls on all outdoor lights or turn
off lights when human activity is not occurring in the lighted area.
• Will avoid nighttime construction during the seabird fledging period, September 15
through December 15.
Hawaiian stilt and Hawaiian coot
Listed Hawaiian waterbirds are found in fresh and brackish-water marshes and natural or man-
made ponds. Hawaiian stilts may also be found wherever ephemeral or persistent standing water
may occur. Threats to these species include non-native predators, habitat loss, and habitat
degradation.
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Mr. Patrick Goodwin
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Based on the project details provided, our information suggests that your project may result in
standing water or the creation of open water, thus attracting Hawaiian waterbirds to the site. In
particular, the Hawaiian stilt is known to nest in sub-optimal locations (e.g. any ponding water),
if water is present. Hawaiian waterbirds attracted to sub-optimal habitat may suffer adverse
impacts, such as predation and reduced reproductive success, and thus the project may create an
attractive nuisance. Therefore, we recommend you work with our office during project planning
so that we may assist you in developing measures to avoid impacts to listed species (e.g.,
fencing, vegetation control, predator management).
To avoid and minimize potential impacts to waterbirds, the project:
• To discourage waterbird use of the facility, the subsurface-flow-constructed wetland will
not have areas of open water; asphalt rather than gravel will be used to provide access
around the lagoons; the lagoons will be lined with a high density polyethylyne liner,
rather than with substrate that would support vegetation growth; shade balls will be used
in the largest lagoon to discourage algal growth; and the lagoons will be bordered by
groves rather than bare land.
• The security fence around the perimeter of the treatment and disposal facility will
exclude larger non-native mammalian predators.
• In areas where waterbirds are known to be present, the project will post and implement
reduced speed limits, and inform project personnel and contractors about the presence of
endangered species on-site.
• If water resources are located within or adjacent to the project site, the project will
incorporate applicable best management practices regarding work in aquatic
environments into the project design.
• A biological monitor that is familiar with the species' biology will conduct waterbird nest
surveys where appropriate habitat occurs within the vicinity of the proposed project site
prior to project initiation. Surveys will be repeated again within 3 days of project
initiation and after any subsequent delay of work of 3 or more days (during which the
birds may attempt to nest). If a nest or active brood is found:
o The Service will be contacted within 48 hours for further guidance,
o Will establish and maintain a 100-ft buffer around all active nests and/or
broods until the chicks/ducklings have fledged. Will not conduct potentially
disruptive activities or habitat alteration within this buffer.
• A biological monitor that is familiar with the species' biology will be present on the
project site during all construction or earth moving activities until the chicks/ducklings
fledge to ensure that waterbirds and nests are not adversely impacted.
Minimize Spread of Rapid Ohia Death
Rapid Ohia Death (ROD), a newly identified disease, has killed large numbers of mature ohia
trees (Metrosideros polymorpha) in forests and residential areas of Hawaii Island. The disease is
caused by a vascular wilt fungus (Ceratocystis fimbriata). Crowns of an affected tree turn
yellowish or brown within days to weeks and dead leaves typically remain on branches for some
time. All ages of ohia trees can be affected and can have symptoms of browning of branches or
leaves. As of early 2017 the disease has been confirmed in all districts except North and South
Kohala. Additional information on ROD can be found at:
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Mr. Patrick Goodwin
5
http://www2.ctahr.hawaii.edu/forestry/downloads/ROD-trifold-03.2016.pdf and
http://www2.ctahr.hawaii.edu/forestry/disease/ohia_wilt.html.
The following avoidance and minimization measures should be followed for projects working in
ohia forests or at sites with ohia trees on Hawaii Island:
1) A survey of the proposed project site should be conducted within two weeks prior to any
tree cutting to determine if there are any infected ohia trees. If infected ohia are suspected
at the site, the following agencies should be contacted for further guidance.
a. Service - please contact the name at the bottom of this letter.
b. Dr. J.B. Friday, University of Hawaii Cooperative Extension Service,
808-969-8254 or jbfriday@hawaii.edu
c. Dr. Flint Hughes, USDA Forest Service, 808-854-2617, fhughes@fs.fed.us
d. Dr. Lisa Keith, USDA Agriculture Research Service,
808-959-4357, Lisa.Keith@ars.usda.gov
2) Both prior to cutting ohia and after the project is complete:
a. Tools used for cutting infected ohia trees should be cleaned with a 70 percent
rubbing alcohol solution. A freshly prepared 10 percent solution of chlorine
bleach and water can be used as long as tools are oiled afterwards, as chlorine
bleach will corrode metal tools. Chainsaw blades should be brushed clean,
sprayed with cleaning solution, and run briefly to lubricate the chain.
b. Vehicles used off-road in infected forest areas should be thoroughly cleaned. The
tires and undercarriage of the vehicle should be cleaned with detergent if they
have travelled from an area with ROD or travelled off-road. Use a pressure
washer with soap to clean all soil off of the tires and vehicle undercarriage.
c. Shoes and clothing used in infected forests should also be cleaned. Shoes should
be decontaminated by dipping the soles in 70 percent rubbing alcohol to kill the
ROD fungus. Other gear can be sprayed with the same cleaning solutions.
Clothing can be washed in hot water and detergent.
d. Wood of affected ohia trees should not be transported to other areas of Hawaii
Island or interisland. All cut wood should be left on-site to avoid spreading the
disease. The pathogen may remain viable for over a year in dead wood. The
Hawaii Department of Agriculture has passed a quarantine rule that prohibits
interisland movement, except by permit, of all ohia plant or plant parts.
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Mr. Patrick Goodwin
6
The Service has analyzed potential impacts to listed species due to the implementation of your
project. Based on the includsion of the avoidance and minimization measures listed above, the
Service anticipates that any potential impacts will be discountable or insignificant and therefore
we concur that the Pahala Large Capacity Cesspool Replacement Project may affect, but is not
likely to adversely affect the endangered Hawaiian hoary bat, Hawaiian Hawk, Hawaiian goose,
Hawaiian Petrel, Band-rumped Storm-Petrel, Hawaiian Stilt, and Hawaiian Coot, and the
threatened Newell's Shearwater.
Thank you for participating with us in the protection of our endangered species. If you have any
further questions or concerns regarding this consultation, please contact Eldridge Naboa, Fish
and Wildlife Biologist, 808-284-0037, e-mail: eldridge naboa@fws.gov. When referring to this
project, please include this reference number: 01EPIF00-2019-I-0153.
Sincerely,
Digitally signed
JODI byJODI
ru A DRIER
CHARRIER Date: 2019.02.15
15:06:51 -10'00'
Jodi Charrier
Acting Island Team Leader
Maui Nui and Hawaii Island
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Mr. Patrick Goodwin
7
BIOSECURTY PROTOCOLS - HAWAII ISLAND (JULY 2018)
The following biosecurity protocol (based on National Park Service, State of Hawaii, U.S. Fish
and Wildlife, U.S. Geological Survey, and the DOI Office of Native Hawaiian Relations
guidance) should be followed when operating on Hawaii Island to prevent the introduction of
harmful invasive species including frogs, ants, weeds, and fungi into local natural areas (e.g.,
Hawaii Volcanoes National Park, Hakalau Forest National Wildlife Refuge, State of Hawaii
"Natural Areas") and areas with native habitat (habitat that is primarily composed of native
vegetation), other islands in Hawaiian archipelago, or the U.S. mainland. The protocol also
includes suggestions for keeping field staff safe from certain invasive species.
1. All work vehicles, machinery, and equipment should be cleaned, inspected by its user,
and found free of mud, dirt, debris and invasive species prior to entry into the natural
areas or native habitat.
a. Vehicles, machinery, and equipment must be thoroughly pressure washed in a designated
cleaning area and visibly free of mud, dirt, plant debris, insects, frogs (including frog eggs) and
other vertebrate species such as rats, mice and non-vegetative debris. A hot water wash is
preferred. Areas of particular concern include bumpers, grills, hood compartments, areas under
the battery, wheel wells, undercarriage, cabs, and truck beds (truck beds with accumulated
material (intentionally placed or fallen from trees) are prime sites for hitchhikers).
b. The interior and exterior of vehicles, machinery, and equipment must be free of rubbish and
food. The interiors of vehicles and the cabs of machinery must be vacuumed clean. Floor mats
shall be sanitized with a solution of >70% isopropyl alcohol or a freshly mixed 10% bleach
solution.
c. Any machinery, vehicles, equipment, or other supplies found to be infested with ants (or other
invasive species) must not enter natural areas or native habitat. Treatment is the responsibility of
the equipment or vehicle owner and operator.
2. Little Fire Ants - All work vehicles, machinery, and equipment should be inspected for
invasive ants prior to entering the natural areas or native habitat.
a. A visual inspection for little fire ants should be conducted prior to entry into natural areas or
native habitat.
b. Hygiene is paramount but even the cleanest vehicle can pick up a little fire ant. Place
MaxForce Complete Brand Granular Insect Bait (1.0% Hydramethylnon;
http://littlefireants.com/Maxforce%20Complete.pdf) into refillable tamper resistant bait stations.
An example of a commercially available refillable tamper resistant bait station is the Ant Cafe
Pro Qittps://www.antcafe.com/). Place a bait station (or stations) in vehicle. Note larger vehicles,
such as trucks, may require multiple stations. Monitor bait stations frequently (every week at a
minimum) and replace bait as needed. If the station does not have a sticker to identify the
contents, apply a sticker listing contents to the station.
c. Any machinery, vehicles, equipment, or other supplies found to be infested with ants (or other
invasive species) must not enter natural areas or native habitat until it is sanitized and re-tested
following a resting period. Infested vehicles must be sanitized following recommendations by
the Hawaii Ant Lab (http://www.littlefireants.com/) or other ant control expert and in accordance
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Mr. Patrick Goodwin
8
with all State and Federal laws. Treatment is the responsibility of the equipment or vehicle
owner.
d. Gravel, building materials, or other equipment such as portable buildings should be baited
using MaxForce Complete Brand Granular Insect Bait (1.0% Hydramethylnon;
http://littlefireants.com/Maxforce%20Complete.pdf) or AmdroPro (0.73% Hydramethylnon;
http://littlefireants.com/Amdro%20Pro.pdf) following label guidance.
e. Storage areas that hold field tools, especially tents, tarps, and clothing should be baited using
MaxForce Complete Brand Granular Insect Bait (1.0% Hydramethylnon;
http://littlefireants.com/Maxforce%120Complete.pdf) or AmdroPro (0.73%> Hydramethylnon;
http://littlefireants.com/Amdro%20Pro.pdf) following label guidance.
3. Base yards and staging areas inside and outside areas must be kept free of invasive
species.
a. Base yards and staging areas should be inspected at least weekly for invasive species and any
found invasive removed immediately. Pay particular attention to where vehicles are parked
overnight, keeping areas within 10-meters of vehicles free of debris. Parking on pavement and
not under trees, while not always practical is best.
b. Project vehicles or equipment stored outside of a base yard or staging area, such as a private
residence, should be kept in a pest free area.
4. All cutting tools must be sanitized to prevent the Rapid Ohia Death (ROD) fungus.
a. Avoid wounding ohia trees and roots with mowers, chainsaws, weed eaters, and other tools.
Cut only the minimum amount of trees and branches as approved for the project.
b. All cutting tools, including machetes, chainsaws, and loppers must be sanitized to remove
visible dirt and other contaminants prior to entry into natural areas or areas with native habitat,
and when moving to a new project area within the native habitat area. Tools may be sanitized
using a solution of >70% isopropyl alcohol or a freshly mixed 10% bleach solution. One minute
after sanitizing, you may apply an oil based lubricant to chainsaw chains or other metallic parts
to prevent corrosion.
c. Only dedicated tools and chainsaws should be used to sample known or suspected ROD
infected trees.
d. Vehicles, machinery, and equipment must be cleaned as described in (1) above.
5. Imported firewood, logs, and ohia parts:
a. Ohia firewood, ohia logs, and ohia parts should not be transported.
6. For individuals working in the field:
a. Before going into the field, visually inspect and clean your clothes, boots, pack, radio
harness, tools and other personal gear and equipment, for seeds, soil, plant parts, insects, and
other debris. A small brush is handy for cleaning boots, equipment and gear. Soles of shoes
should be sanitized using a solution of >70% isopropyl alcohol or a freshly mixed 10% bleach
solution.
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Mr. Patrick Goodwin
9
b. Immediately before leaving the field, visually inspect and clean your clothes, boots, pack,
radio harness, tools, and other personnel gear and equipment, for seeds, soil, plant parts, insects,
and other debris. Soles of shoes should be sanitized using a solution of >70% isopropyl alcohol
or a freshly mixed 10% bleach solution.
c. Little fire ants nest in trees. If you are under a tree and that tree is bumped or somehow
stressed, the threat response of the ants is to fall from the leaves and sting the person under the
tree. If you are subject to an ant attack, do not panic. The ants are extremely small but their stings
are painful so make sure you remove all ants from your body and clothing. The stings cause inch
long welts that are itchy and painful, and can last for weeks. Treat stings as you would other
insect stings. In some persons stings can produce life threatening reactions. Stocking
antihistamine in the first aid kit is a reasonable precaution.
d. Rat Lungworm disease is caused by a parasite that can infect humans who consume raw or
undercooked infected snails or slugs or consume raw produce that contains a small infected snail
or slug. Infection is rare but can be serious. Symptoms can include severe headache, neck
stiffness, low grade fever, nausea, and vomiting anywhere from 1-6 weeks after exposure. The
disease is not spread person to person. Anyone who handles snails or slugs should wear gloves
and/or wash hands. Eating unwashed produce is discouraged.
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Final EA, Pahala LCC Replacement Project
Pahala, Ka'u District, Hawai'i
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February 2020
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Final EA, Pahala LCC Replacement Project
Pahala, Ka'u District, Hawai'i
Appendix D
Draft Archeological Inventory Survey (AIS) Report
February 2020
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Final EA, Pahala LCC Replacement Project
Pahala, Ka'u District, Hawai'i
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February 2020
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Wilfred M. Okabe
Managing Director
Harry Kim
Mayor
William A. Kucharski
Director
Diane A. Noda
Deputy Director
of Patent
DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
345 Kekuanao'a Street, Suite 41 ¦ Hilo, Hawai'i 96720
Ph: (808) 961-8083 ¦ Fax: (808) 961-8086
Email: cohdem@hawaiicounty.gov
March 11, 2019
Dr. Alan S. Downer, SHPD Administrator
Department of Land and Natural Resources
State Historic Preservation Division
601 Kamokila Boulevard, Suite 555
Kapolei, Hawai'i 96707
Re: Draft Archaeological Inventory Survey for the Pahala Wastewater Treatment
Plant and Sewer System Project, Hionamoa, Palima, and Pa'au'au 1 and 2
Ahupua'a, Ka'u District, Hawai'i Island
TMKs: (3) 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and
County of Hawai'i Right-of-Ways (Bautista et al. 2019)
Submitted for HRS 6E-8 Review
Dear Dr. Downer:
The County of Hawai'i Department of Environmental Management is submitting the attached
Draft Archaeological Inventory Survey (AIS) for the Pahala Wastewater Treatment Plant and
Sewer System Project, Hionamoa, Palima, and Pa'au'au 1 and 2 Ahupua'a, Ka'u District, Hawai'i
Island, TMKs: (3) 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County of
Hawai'i Right-of-Ways (Bautista et al. 2019) for SHPD review, along with a 6E submittal filing fee
form and check. These materials are additional submittals associated with existing Log No.
2018.000722.
The County of Hawai'i contracted Brown and Caldwell and its sub-consultants, Wilson Okamoto
Corporation and Cultural Surveys of Hawai'i Inc., to prepare the attached AIS and has
authorized them to coordinate directly with SHPD for processing and review and to address
associated SHPD comments for this submittal.
The project's point of contact at the County of Hawai'i Department of Environmental
Management is:
County of Hawai'i is an Equal Opportunity Provider and Employer
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Dr. Alan S. Downer, SHPD Administrator
March 11, 2019
Page 2
William A. Kucharski, Director
345 Kekuanaoa Street, Suite 41
Hilo, Hawai'i 96720
Phone: (808) 961-8083
Email: william.kucharski@hawaiicounty.gov
The project's point of contact at the County of Hawai'i Department of Environmental
Management's Wastewater Division is:
Dora Beck, Wastewater Division Chief
108 Railroad Avenue
Hilo, Hawai'i 96720
Phone: (808) 961-8513
Email: dora.beck@hawaiicounty.gov
If you have any questions or comments, please contact Craig Lekven with Brown and Caldwell
at (808) 442-3301. You may also reach him by email at CLekven@brwncald.com.
WK:mef
Encs: Submittal Form
Draft AIS
Check for Filing Fee
cc: Diane Noda, DEM Deputy Director
Dora Beck, DEM-WWD Chief
Craig Lekven, P.E., Brown and Caldwell
John Sakaguchi, Wilson Okamoto Corporation
Sincerely,
William A. Kucharski
Director
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10349-01
March 11,2019
Dr. Alan S. Downer, SHPD Administrator
DLNR-State Historic Preservation Division
Kakuhihewa Building, Suite 555
601 Kamokila Boulevard
Kapolei, Hawai'i 96707
Attention: Dr. Susan Lebo, Archaeology Branch Chief
Subject: Draft Archaeological Inventory Survey for the Pahala Wastewater
Treatment Plant and Sewer System Project, Hionamoa, Palima, and
Pa 'au 'au 1 and 2 Ahupua 'a, Ka 'u District, Hawai 'i Island, TMKs: [3J 9-
6-002:016por. and 018por., 9-6-005:036por. and 044, and County of
Hawai 7 Right-of-Ways (Bautista et al. 2019) submitted for HRS 6E-8
review
Dear Dr. Downer:
We are submitting the following:
1) One (1) cardstock copy of the Draft Archaeological Inventory Survey for the Pahala
Wastewater Treatment Plant and Sewer System Project, prepared by Cultural Surveys
Hawaii, March 2019;
2) Filing fee check of $450.00 payable to: Hawaii Historic Preservation Special Fund; and
3) Two (2) copies of the 6E filing fee form.
An electronic document link and related information has been sent to
DLNR.Intake.SHPD@hawaii.gov. If you have any questions, please call me at 808-946-2277.
Vice President, Director of Planning
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Roa, EPA
C. Levken; BC; W. Folk; CSH
Enclosures
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
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(
DAVID Y. IGE
GOVERNOR OF
HAWAII
-7
/
STATE OF HAWAII
DEPARTMENT OF LAND AND NATURALRESOURCES
STATE HISTORIC PRESERVATION DIVISION
KAKUHIHEWA BUILDING
601 KAMOKILA BLVD, STE 555
KAPOLEL HAWAII 96707
SUZANNE D. CASE
CHAIRPERSON
BOARD OF LAND AND NATURAL RESOURCES
COMMISSION ON WATER RESOURCE MANAGEMENT
ROBERT K. MASUDA
FIRST DEPUTY
JEFFREY T. PEARSON, P.E.
DEPUTY DIRECTOR - WATER
AQUATIC RESOURCES
BOATING AND OCEAN RECREATION
BUREAU OF CONVEYANCES
COMMISSION ON WATER RESOURCE MANAGEMENT
CONSERVATION AND COASTAL LANDS
CONSERVATION AND RESOURCES ENFORCEMENT
ENGINEERING
FORESTRY AND WILDLIFE
HISTORIC PRESERVATION
KAHOOLAWE ISLAND RESERVE COMMISSION
LAND
STATE PARKS
HRS 6E Submittal Filing Fees
All submittals must have the appropriate filing fee in accordance with HAR § 13-275-4 or HAR § 13-284-4.
All contact fields below must be complete and accurate.
Landowner:
Agency:
Contact Name:
Mailing Address:
Phone:
n/a
(if privately-owned historic property on Hawaii Register, HRS §6E-10)
Department of Environmental Management, County of Hawai'i
William A. Kucharski, Director
345 Kekuanaoa Street Suite 41, Hilo Hawaii 96720
(808) 961-8083
Email: william.kucharski@hawaiicounty.gov
Title of Report/Plan: Draft Archaeological Inventory Survey for the Pahala Wastewater Treatment Plant and
Sewer System Project, Hionamoa, Palima, and Pa'au'au 1 and 2 Ahupua'a, Ka'u District,
Hionamoa, Palima, and ... District: Ka'u Island: Hawai'i
Ahupua'a:
TMK(s):
[31 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County of Hawai'i Right-o
Contract Firm:
Contact Name:
Phone:
Cultural Surveys Hawai'i
(firm who completed the work on behalf of the agency)
William Folk
(808) 262-9972
Email:
wfolk (/culturalsurveys.coin
Check if Report/Plan is a re-submittal (no fee)
Check if Field Inspection Report requested by SHPD (no fee)
Check if Final Report (no fee)
$0 Archaeological Monitoring Report, no resources reported
$25 Archaeological Monitoring Plan
$25 Burial Disinterment Report
$25 Request from Agency for Determination Letter per HAR §13-275
$50 Archaeological Assessment (AIS with negative findings)
$50 Osteological Analysis Report
$100 Archaeological Monitoring Report, resources reported
$ 150 Archaeological Inventory Survey Plan, Archaeological Data Recovery Plan, or Preservation Plan
$250 Burial Treatment Plan (BTP)
/ $450 Archaeological, Architectural, or Ethnographic Survey Report
$450 Archaeological Data Recovery Report
Fee Total: Make check payable to "Hawaii Historic PreservationSpecial Fund"
For Office Use Only:
Date Received:
Payment Method:
Cash
Amount $
Log No.:
Check No.
Amount $
Receipt Issued:
Money Order
Amount $
rev. 11/9/2017
Draft
Final
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Draft
Archaeological Inventory Survey for the
Pahala Wastewater Treatment Plant and
Hionamoa, Palima, and Pa'au'au 1 and 2 Ahupua'a,
Ka'u District, Hawai'i Island
TMKs: [3] 9-6-002:016 por. and 018 por.,
9-6-005:036 por. and 044, and
County of Hawai'i Right-of-Ways
Prepared for
Wilson Okomoto Corporation
and the
County of Hawai'i Department of Environmental Management,
Wastewater Division
Prepared by
Olivier M. Bautista, B.A.,
Sarah Wilkinson, B.A.,
and
Hallett H. Hammatt, Ph.D.
Cultural Surveys Hawai'i, Inc.
Kailua, Hawai'i
(Job Code: HIONAMOA 2)
Sewer System Project,
March 2019
O'ahu Office
P.O. Box 1114
Kailua, Hawai'i 96734
Ph.: (808) 262-9972
Fax:(808)262-4950
www.culturalsurvevs.com
Hawai'i Office
399 Hualani St. #124
Hilo, Hawai'i 96720
Ph.: (808) 965-6478
Fax: (808) 965-6582
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Management Summary
Management Summary
Reference
Archaeological Inventory Survey for the Pahala Wastewater Treatment
Plant and Sewer System Project, Hionamoa, Palima, and Pa'au'au 1 and
2 Ahupua'a, Ka'u District, Hawai'i Island, TMKs: [3] 9-6-002:016 por.
and 018 por., 9-6-005:036 por. and 044, and County of Hawai'i Right-
of-Ways (Bautista et al. 2019)
Date
March 2019
Project Number(s)
Cultural Surveys Hawai'i, Inc. (CSH) Job Code: HIONAMOA 2
Investigation Permit
Number
CSH completed the archaeological inventory survey (AIS) fieldwork
under archaeological fieldwork permit numbers 18-15 and 19-07, issued
by the Hawai'i State Historic Preservation Division (SHPD) per
Hawai'i Administrative Rules (HAR) §13-282.
Agencies
United States Environmental Protection Agency (EPA); Hawai'i State
Department of Health (DOH); SHPD; County of Hawai'i Department of
Environmental Management (DEM), Wastewater Division
Land Jurisdiction
County; private (Kamehameha Schools, Olson Trust)
Project Proponent
County of Hawai'i DEM
Project Funding
EPA (EPA Grant XP-96942401-6); State Revolving Fund
Project Location
The project is located in the town of Pahala, approximately 5 km
(3.1 miles) back from the coast in the Ka'u District, Hawai'i Island. The
project area crosses portions of Hionamoa, Palima, and Pa'au'au 1 and
2 Ahupua'a. The proposed treatment plant is located adjacent to the
Maile Street and Hawai'i Belt Road (Route 11) intersection. The project
and is depicted on a portion of the 1995 Pahala U.S. Geological Survey
(USGS) 7.5-minute topographic quadrangle.
Project Description
The project includes closure of two Large Capacity Cesspools (LCCs)
and development of a new collection system and treatment and disposal
facility to service the Pahala community. The collection system is
located on county streets. The treatment disposal facility will occupy
14.9 acres and is located on a portion a 42.5-acre property (TMK: [3] 9-
6-002:018) near the southern edge of Pahala Town presently owned by
Kamehameha Schools and under lease to Royal Hawaiian Orchards.
Almost the entire parcel is planted in a commercial macadamia nut
orchard, with a macadamia nut processing plant parking lot in the
southeastern corner outside the limits of the current project area.
Area of Potential
Effect (APE) and
AIS Project Area
Acreage
The project APE comprises 57.7 acres (23.4 hectares) in Pahala Town,
while the AIS project area is a 29.3-acre (11.8 hectares) area within the
APE. The TMK parcels listed under "Reference" above are those
associated with the project area; a full list of TMK parcels for the
overall APE is given in Appendix A.
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
1
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Management Summary
The APE includes the following:
1. The 14.9-acre wastewater treatment plant (WWTP) site, within
which all project-related staging, including for the collection
system and the treatment and disposal facility, will be located;
2. An approximately 1,500-foot (ft) long by 25-ft wide utility
easement (about 0.94 acres) located entirely within TMK: [3] 9-
6-002:018 to connect the collection system line and other
utilities to the WWTP;
3. The path of the new sewer collection lines, to be located within
the 22- to 24-ft wide travel surface of select county streets;
4. Sewer line easements of similar width (22-24 ft) through TMKs:
[3] 9-6-005:036 and 044 connecting the collection lines to the
proposed Pahala WWTP site;
5. The existing LCC 1 and 2 locales (located in TMKs: [3] 9-6-
002:016 and 9-6-016:041, respectively), and an approximately
100-m (328-ft) long by 15-m (49-ft) wide corridor along the
existing sewer line easement in TMK: [3] 9-6-002:016 between
Maile Street and LCC 1; and
6. Numerous single-family residential/other properties with
existing sewer laterals, some of which may need to be
replaced/repaired/rehabilitated by the County.
The AIS project area comprises Items 1-5 within the project APE,
except for the LCC 2 location behind a private residence in TMK: [3] 9-
6-016:041. It also does not include the numerous private properties
located along the county streets selected for new sewer collection lines
(Item 6).
Historic Preservation
Regulatory Context
This AIS investigation was designed to comply with both federal and
Hawai'i State environmental and historic preservation review
legislation. Due to federal (EPA) funding, this project is a federal
undertaking, requiring compliance with Section 106 of the National
Historic Preservation Act (NHPA) and the National Environmental
Policy Act (NEPA). As a county project within both private and county
lands, the project is also subject to Hawai'i State environmental and
historic preservation review legislation (Hawai'i Revised Statutes
[HRS] §343 and HRS §6E-8/HAR §13-275, respectively).
In consultation with the SHPD, this archaeological inventory survey
(AIS) investigation fulfills the requirements of HAR §13-276 and the
Secretary of the Interior's Standards for Archaeology and Historic
Preservation. It was conducted to identify, document, and make
National Register of Historic Places (National Register) and Hawai'i
Register of Historic Places (Hawai'i Register) eligibility
recommendations for any historic properties. This report is also
intended to support any project-related historic preservation
consultation with stakeholders such as state and county agencies and
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
11
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Management Summary
interested Native Hawaiian Organizations (NHOs) and community
groups, if applicable.
Pacific Legacy in 2016 conducted an archaeological field inspection of
the entire 42.5-acre TMK: [3] 9-6-002:018 (Cleghorn 2016). The
11 November 2016 letter report was addressed to Dora Beck, P.E.,
Wastewater Division Chief for the County DEM Wastewater Division.
The report noted extensive ground disturbance throughout the parcel
conducted "prior to the planting of the present macadamia nut orchard.
The area at the southeastern corner of the parcel that is not planted in
macadamia nut trees has also been extensively disturbed and a portion
of it serves as a graveled parking lot for the adjacent macadamia nut
processing plant." A sealed lava tube entrance is present in this corner
of the parcel outside the current project area. No surface archaeological
features were documented by Cleghorn (2016). A handful of surface
artifacts, including a single discoidal hammerstone and fragmental
bottle glass and ceramics, were documented within the northern portion
of the parcel outside the current project area. Cleghorn (2016)
recommended consultation with SHPD about project historic
preservation requirements, noting that SHPD would likely require an
AIS. Cleghorn (2016) also recommended limiting the project area
footprint to avoid the lava tube located in the southeastern corner of
TMK: [3] 9-6-002:018.
On 17 October 2017 the project proponent provided a written request to
the SHPD for a letter of determination in accordance with HAR §13-
275-3 (Appendix B). The Cleghorn (2016) letter report was attached as
supportive information.
CSH on 22 February 2018 met with SHPD Archaeology Branch Chief
Dr. Susan Lebo to follow up on a 17 October 2017 request for project
determination. During this meeting Dr. Lebo indicated the following:
• An AIS should be undertaken addressing the entire area of
proposed ground disturbance, with subsurface testing;
• The AIS should include a "good faith effort" to address possible
lava tubes within the area of proposed ground disturbance;
• Backhoe assisted excavations should be conducted within
select proposed features at the plant site;
• All areas of the project not included in TMK: [3] 9-6-002:018
should be addressed, in particular the lateral installations along
the county roadways; these areas probably would not require
subsurface testing but should be evaluated for any relation to a
possible historic plantation village or historic property
designation.
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
111
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Management Summary
The items outlined above, and a more detailed summary of the
subsurface testing schema, were supplied in a 22 March 2018 county
DEM letter addressed to SHPD, which requested formal written
concurrence with the AIS approach; additional materials were
subsequently supplied to SHPD on request (see Appendix B). SHPD
replied to this letter concurring with the AIS approach in a §6E-8 and
NHPA Section 106 Review letter dated 20 August 2018 (Log No.:
2018.00722; Doc. No.: 1808JA02) (Appendix C).
CSH on 6 December 2018 met with Dr. Susan Lebo and Dr. Jane Allen
of SHPD to discuss the project APE and documentation requirements
(Appendix D).
Fieldwork Effort
CSH archaeologists Olivier Bautista, B.A., and Sarah Wilkinson, B.A.,
conducted fieldwork on 18 September 2018, 1-4 October 2018, and
10 January 2019 under the general supervision of Principal Investigator
Hallett H. Hammatt, Ph.D. This work required approximately 8 person-
days to complete.
Consultation
Consultation is being undertaken for the project to comply with
Section 106 of the NHPA. Presently, Section 106 consultation with
community, agency, and Native Hawaiian Organizations has been
initiated and is ongoing by the project proponents. The results of the
current investigation will be utilized in these ongoing efforts. To date,
no historic properties have been assessed as having traditional cultural
significance to an ethnic group (Criterion e) within the project area.
Historic Properties
Identified
Two newly documented historic properties were identified through
background research: State Inventory of Historic Places (SIHP) #s 50-
10-69-31088 is the historic Wood Valley Road/Coastal Road corridor,
and SIHP # 50-10-69-31089 is the historic Volcano Road corridor.
They are both assessed as significant under Criterion d for yielding
important information for research on former rights of way in Pahala
history. Constructed elements of the portions of these road alignments
within the project area have been thoroughly impacted by the
development of modern roadways, becoming Maile Street and Pikake
Street in Pahala town within the original corridors. Due to the impacts
and changes to these roads in Pahala over time these historic properties
only maintain integrity of location of the old corridor.
SIHP # s -31088 and -31089 are assessed as significant under Criterion
d per HAR §13-275-6 for the information they have yielded about
primary transportation routes in the Pahala vicinity during the late
nineteenth and early twentieth centuries.
Effect
Recommendation
Following consultation among EPA, DOH, DEM, and SHPD regarding
the project effect for the segments of the Wood Valley/Coastal Road
(SIHP # 50-10-69-31088) and Volcano Road (SIHP # 50-10-69-31089)
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
iv
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Management Summary
within the project area under HRS §6E-8, per HAR § 13-275-7(a)(l) the
County of Hawai'i DEM's project effect determination is "no historic
properties affected." In accordance with federal regulations (36 CFR
800.5), the AIS results support a determination of "no historic
properties affected."
Mitigation
Recommendations
No mitigation commitments are recommended for the portions of SIHP
#s 50-10-69-31088 and -31089 within the project area. The portions of
these historic properties within the project area only maintain integrity
of location as all of the constructed elements of the original Wood
Valley/Coastal road and Volcano road are no longer evident today.
While this project will have no effect on historic properties,
archaeological monitoring during construction for identification and/or
cautionary measures is proposed. This is based on the location of the
project being within the "Pahala Historic District" (SIHP # 50-10-69-
07362), as well as the presence near the project area of three historic
properties as follows:
• a lava tube system (SIHP # 50-10-69-27570) with some cultural
modifications beneath Pahala town;
• Ka'u High and Pahala Elementary School (SIHP # 50-10-69-
07522), a National Register-eligible historic property; and
• the Hawai'i Belt Road, (SIHP # 50-10-47-30187), a National
Register-eligible historic property south of the project area.
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
V
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Table of Contents
Management Summary i
Section 1 Introduction 1
1.1 Project Background 1
1.2 Historic Preservation Regulatory Context and Document Purpose 8
1.3 Environmental Setting 9
1.3.1 Natural Environment 9
1.3.2 Built Environment 10
Section 2 Methods 13
2.1 Field Methods 13
2.1.1 Pedestrian Survey 13
2.1.2 Subsurface Testing 13
2.2 Laboratory Methods 13
2.3 Research Methods 14
2.4 Consultation Methods 14
Section 3 Background Research 15
3.1 Traditional and Historical Background 15
3.1.1 Traditional Accounts 15
3.1.2 Early Historic Period 16
3.1.3 The Mahele and the Kuleana Act 19
3.1.4 Mid-to Late 1800s 21
3.1.5 1900s 25
3.1.6 Contemporary Land Use 29
3.2 Previous Archaeological Research 33
3.2.1 Previous Archaeological Studies 33
3.3 National Register-Eligible Historic Properties in the Vicinity 40
3.3.1 Ka'u High and Pahala Elementary School 40
3.3.2 Mamalahoa Highway 40
3.4 Background Summary and Predictive Model 40
Section 4 Results of Fieldwork 42
4.1 Pedestrian Inspection Results 42
4.2 Subsurface Testing Results 54
4.2.1 Test Excavation 1 (TE 1) 54
4.2.2 Test Excavation 2 (TE 2) 60
4.2.3 Test Excavation 3 (TE 3) 60
4.2.4 Test Excavation 4 (TE 4) 60
4.2.5 Test Excavation 5 (TE 5) 60
4.2.6 Test Excavation 6 (TE 6) 60
4.2.7 Test Excavation 7 (TE 7) 71
Section 5 Historic Property Descriptions 74
5.1 SIHP # 50-10-69-31088 74
5.2 SIHP # 50-10-69-31089 77
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Section 6 Significance Assessments and Register Eligibility 78
6.1 Significance Assessments under HRS §6E 78
6.2 National Register and Hawai'i Register Eligibility Determination 78
Section 7 Summary and Interpretation 80
Section 8 Project Effect and Mitigation Recommendations 81
8.1 Project Effect 81
8.2 Mitigation Recommendations 81
Section 9 References Cited 82
Appendix A APE Land Jurisdiction 86
Appendix B County of Hawai'i Correspondence to SHPD 88
Appendix C SHPD Correspondence 102
Appendix D SHPD Meeting Notes 104
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i J
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
List of Figures
Figure 1. Portion of the 1995 Pahala USGS 7.5-minute topographic quadrangle showing the
location of the project area 2
Figure 2. Tax Map Key (TMK) [3] 9-6-05 showing the northern portion of the project area
(Hawai'i TMK Service 2018) 3
Figure 3. TMK: [3] 9-6-02 showing the southern portion of the project area (Hawai'i TMK
Service 2018) 4
Figure 4. Aerial photograph of the project area (Google Earth 2013) 5
Figure 5. Aerial photograph of the project area, showing its configuration within the greater
project APE and the locations of LCCs 1 and 2 (Google Earth 2013) 6
Figure 6. Preliminary site plan showing the 14.9-acre Pahala WWTP and utility easement
through TMK: [3] 9-6-002:018 (courtesy of client) 7
Figure 7. Overlay of Soil Survey of the State of Hawaii (Sato et al. 1972), indicating soil types
within and surrounding the project area (USDA SSURGO 2001) 11
Figure 8. Portion of R.F. Pierce's 1914 map of Kalaala and Moaula-Kopu-Makaka Makai
Government Tracts, showing the project area in relation to roads, trails, and the plantation
railroad 20
Figure 9. F.S. Lyman 1877 map of Hawaiian Agricultural Company sugarcane lands, showing
the project area in relation to the Pahala Mill and developed cane lots 23
Figure 10. Portion of W.A. Wall's 1886 map of Hawai'i Island, showing the project area in
relation to sugar mills and harbors in windward Ka'u 24
Figure 11. Portion of J.M. Donn's 1906 map of Hawai'i Island, showing the project area in
relation to Pahala Mill, school, post office, and areas of different land use 26
Figure 12. 1929 map of Hawaiian Agricultural Co. cane fields, showing the location of the
project area 27
Figure 13. Portion of the 1930 Palima Point USGS 7.5-minute topographic quadrangle showing
the project area in relation to the mill, school, church, roads, and railroad in the Pahala
vicinity 28
Figure 14. Portion of the 1967 Pahala USGS 7.5-minute topographic quadrangle showing the
project area and development within Pahala Town 30
Figure 15. Portion of an undated field map of the Pahala Mill and Camp reprinted in Cleghorn
(2016:13) showing the project area in relation to plantation features 31
Figure 16. Portion of the 1977 USGS orthophotoquad aerial photo, Pahala Quadrangle, showing
the project area and continued development of Pahala Town 32
Figure 17. Portion of the 1995 Pahala USGS 7.5-minute topographic quadrangles showing
previous archaeological studies in the vicinity of the project area 35
Figure 18. Portion of the 1995 Pahala USGS 7.5-minute topographic quadrangles showing
locations of sites documented in previous archaeological studies in the vicinity of the
project area 36
Figure 19. Aerial photo showing the Escott (2013) project area and site locations (Escott
2013:18) 38
Figure 20. Survey map of SIHP # -29501 burial and SIHP # -27570 lava tube ceiling thicknesses
(Escott 2013:19); note the tube is set back from Kamani Street and Puahala Street where
a portion of the current project area is located 39
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
viii
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Figure 21. Aerial photo of the project area (Google Earth 2013) showing the locations of newly
documented historic properties 43
Figure 22. Photo showing the portion of the easement in TMK: [3] 9-6-005:036 that extends
from Maile Street along an existing asphalt driveway; view northwest 44
Figure 23. Photo showing the portion of the easement in TMK: [3] 9-6-005:036 that passes
through the old plantation maintenance yard; the structures present to either side are
outside the project area; view to northwest 44
Figure 24. Photo showing the forested area between the maintenance yard and Ilima Street at the
northern end of the easement in TMK: [3] 9-6-005:036; view to northwest 45
Figure 25. Photo showing the location where the easement in TMK: [3] 9-6-005:036 exits at
Ilima Street (frame right); the earthen drainage channel extending from the Huapala
Street culvert is beneath the grass to the left of the road; view to southwest 45
Figure 26. Photo looking down Huapala Street; note linear drainage in grassy lawn on left side of
photo; view to southeast 46
Figure 27. Photo looking up Ilima Street; note drainage in grassy shoulder on right side of photo;
view to northwest 46
Figure 28. Photo looking up Hinano Street from the eastern Huapala Street intersection; view to
northwest 47
Figure 29. Photo looking up Hala Street from the Hinano Street intersection; view to north 47
Figure 30. Photo of the intersection of Pikake and Puahala streets; view to northwest 48
Figure 31. Photo of the culvert located at the Huapala Street and Ilima Street intersection; view
to northeast 48
Figure 32. Photo looking up Pikake toward the Kamani Street intersection; commercial center is
visible to the right; view to north 50
Figure 33. Photo showing the Pikake Street terminus at Maile Street; Hawaiian Telcom building
is on opposite corner; view to southwest 50
Figure 34. Photo of a portion of Maile Street within the project area, showing the Pikake Street
intersection in the background and the HELCO building (left frame); view to northeast.51
Figure 35. Photo of a portion of Maile Street in the project area, showing the Lower Moaula
Road fork in the far background; view to southwest 51
Figure 36. Representative photo of the macadamia orchard; note the surface irrigation lines
between the trees; view to southwest 52
Figure 37. Photo of the paved road that passes through the macadamia orchard between Maile
Street and the macadamia nut husking plant; this road forms the mauka boundary of the
proposed WWTP site portion of the project area; view to northeast 52
Figure 38. Photo showing the margin of the macadamia orchard at the southeastern corner of the
proposed WWTP site portion of the project area; a dozer push pile is present beneath the
grass along the left side of the photo; view to southwest 53
Figure 39. Photo showing a portion of the linear push pile/berm located along the wind break
bisecting the macadamia orchard; view to southwest 53
Figure 40. Photo of the sewer manhole located along the existing, maintained sewer easement
within TMK: [3] 9-6-002:016; view to southwest 55
Figure 41. Photo showing the LCC 1 location at the makai terminus of the existing, maintained
sewer easement within TMK: [3] 9-6-002:016; view to south 55
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
IX
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Figure 42. Aerial photograph showing the locations of the seven test excavation trenches within
the proposed WWTP site portion of the project area (TE 1 through TE 7) (Google Earth
2013) 56
Figure 43. Preliminary WWTP site plan, overlain with locations of the seven test excavation
trenches within the proposed WWTP site portion of the project area (TE 1 through TE 7)
(site plan courtesy of client, with Google Earth 2013 overlay added) 57
Figure 44. Photo of TE 1 marked out with flagging tape prior to excavation; view to southwest 58
Figure 45. Photo of TE 1 northwest sidewall profile; view to northwest 58
Figure 46. Profile of TE 1 northwest sidewall 59
Figure 47. Photo of TE 2 marked out with flagging tape prior to excavation; view to southeast .61
Figure 48. Photo of TE 2 southwest sidewall; view to northeast 61
Figure 49. Stratigraphic profile of TE 2 southwest sidewall 62
Figure 50. Photo of TE 3 marked out with flagging tape prior to excavation; view to southeast .63
Figure 51. Photo of TE 3 west sidewall; view to northeast 63
Figure 52. Stratigraphic profile of TE 3 northeast sidewall 64
Figure 53. Photo of TE 4 marked out with flagging tape prior to excavation; view to south 65
Figure 54. Photo of TE 4 northwest sidewall; view to northwest 65
Figure 55. Stratigraphic profile of TE 4 northwest sidewall 66
Figure 56. Photo of TE 5 marked out with flagging tape prior to excavation; view to southwest 67
Figure 57. Photo of TE 5 southwest sidewall; view to south 67
Figure 58. Stratigraphic profile of TE 5 southwest sidewall 68
Figure 59. Photo of TE 6 marked out with flagging tape prior to excavation; view to southwest 69
Figure 60. Photo of TE 6 southeast sidewall; view to southeast 69
Figure 61. Stratigraphic profile of TE 6 southeast sidewall 70
Figure 62. Photo of TE 7 marked out with flagging tape prior to excavation; view to southwest 72
Figure 63. Photo of TE 7 south sidewall; view to southeast 72
Figure 64. Stratigraphic profile of TE 7 southeast sidewall 73
Figure 65. Portions of the 1995 Wood Valley, Pahala, Punaluu, and Naalehu USGS 7.5-minute
topographic quadrangles showing the location of the project area in relation to historic
roadways 75
Figure 66. Portions of the 1995 Pahala and Punaluu USGS 7.5-minute topographic quadrangles
showing the location of the project area in relation to historic roadways 76
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
X
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
List of Tables
Table 1. Previous archaeological studies in the vicinity of the project area 34
Table 2. TE 1 stratigraphic description 59
Table 3. TE 2 stratigraphic description 62
Table 4. TE 3 stratigraphic description 64
Table 5. TE 4 stratigraphic description 66
Table 6. TE 5 stratigraphic description 68
Table 7. TE 6 stratigraphic description 70
Table 8. TE 7 stratigraphic description 73
Table 9. Sites identified within the current project area 74
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
XI
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Introduction
Section 1 Introduction
1.1 Project Background
At the request of Wilson Okomoto Corporation and on behalf of the County of Hawai'i
Department of Environmental Management, Wastewater Division, Cultural Surveys Hawai'i, Inc.
(CSH) has prepared this archaeological inventory survey report (AISR) for the Pahala Wastewater
Treatment Plant and Sewer System project, Hionamoa, Palima, and Pa'au'au 1 and 2 Ahupua'a,
Ka'u District, Hawai'i Island, TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and
044, and County of Hawai'i Right-of-Ways. The project area is located within a larger Area of
Potential Effect (APE) in the town of Pahala. The project area is depicted on a portion of the 1995
Pahala U.S. Geological Survey (USGS) 7.5-minute topographic quadrangle (Figure 1), tax map
plats (Figure 2 and Figure 3), and a 2013 aerial photograph (Figure 4).
The project includes closure of two Large Capacity Cesspools (LCCs) and development of a
new collection system and treatment and disposal facility to service the Pahala community. The
collection system is located on county streets. The treatment disposal facility will occupy
14.9 acres and is located on a portion a 42.5-acre property (TMK: [3] 9-6-002:018) near the
southern edge of Pahala Town adjacent to the Maile Street and Hawai'i Belt Road (Route 11)
intersection. This parcel is presently owned by Kamehameha Schools and under lease to Royal
Hawaiian Orchards. Almost the entire parcel is planted in a commercial macadamia nut orchard,
with a macadamia nut processing plant parking lot in the southeastern corner outside the limits of
the current project APE.
The project APE comprises 57.7 acres (23.4 hectares) in Pahala Town, while the AIS project
area is a 29.3-acre (11.8 hectares) area within the APE (Figure 5). The TMK parcels listed above
are those associated with the project area; a full list of TMK parcels for the overall APE is given
in Appendix A. The APE includes the following:
1. The 14.9-acre wastewater treatment plant (WWTP) site, within which all project-related
staging, including for the collection system and the treatment and disposal facility, will
be located (Figure 6);
2. An approximately 1,500-foot (ft) long by 25-ft wide utility easement (about 0.94 acres)
located entirely within TMK: [3] 9-6-002:018 to connect the collection system line and
other utilities to the WWTP (see Figure 6);
3. The path of the new sewer collection lines, to be located within the 22- to 24-ft wide
travel surface of select county streets;
4. Sewer line easements of similar width (22-24 ft) through TMKs: [3] 9-6-005:036 and
044 connecting the collection lines to the proposed Pahala WWTP site;
5. The existing LCC 1 and 2 locales (located in TMKs: [3] 9-6-002:016 and 9-6-016:041,
respectively), and an approximately 100-m (328-ft) long by 15-m (49-ft) wide corridor
along the existing sewer line easement in TMK: [3] 9-6-002:016 between Maile Street
and LCC 1; and
6. Numerous single-family residential/other properties with existing sewer laterals, some
of which may need to be replaced/repaired/rehabilitated by the County.
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
1
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Cultural Surveys Hawai'i Job Code: HIONAMOA2
Introduction
HAWAII
Project Area
Legend
| Project Area
Base- Map. USGS Topographic Map. Paha/a (19951 Qus^angic
Data Sources CSH
Scale
0 300
1,009
$00 Meters N
1
2.000 Feet
C.tthtfTat^yJTt\Cffit /"/jW'JrV, ftl-i
Figure 1. Portion of the 1995 Pahala USGS 7.5-minute topographic quadrangle showing the
location of the project area
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
2
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Introduction
Figure 2. Tax Map Key (TMK) [3] 9-6-05 showing the northern portion of the project area (Hawai'i TMK Service 2018)
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
3
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Cultural Surveys Hawai'i Job Code: HIONAMOA2
Introduction
Legend
Project Area
Base Map: Tax Map Key [3] S-6-Q2
Data Sources: CSN
Scale
0 500 1,000 Meters
/
K '« \f ;
0 1,500 3.000 F&et /
(_, ulhitztl rtjz* .U V, be
Figure 3. TMK: [3] 9-6-02 showing the southern portion of the project area (Hawai'i TMK Service 2018)
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por.. 9-6-005:036 por. and 044, and County Right-of-Ways
4
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Cultural Surveys Hawai'i Job Code: HIONAMOA2
Introduction
SCHOOil
Project Area
Legend
I I Project Area
300 Meters
Base Map Google Earth Aerial imager? (2913)
Data Sources; CSH
( _ ttlfitrjlctfy
Figure 4. Aerial photograph of the project area (Google Earth 2013)
AISR for the Paliala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
5
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Cultural Surveys Hawai'i Job Code: HIONAMOA2
Introduction
Project Area
Legend
I I Area of Potential Effect (APE)
O Exis»tr»g Large Capacity Cesspool (LCC)
Base Map Google Earth Aerial imager? (2913)
Data Sources: C SH
AIS Project Area
Scale
o
150
500
300 Meters N
1
1,000 Feet I
C, JyiffVrt/ir f~fjwarX fae.
Figure 5. Aerial photograph of the project area, showing its configuration within the greater project
APE and the locations of LCCs 1 and 2 (Google Earth 2013)
AISR for the Paliala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
6
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Introduction
DOUBLE CHECK
DETECTOR ASSEMBLY
FOR FIRELINE
1* WATER METER
FOR POTABLE
WATER
25" WIDE UTILITY
EASEMENT [0 W ACRES}
/r INFLUENT
SEWER
iWCte
- -i-£^i.'IT.
LOT 1
(27.6 ACRES)
PROPERTY
LINE. TYP
WSHOP ESTATES
{KAMEKAMEHA SCHOOLS)
TMK: (3) •HEKN&Olf
42,5 ACRES
EW5TINO ACCESS VIA
KAMEHAMEMA SCHOOLS
FOR OTHERS TO REMAW
(0 5 ACRES)
25' SETBACK
r—«r SETBACK
DISINFECTION
Va<
NOTE:
TOPOGRAPHICAL CONTOURS ARE APPROXIMATE
AND tiASEO ON PArtALA USGS TOPO QUADRANGLE
\
20Q
X
400
SCALE IN FffT
PAHALA WASTEWATER TREATMENT PLANT
PRELIMINARY SITE PLAN
piaufif
5-1
Figure 6. Preliminary site plan showing the 14.9-acre Pahala WWTP and utility easement through TMK: [3] 9-6-002:018 (courtesy of
client)
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Introduction
The AIS Project Area comprises Items 1-5 within the project APE, except for the LCC 2
location behind a private residence in TMK: [3] 9-6-016:041. It also does not include the numerous
private properties located along the county streets selected for new sewer collection lines (Item 6).
The gravity sewer collection system lines will be mostly 8-inch diameter lines with the others
from 12 to 16 inches, depending on their location, and will be placed in trenches located within
the county streets. The trenches will be 3 to 4 ft wide and will be approximately 6 ft deep, or deeper
depending on the location. For the former C. Brewer properties, the sewer laterals connecting the
parcels to the collection system in the street have already been installed, although some of them
may need to be replaced/repaired/rehabilitated by the County. For other properties that may
eventually connect, the owners will be responsible for the improvements on their private property
to connect to the collection system at the property line.
1.2 Historic Preservation Regulatory Context and Document Purpose
This AIS investigation was designed to comply with both federal and Hawai'i State
environmental and historic preservation review legislation. Due to federal (Environmental
Protection Agency [EPA]) funding, this project is a federal undertaking, requiring compliance with
Section 106 of the National Historic Preservation Act (NHPA) and the National Environmental
Policy Act (NEPA). As a county project within both private and county lands, the project is also
subject to Hawai'i State environmental and historic preservation review legislation (Hawai'i
Revised Statutes [HRS] §343 and HRS §6E-8/Hawai'i Administrative Rules [HAR] §13-275,
respectively).
In consultation with the State Historic Preservation Division (SHPD), this AIS investigation
fulfills the requirements of HAR §13-276 and the Secretary of the Interior's Standards for
Archaeology and Historic Preservation. It was conducted to identify, document, and make
National Register of Historic Places (National Register) and Hawai'i Register of Historic Places
(Hawai'i Register) eligibility recommendations for any cultural resources/historic properties. This
report is also intended to support any project-related historic preservation consultation with
stakeholders such as State and County agencies and interested Native Hawaiian Organizations
(NHOs) and community groups, if applicable.
Pacific Legacy in 2016 conducted an archaeological field inspection of the entire 42.5-acre
TMK: [3] 9-6-002:018 (Cleghorn 2016). The 11 November 2016 letter report was addressed to
Dora Beck, P.E., Wastewater Division Chief for the County Department of Environmental
Management (DEM) Wastewater Division. The report noted extensive ground disturbance
throughout the parcel conducted "prior to the planting of the present macadamia nut orchard. The
area at the southeastern corner of the parcel that is not planted in macadamia nut trees has also
been extensively disturbed and a portion of it serves as a graveled parking lot for the adjacent
macadamia nut processing plant." A sealed lava tube entrance is present in this corner of the parcel
outside the current project area. No surface archaeological features were documented by Cleghorn
(2016). A handful of surface artifacts, including a single discoidal hammerstone and fragmental
bottle glass and ceramics, were documented within the northern portion of the parcel outside the
current project area. Cleghorn (2016) recommended consultation with SHPD about project historic
preservation requirements, noting that SHPD would likely require an AIS. Cleghorn (2016) also
recommended limiting the project area footprint to avoid the lava tube located in the southeastern
corner of TMK: [3] 9-6-002:018.
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
8
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Introduction
On 17 October 2017 the project proponent provided a written request to the SHPD for a letter
of determination in accordance with HAR §13-275-3 (Appendix A). The Cleghorn (2016) letter
report was attached as supportive information.
CSH on 22 February 2018 met with SHPD Archaeology Branch Chief Dr. Susan Lebo to follow
up on 17 October 2017 request for project determination. During this meeting Dr. Lebo indicated
the following:
• An AIS should be undertaken addressing the entire area of proposed ground disturbance,
with subsurface testing;
• The AIS should include a "good faith effort" to address possible lava tubes within the
area of proposed ground disturbance;
• Backhoe assisted excavations should be conducted within select proposed features at
the plant site;
• All areas of the project not included in TMK: [3] 9-6-002:018 should be addressed, in
particular the lateral installations along the county roadways; these areas probably
would not require subsurface testing but should be evaluated for any relation to a
possible historic plantation village or historic property designation.
The items outlined above, and a more detailed summary of the subsurface testing schema, were
supplied in a 22 March 2018 county DEM letter addressed to SHPD, which requested formal
written concurrence with the AIS approach; additional materials were subsequently supplied to
SHPD on request (see Appendix A). SHPD replied to this letter concurring with the AIS approach
in a §6E-8 and NHPA Section 106 Review letter dated 20 August 2018 (Log No.: 2018.00722;
Doc. No.: 1808JA02) (Appendix B).
CSH on 6 December 2018 met with Dr. Susan Lebo and Dr. Jane Allen of SHPD to discuss the
project APE and documentation requirements (Appendix D).
1.3 Environmental Setting
1.3.1 Natural Environment
The project area is situated approximately 5 km (3.1 miles) back from the coast on the
southeastern slope of Mauna Loa volcano, at an elevation of 170-305 m (590-1,000 ft) above
mean sea level (amsl). The Pahala Town vicinity receives an annual average rainfall of 52 inches
(Giambelluca et al. 2013), which today supports commercial agricultural crops like coffee and
macadamia nuts and historically supported sugarcane. The Ka'u Forest Reserve is located
approximately 2.5 miles upslope. Gulches carrying flood waters from the forest reserve makai
(seaward; downslope) bracket the town; no natural waterways are present within the project area.
Vegetation within the proposed treatment plant consists of a macadamia (Macadamia integrifolia)
orchard with Norfolk Island pines (Araucaria heterophylla) used for windbreaks. The terrain in
this area is gently sloped to the southwest. The sewer line easement extends through the orchard
and areas of grasses and weeds. Landscaped residential yards line the sides of the County roadways
in Pahala Town. The terrain along the roadways ranges from level to sloped.
The unique geology of its upper slopes, lined with a string of large pu 'u (hills, cinder cones)
has protected broad portions of windward Mauna Loa from relatively recent lava flows. The region
is known for its arable soils formed in volcanic ash, commonly referred to as "Pahala Ash."
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
9
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Introduction
According to the U.S. Department of Agriculture (USDA) Soil Survey Geographic (SSURGO)
database (2001) and soil survey data gathered by Sato et al. (1973), the project area's soils consist
of soils from the Waiaha and Naalehu series (Figure 7). The northern half of the project area is
Waiaha silt loam, 0 to 10% slopes (WAC), and the southeastern corner is Waiaha silt loam, 10 to
20% slopes (WKD). The remaining portions of the project area are Naalehu silty clay loam 0%-
10% slopes (NaC) and Naalehu silty clay loam 10%-20% slopes (NaD) (see Figure 7).
Waiaha soils are described as
shallow, well-drained silt loams that formed in volcanic ash. These soils are nearly
level to moderately steep and most areas are extremely stony . . . The natural
vegetation consists of kiawe, koa haole, natal redtop, lantana, guineagrass, and
bermudagrass. . .
Waiaha soils are used for pasture. [Sato et al. 1973:52]
The WAC type has a non-stony surface layer and "receives more rain during the winter than
the extremely stony soil;" it is also used for orchards (Sato et al. 1973:53).
Naalehu soils are described as
well-drained silty clay loams that formed in volcanic ash. These soils are nearly
level to steep. . . The natural vegetation consists of Christmas berry, bermudagrass,
guava, and kaimi cover... Naalehu soils are used mostly for sugarcane. Small areas
are used for pasture. [Sato et al. 1973:40]
1.3.2 Built Environment
The entire project area has been altered by agricultural, commercial, and residential
development. The location of the proposed treatment plant is currently an active macadamia nut
orchard operated by Royal Hawaiian Orchards. This portion of the project area is on the southern
outskirts of Pahala Town, bound to the west by Maile Street, to the south by the Hawai'i Belt Road
or Mamalahoa Highway (State Inventory of Historic Places [SIHP] # 50-10-47-30187), to the
north by additional macadamia orchard, and to the east by an unimproved jeep road separating the
orchard from the Royal Hawaiian processing facilities. This road is bound to the east by a concrete
flume extending mauka-makai (from mountains to sea), located outside the project area. An
unnamed paved roadway forms the approximate northern boundary of the proposed plant area; this
road provides access to and from the Royal Hawaiian Orchards processing facility via Maile Street.
Just inside the western boundary of the parcel parallel to Maile Street is another unimproved road,
used to access the orchard. An earthen ditch is situated between this road and Maile Street,
designed to channel run-off downslope. The orchard itself is bisected by a large, linear dozer push
pile containing a row of trees forming additional wind-breaks; unimproved access roads run along
both sides of this push pile.
The proposed sewer collection line extends for the most part along existing, paved County
roadways including Maile Street, Pikake Street, Ilima Street, Huapala Street, Hinano Street,
Kamani Street, and Puahala Street (see Figure 4). These roadways extend through predominately
residential areas of Pahala Town. The portion of Maile Street in which the sewer line will be placed
is located between the Pikake Street/Old Camp Mill Road intersection and the Lower Moa'ula
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
10
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Cultural Surveys Hawai'i Job Code: HIONAMOA2
Introduction
Scale
0 160 300 Meters *
i
500 1.000 Feet 1
( {Tlfy / jr..
Soil Map Unit
B FL, Fill land
NaC. Naalehu sitty clay loam. 0 to 10 percent slopes
NaD. Naalehu siSty clay loam. 10 to 20 percent slopes
RB, Rough broken larwJ
WAC, Waiaha si)t loam. 0 to 10 percent slopes
WAD. Waiaha silt loam, 10 to 20 percent slopes
^¦l WKD, Waiaha very rocky silt loam, 10 to 20 percent slopes
rKED, Kairrsu extremely stony peat, 7 to 25 percent slopes
Legend
~ Project Area
Base Map Google Earth A«nal imagery (2013)
Data Sources: CSH: SSURGO
WAD WAD
NaQ
WAC
WAC
WAD
Figure 7. Overlay of Soil Survey of the State of Hawaii (Sato et al. 1972), indicating soil types
within and surrounding the project area (USDA SSURGO 2001)
AISR for the Paliala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
11
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Introduction
Road fork. Remnants of the sugar mill and associated plantation structures are present on either
side of Maile Street outside of the project area.
Three sewer line easements are proposed for portions of the sewer line not within county
roadways. One of these easements would extend along the southernmost segment of Pikake Street,
which crosses privately owned TMK: [3] 9-6-005:044. This sewer line easement would also be
within the existing paved roadway. Another easement extends from the eastern section of 'Ilima
Street through the old Pahala Sugar Mill maintenance yard at TMK: [3] 9-6-005:036. The
maintenance yard property has been completely altered with the development of the sugar
plantation and town. The property has been graded and contains structures, driveways, parking
areas, and a portion of a roadway used to access Ka'ala'iki Road/Pahala Cane Haul Road. Though
this overall parcel is within the project APE, no new sewer connections are proposed under the
current project for any of its structures. The easement extends between and around the existing
historic structures on this parcel and exits the property at Maile Street, where the line then extends
southeast into TMK: [3] 9-6-002:018. The sewer line runs through the macadamia nut orchard,
connecting to the northern corner of the proposed plant site.
The project involves the closure of the two existing LCCs (LCC 1 and LCC 2). LCC 1 is located
in TMK [3] 9-6-002:016 south of Maile Street, at the terminus of a sewer easement maintained by
the County. The portion of the parcel containing LCC 1 and its associated easement are fallow
cane land. LCC 2 and its tie-ins to existing sewer lines are located behind a private residence at
TMK [3] 9-6-016:041. This residential property comprises a main dwelling, outbuildings,
driveway, and landscaped yard.
The sewer collection and transmission lines overlap with the known boundaries of the "Pahala
Historic District." In the 1970s the majority of Pahala Town was designated SIHP # 50-10-69-
07362, a historic district associated with the historic sugar plantation and village. This historic
property is not listed on the National Register or Hawai'i Register, and to the best of our knowledge
has never been evaluated for eligibility for listing on these registers. CSH was unable to locate any
records on file at the SHPD offices in Hilo or Kapolei pertaining to SIHP # -07362.
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
12
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Methods
Section 2 Methods
2.1 Field Methods
CSH completed the fieldwork component of this archaeological inventory survey under
archaeological fieldwork permit number 18-15, issued by the SHPD pursuant to HAR §13-282.
Fieldwork was conducted on 18 September 2018 and 10 January 2019 by CSH Field Supervisor
Olivier Bautista, B.A., and Project Director Sarah Wilkinson, B.A.; and on 1-4 October 2018 by
Olivier Bautista B.A., under the general supervision of CSH Principal Investigator Hallett H.
Hammatt, Ph.D. This work required approximately 8 person-days to complete. In general,
fieldwork included 100% pedestrian inspection of the project area, GPS data collection, and
subsurface testing.
2.1.1 Pedestrian Survey
A 100%-coverage pedestrian inspection of the project area was undertaken for the purpose of
historic property identification and documentation. The pedestrian survey was accomplished
through systematic sweeps spaced 2-5 m apart depending on ground visibility.
Where a new historic property was encountered, the determination of its boundary was based
on factors including apparent age, architectural style, and the spatial and functional
interrelationships of both natural and man-made features.
2.1.2 Subsurface Testing
A program of subsurface testing was undertaken for the AIS to assess the potential for
subsurface archaeological features, including but not limited to buried cultural deposits and/or
culturally modified lava tubes. The number and locations of the test excavations were chosen based
on consultation with SHPD (see Appendices A and B). The subsurface testing program consisted
of backhoe assisted excavation of seven trenches within the proposed plant site: one each within
proposed Lagoons 1 and 4, Groves 1-4, and the Wetland area. The test excavations were placed
to avoid trees, roots, and irrigation lines. In general, the seven linear trenches measured
approximately 5 m (20 ft) long and 1.0 m (3.2 ft), and all trenches were excavated to bedrock.
A stratigraphic profile of each test excavation was drawn and photographed. The observed
sediments were described using standard USDA soil description observations/terminology.
Sediment descriptions included Munsell color; texture; consistence; structure; plasticity;
cementation; origin of sediments; descriptions of any inclusions, such as cultural material and/or
roots; lower boundary distinctiveness and topography; and other general observations. Were
stratigraphic anomalies or potential cultural deposits exposed, these were to be carefully
represented on test excavation profile maps.
2.2 Laboratory Methods
No samples or cultural materials were collected during the AIS fieldwork; therefore, laboratory
studies were unnecessary.
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
13
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Methods
2.3 Research Methods
Background research included a review of previous archaeological studies on file at the SHPD;
review of documents at Hamilton Library of the University of Hawai'i, the Hawai'i State Archives,
the Mission Houses Museum Library, the Hawai'i Public Library, and the Bishop Museum
Archives; study of historic photographs at the Hawai'i State Archives and the Bishop Museum
Archives; and study of historic maps at the Survey Office of the Department of Land and Natural
Resources. Historic maps and photographs from the CSH library were also consulted. In addition,
Mahele records were examined from the Waihona 'Aina database (Waihona 'Aina 2000).
This research provided the environmental, cultural, historic, and archaeological background for
the project area. The sources studied were used to formulate a predictive model regarding the
expected types and locations of cultural resources in the project area.
2.4 Consultation Methods
Consultation is being undertaken for the project to comply with Section 106 of the National
Historic Preservation Act (NHPA). Presently, Section 106 consultation with community, agency,
and Native Hawaiian Organizations has been initiated and is ongoing by the project proponents.
The results of the current investigation will be utilized in these ongoing efforts. No historic
properties have been assessed as having traditional cultural significance to an ethnic group
(Criterion e) within the project area.
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
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Section 3 Background Research
3.1 Traditional and Historical Background
3.1.1 Traditional Accounts
The district of Ka'u is the southernmost and largest district of Hawai'i Island, encompassing
over 600,000 acres and nearly 30 ahupua'a (land divisions usually extending from uplands to the
sea). The current project area crosses the boundaries of four ahupua'a, including (from west to
east) Hionamoa, Palima and Pa'au'au 1 and 2. According to Pukui et al. (1976:173, 177), Pa'au'au
translates as "bath enclosure," and Palima literally means "five-fold." The meaning of "Hionamoa"
was not found.
Traditional accounts concerning the area known as Pahala are limited, likely due to scarcity of
pre-Contact settlement in the vicinity. Pahala is a historic-era settlement that formed around a
sugar plantation in the late 1800s; the name "Pahala" refers to a practice in the cane fields of
"cultivation by burning mulch" (Pukui et al. 1976:174) made from the hala tree (Pandanus
tectorius). That sugar became one of the first industries of Ka'u is indicative of the suitability of
this inland regions for agriculture: Handy and Handy (1972:558) note that the kula (plains) lands
of Ka'u are "perhaps the finest arable country in the Hawaiian Islands."
Given its geological and climatic complexity, it is not surprising that Ka'u came to be known
as a land of fierce and independent people, a "fatal land to chiefs." These characteristics are
expressed in David Malo's (1951) delineation of the responsibilities of the ali(chiefly class), and
of the treatment meted out to those aliwho abused their power:
It was the king's duty to seek the welfare of the common people, because they
constituted the body politic. Many kings have been put to death by the people
because of their oppression of the maka 'ainana [populace].
The following kings lost their lives on account of their cruel exactions on the
commoners: Koihala was put to death in Kau, for which reason the district of Kau
was called The Weir (Makaha) [Makaha, "fierce Ka'u"]. [Malo 1951:195]
Samuel Kamakau, in Ruling Chiefs of Hawai'/', mentions Ka'u as he recounts the political
unification of the island of Hawai'i under 'Umi-a-Llloa during the sixteenth century.
I-mai-ka-lani was the chief of Ka-u. He was blind, but noted for his strength and
skill in battle. Many chiefs who had fought against him were destroyed. . . . 'Umi-
a-Liloa feared I-mai-ka-lani. . . After I-mai-ka-lani became blind the fight between
him and 'Umi continued . . . After I-mai-ka-lani's death Ka-u became 'Umi-a-
Liloa's. [Kamakau 1961:18-19]
Kamakau also details the shifts of power within Ka'u and other districts through generations on
the island of Hawai'i. Power, apparently, did not necessarily transfer from a ruler to his
descendants (Kamakau 1961:61-65).
At times, the contiguous districts Kohala, Kona, and Ka'u formed a triumvirate under a single
ruler. However, such unions were subject to change as, according to Kamakau, in later times rule
over Ka'u was consolidated with that of Puna:
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
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Ka-lani-'opu'u and Keoua were the hereditary heirs to the land of Hawaii, for it had
belonged to their father, Ka-lani-nui-'i-a-mamao, and [his brother] Ka-lani-ke'e-
au-moku; but Alapa'i had seized it through force of arms and had slain the
inheritors.
... a great battle was fought [between Ka-lani-'opu'u and Alapa'i] at Kualoa and
Mokaulele all the way to Mahinaakaka, at which Ka-lani-'opu'u almost lost his life
. . . Ka-lani-'opu'u's men were victorious that day, and the chief realized how
powerful his following was in chiefs and fighting men and how strong he himself
was to break men's bones with his hands.
After this battle Mahinaakaka, Ka-lani-'opu'u ruled over Ka-'u and Puna, for he
was a native of Ka-'u. There were the birth sands of his ancestors. [Kamakau
1961:76-77]
Kamakau's account suggests the precariousness of the inter-district power combinations by the
ruling aliduring traditional Hawaiian times in Ka'u and other districts.
The chief Ka-lani-'opu'u ruled Ka'u during the eighteenth century just before the first European
visitors began to record their early impressions of the land and its people.
3.1.2 Early Historic Period
Lt. James King, sailing off the island of Hawai'i during the 1779 voyage of Captain James
Cook, described the Ka'u first seen by Europeans:
The coast of Kaoo [Ka'u] presents a prospect of the most horrid and dreary kind:
the whole country appearing to have undergone a total change from the effects of
some dreadful convulsion. The ground is every where covered with cinders and
intersected in many places with black streaks, which seem to mark the course of a
lava that has flowed, not many ages back, from the mountain Roa [Mauna Loa] to
the shore. The southern promontory looks like the mere dregs of a volcano. The
projecting headland is composed of broken and craggy rocks, piled irregularly on
one another, and terminating in sharp points. [King 1784:104]
The only onshore exploration at Ka'u involved a search for freshwater:
When [Mr. Bligh] landed, he found no stream or spring, but only rain-water,
deposited in holes upon the rocks; and even that was brackish, from the spray of
the sea; and that the surface of the country was entirely composed of flags and
ashes, with a few plants here and there interspersed. [King 1784:545]
Archibald Menzies, a surgeon and naturalist on the 1794 voyage of Captain George Vancouver,
describing an excursion from Kona across Ka'u to the top of Mauna Loa, found a different scene
in areas that received more rainfall. Menzies writes of
a fine fertile valley [where he] put up for the night at a village called Kioloku, on a
rich plantation belonging to Keawe-a-heulu.
. . . This was by far the most populous village we had yet met with since we left
Kealakekua. Towards the dusk of the evening, there fell some showers of rain
which gave a gay and refreshing look to the most enchanting scenes of rural
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
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industry with which we were surrounded. The economy with which these people
laid out and managed their ground and the neatness with which they cultivated their
little fields made the whole valley appear more like a rich garden than a plantation.
A stream of water which fell from the mountain through the middle of it was
ingeniously branched off on each side to flood and fertilize the most distant fields
at pleasure. [Menzies 1920:184-185]
This abundance was not isolated; continuing on his way east through the ahupua 'a of Honu'apo
(approximately 9 miles southwest of Palima), Menzies found
... the people everywhere busily employed in their little fields, many of which
were here cropped with plantains and bananas that had a ragged appearance from
having little or no shelter, yet they bore fruit tolerably well. [Menzies 1920:185]
In 1823, Rev. William Ellis, journeying like Menzies from Kona through Ka'u, recorded his
impressions of the land, demonstrating like Menzies a willingnessto look and let the land speak
for itself. He describes the valley of Wai'ohinu (located approximately 12 miles southwest of the
project area) as open toward the sea, and on both sides adorned with gardens and interspersed with
cottages, even to the summits of the hills.
A fine stream of fresh water, the first we had seen on the island, ran along the centre
of the valley, while several smaller ones issued from the rocks on the opposite side,
and watered the plantations below.
Our road, for a considerable distance, lay through the cultivated parts of this
beautiful valley: the mountain taro, bordered by sugar-cane and bananas, was
planted in fields six or eight acres in extent, on the sides of the hills, and seemed to
thrive luxuriantly. [Ellis 1963:133-134]
Ellis' account confirms the upland luxuriance that had made the ahupua 'a of Wai'ohinu a center
for the aliof Ka'u. As Ellis continued his journey he moved closer to the coast and his journal
illumines areas where western eyes had previously perceived only a "prospect of the most horrid
and dreary kind." Travelling northeast toward Punalu'u (located approximately 4.5 miles
southwest of the project area), Ellis found the countryside "more thickly inhabited [as his walk
continued] . . . The villages along the sea shore, were near together, and some of them extensive"
(Ellis 1963:136). Ellis also notes the intervening broad stretches of rough 'a'a between the
habitation areas. These flows had been made traversable by waterworn boulder paths. Ellis thus
reveals the desolate coastline described 44 years earlier by James King was in fact the site of a
well-populated, active culture and economy where habitation centers, though isolated, were
accessible to each other and to the resources of land and sea.
William Ellis in 1823 may have been the first missionary to visit Ka'u. During the 1830s
Protestant missionaries based in Kona and Hilo made occasional tours into Ka'u, but a permanent
missionary presence was not installed until the early 1840s when Catholic and Protestant missions
were established in the district. In 1841, a Catholic priest, Father Marechal, arrived in Ka'u and
within a few months boasted of 900 converts. The following year, 1842, the Protestant minister
John Paris reached Ka'alu'alu (located at Ka Lae, approximately 19 miles southwest of the project
area) by schooner where he found,
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
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The shore was lined with hundreds of natives as our little boat neared the shore.. . .
Then came greetings from the multitude, some kissing my hands and some taking
hold of my feet. A joyful 'Aloha ino!' with a low wail, rose from the aged ones.
[Paris 1926:89]
Paris' account illustrates the abundant resources available in the district:
. . . two strong men, tattooed from head to foot, came in bearing a huge whole hog,
baked entire minus hair and entrails. These bearers were followed by others,
dressed in the same style bringing calabashes of various sizes filled with fish, poi,
potatoes, then came melons, bananas, and sugar cane, and little gourds filled with
goat's milk. All was spread out in royal Hawaiian style, a dozen kukuis [nuts from
the Candlenut tree, Aleutris moluccana\ burning and kahilis [feather standards]
waving to and fro. [Paris 1926:90]
Paris settled in Wai'ohinu where he founded a church and school. Later, in 1843, a stone church
was also built at Punalu'u to the northeast. Cordy (1986:21) postulates that around this time a
settlement shift was occurring from coastal to inland regions, the result of depopulation and of
efforts to gain access to the government road and to populate the economic center of Wai'ohinu.
Mission station reports, censuses, and accounts by visitors to Ka'u during the mid-nineteenth
century document changes to the district brought about by natural forces and the pressures of an
increasing western presence. A visitor to Wai'ohinu and its environs in 1849 anonymously
published an account describing the devastating effects of a drought and fire that had occurred
three years earlier:
[W]e noticed many a tall, stately trunk, branchless and lifeless standing monument-
like, all over the country. On enquiry we ascertained that they were the remains of
a noble forest, which, with the whole surrounding country, were burnt in 1846. In
that year a severe drought visited the Island, the streams dried up, the grass
withered, and fire swept over the whole district. [Sailor in Kelly 1980:89]
The author also describes an area above the settlement at Wai'ohinu that, apparently undamaged
by the 1846 fire, probably represents the idyllic setting that had drawn the Ka'u ali'i to the
ahupua 'a:
[W]e ascended the hills back of the mission, and when we had reached an elevation
of about 5,000 feet were repaid with one of the richest scenes it was our privilege
to look upon. Below us lay, fashioned by the hand of nature, within a range of ten
miles, six lovely terraces, on which one thousand dwellings might be placed, each
of which should have a prospect of the sea, the rocky shore, the lava and the verdant
upland. ... On this land we saw some noble upland kalo, and a number of very
large banana trees. Several crystal springs take their rise on the summit, and might
send, if rightly directed, a portion of their treasures through every man's fields.
Behind this noble series of hills, timber abounds. So that there is to be found every
thing desirable to make a rich farming country, and in a circuit of some fifteen
miles, might be abundantly grown the best products of the temperate, with the rich
and varied fruits of the tropic zones. But alas the farmers are wanting, the land lies
in all the wild luxuriance of nature desolate, there are no passable roads, except foot
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
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paths, to it, and no harbor at which vessels could lie in safety, is found within many
miles. [Sailor in Kelly 1980:89]
Noticeably missing from this account is mention of any Hawaiians occupying and utilizing this
verdant land "now lying utterly waste." An 1831-1832 census of Ka'u, the first taken within the
district, records a total population of 5,800. In 1835 the total population is counted as 4,766. The
first official government census, taken in 1847, records the population as having dropped to 3,010.
Reverend John Paris would write in an 1848 mission station report (Paris 1848:3), "Since the year
1845 the work of depopulation of Kau has gone on with fearful rapidity." He notes, during the
years 1845 and 1846 (Paris 1848:3), a "distressing famine and fire which overran the country," the
same disasters the anonymous visitor of 1849 mentioned. By the time of the 1853 government
census only 2,210 people are recorded in Ka'u.
3.1.3 The Mahele and the Kuleana Act
In the mid-nineteenth century, during the time of Kamehameha III, a series of legal and
legislative changes were brought about in the name of land reform (see the works of Jon Chinen
1958, 1971 for a thorough and well-written explanation). Previous to the Mahele, all land belonged
to the akua (gods), held in trust for them by the paramount chief, and managed by subordinate
chiefs.
Following the enactment of a series of new laws from the mid-1840s to mid-1850s,
Kamehameha III divided the land into four categories: Crown Lands reserved for himself and the
royal house; Government Lands for the government; Konohiki Lands claimed by aliand their
konohiki (supervisors); and kuleana, small plots claimed by the maka'ainana (commoners)
(Chinen 1958:8-15). These claims are described in Land Commission Award (LCA) testimony
from the claimant and witnesses. A Royal Patent (RP), which quit-claimed the government's
interest in the land, was issued on most Land Commission Awards (LCA) (Chinen 1958:14). In
some cases, more than one RP number was issued for an LCA, especially in cases where there
were several widely separated 'apana (lots), such as an award with agricultural land in one
ahupua 'a and a house lot in another.
Ali 'i were required to pay a commutation fee to the government for their confirmed Konohiki
Land titles; this payment could be in cash or in the return of land to the government or crown.
Many ali'i elected to return substantial portions of their awarded lands to avoid the one-third
commutation cash fee. The Kuleana Act of 1850 allowed maka'ainana, in principle, to own land
parcels where they were currently and actively cultivating and/or residing. In 1851, certain
Government Lands became available for purchase in lots of 1 to 50 acres in fee simple; this new
category of land ownership became known as Royal Patent Grants or Land Grants. Unfortunately,
Land Grant records tend to offer far less insight into specific land use than LCA records.
According to Soehren (2010), Hionamoa, Palima, and Pa'au'au were not named in the Mahele
Book. However, a 1914 map (Figure 8) shows 1,950 acres in Hionamoa awarded to the ali'i
William Pitt Leleiohoku as LCA 9971:12.
Waihona ' Aina (2000) indicates Moses Keawe claimed five 'apana in the vicinity of the project
area as part of LCA 7312. Two of the five lots were awarded. LCA 7312:1 comprised 1.5 acres
located in Pa'au'au 2, approximately 750 m north of the project area along the "Kau-Volcano
Road" (present Ka'ala'iki Road). LCA 7312:2 comprised 11.7 acres in Hionamoa, located
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
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"X \ \Vm^ I \ )
7 ' PoifAtohofyA- ---USB
i * /
( < - / tt>
Leqend
Scale
Project Area
0 0.5 1 Kilometers N
0 0.5 1 Miles
Base Map: 1914 Pierce Map of Kaalaala and Moaula-Kopu-Makaka Makai
Government Tracts (HIS Plat 104)
Data Sources: CSH
(^ulturai'^jurvetjs t~jawail, Inc.
Figure 8. Portion of R.F. Pierce's 1914 map of Kalaala and Moaula-Kopu-Makaka Makai Government Tracts, showing the project
area in relation to roads, trails, and the plantation railroad
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
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approximately 350 m northwest of the project area along the "Kau-Volcano Road"/Ka'ala'iki
Road. Both of the awarded 'apana were house lots. The three 'apana not awarded comprised taro
fields.
LCA 10248 to Mahi was also awarded in Pa'au'au 2. This award comprised 13 acres straddling
the "Kau-Volcano Road"/Ka'ala'iki Road adjacent to LCA 7312:1, approximately 750 m north of
the project area. Unfortunately, the testimony for this award does not provide information about
land use. No kuleana are indicated within Pa'au'au 1 or Palima.
Waihona 'Aina (2000) lists four land grants in Palima-Pa'au'au: Land Grant 01370 to Nahala,
02446 to Kamalo (overlapped by the project area), 02655 to Nahala, and 02727 to F.S. Lyman. In
addition to these, Pa'au'au also contained Land Grant 03533 made to the trustees of the Bernice
Pauahi Bishop Estate; this grant is also overlapped by the project area. Soehren (2010) notes that
Grant 03533, which also included lands at Kaunakakai on Moloka'i and Honolulu and
Ka'akaukukaui on O'ahu, was made "in exchange for quitclaim deed to certain lands in Hilo."
Grants 01370 and 02655 are located mauka (inland) of the "Kau-Volcano Road"/Ka'ala'iki Road.
Grants 02446, 02727, and 03533 are depicted on the 1914 map (see Figure 8) in relation to the
project area. Figure 8 also indicates a fifth grant in upland Palima: Land Grant 01374 to Keawe.
This grant, comprising two separate 'apana, is listed on Waihona 'Aina (2000) as being located in
Kopu-Moaula a short distance east of Palima. Figure 8 indicates the portion of Land Grant 01374
north of the project area is 'Apana 2. No Land Grants are indicated within Hionamoa.
3.1.4 Mid- to Late 1800s
By the middle of the nineteenth century, imported livestock roaming freely throughout
pasturelands of Ka'u were creating new aggravations. Ka'alu'alu had become a focus of activity
as the export of agriculture and livestock began to dominate the Ka'u economy; at the same time,
about 1852, an improved, 7-mile-long cart road was constructed between the bay and Wai'ohinu.
In the 1850s, Rev. Henry Kinney (cited in Kelly 1980) commented on the "hundreds of goats salted
and dried" as well as "upland taro, potatoes and onions" which previously had to be hauled "on
the backs of men" overland to Hilo and which could now be taken to the harbor and shipped.
Ranching activity in Ka'u commenced sometime after the middle of the century when Princess
Ruth Ke'elikolani started Ka'alu'alu Ranch with cattle brought from Waimea. Cattle continued to
be shipped out of Ka'alu'alu at least until the 1920s. Organized cattle ranching was focused at
Ka'alu'alu, Kahuku, and Kapapala (located northeast of present Pahala Town).
While cattle and other livestock were significant elements of the new western economic focus
imposed upon Ka'u during the nineteenth century, it was agriculture that had the most extensive
impact on the land and people. Among new agricultural pursuits attempted in Ka'u was wheat
growing:
But it proved difficult to co-ordinate the size of the wheat crop with the
requirements of the flour mills; difficult also to coordinate the output of the mills
with the demands of the market, domestic and foreign. The business did not become
a permanent one. [Kuykendall 1966:150]
Contributing to the failure of wheat production was the harvesting of pulu, a soft, flossy, yellow
wool on the base of tree-fern leaf stalks {Cibotium spp.) used for stuffing mattresses and pillows.
During the 1860s pulu constituted the major export crop from Ka'u. A mission station report
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written in 1860 by W.C. Shipman relates the ruinous effect upon the native population of
participation in thepulu trade:
The effect—on them is not good; not that the pulu is not a source from which they
might secure comfort to themselves and families, but the actual result is the reverse.
They are offered goods to almost any amount, to be paid for in pulu; this to a native
is a strong temptation to go into debt. Consequently many of them are deeply in
debt and almost all to some extent. The policy of the traders is to get them in debt
and to keep them there so long as possible . . . [T]hey are almost entirely under the
control of their creditors, and are compelled to live in the pulu regions, at the peril
of losing their houses and lots, and whatever other property they may possess. Thus
their homes are almost in reality deserted, ground uncultivated. [Shipman 1860:4]
Life in Ka'u during the 1860s was further disrupted and devastated by the forces of nature. A
sequence of major earthquakes and eruptions of Mauna Loa beginning in March 1868 resulted in
many deaths and losses of property and livestock. Then an earthquake in early April precipitated
a tidal wave that destroyed coastal villages, dislodged a cliff side at Kapapala blanketing the land
below and burying a village, and opened the Great Crack at Kllauea (located approximately
2.5 miles east of Pahala), emptying the crater's lava lake into Punalu'u and Keauhou. A subsequent
lava flow, this time in western Ka'u, buried all of Wai'ahukini Valley west of the great pali.
Apparently great natural disasters could not hinder the pace of foreign business interests in
Ka'u. In 1868, the same year as the great earthquake, Alexander Hutchinson established the
Naalehu Sugar Company and built a mill at Na'alehu just east of Wai'ohinu. More enduring
commercially than either wheat or pulu, sugar cultivation beaome the major industry within Ka'u,
appropriating the focus of life in the district.
During the mid-1870s Waiohinu Plantation was established by John Nott and Company. This
operation was bought out in 1877 by Alexander Hutchinson who at the same time founded Hilea
Plantation. By the end of the 1870s, sugar mills were operating at Na'alehu, Hilea, and Honu'apo.
Though Hutchinson died in 1879, his name survived in the Hutchinson Sugar Company which
during the remainder of the nineteenth century continued to expand and consolidate existing
plantation operations in Ka'u.
Another plantation operation, the Hawaiian Agricultural Company, was established in Pahala
in 1876 by a consortium of Honolulu businessmen. An 1877 map of the Hawaiian Agricultural
Company sugarcane lands (Figure 9) shows the Pahala Mill located just east of the project area,
overlapping lands indicated as already planted in cane, as well as unplanted areas labeled as "Good,
Stony land." No roads or trails are indicated. An 1886 map (Figure 10) also depicts the location of
the mill at the "Pahala Plantation," as well as the Hutchinson Sugar Company mills at Hilea,
Honu'apo, and Na'aleahu to the southwest and the associated wharves at Honu'apo and Punalu'u.
Dorrance and Morgan (2000:110) note that Pahala's "steam driven mill was the most modern and
largest in the islands." Figure 10 curiously depicts the project area overlapping land divisions
called "Nakumu" and "Makaka;" no information about these places names was found. Figure 10
also illustrates three travel routes extending though the Pahala vicinity: two routes extend from
Na'alehu northeast, one along the coast and one mauka, joining and continuing northeast above
Pahala Mill. Another route is shown extending northeast from Nlnole/Punalu'u through Pahala,
parallel and makai of the Na'alehu route.
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
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J? i
' W
k M
I V*- ,
S /
/
/
f
\
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- • , /.¦ v. , i
— y
/
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| Project Area
Base- Map. 1877 Lyman Map of Hawaiian Agriaiiluraa Company Sugar Cana Lands (RM949)
Data Sources: CSH
)
"V~
. ft / Iff.,—'
—1| Project Area
y
f;/y
^ ¦ m f 'Sh-
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Figure 9. F.S. Lyman 1877 map of Hawaiian Agricultural Company sugarcane lands, showing the project area in relation to the Pahala
Mill and developed cane lots
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
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Legend
| Project Area
Base Map. 186S Wan Hawaiian Goverrirnem Survey of Hawa« island (RM 1439)
Data Sources: C-SH
(, f'j.iwjr't. JtU;
Figure 10. Portion of W.A. Wall's 1886 map of Hawai'i Island, showing the project area in
relation to sugar mills and harbors in windward Ka'u
AISR for the Paliala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
24
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Cultural Surveys Hawai'i Job Code: HtONAMOA 2
Background Research
By the end of the nineteenth century the Hawaiian Agricultural Company controlled almost
10,000 acres of cane land and constituted the largest plantation in the Hawaiian Islands. The
extensive agricultural endeavors taking place in Ka'u at this time were also altering the social
landscape. During the 1870s, Chinese laborers were brought in by Alexander Hutchinson. By the
time of the 1884 government census there were 568 Chinese in the district. Japanese laborers were
imported beginning in the latter 1880s and Filipinos began arriving during the first decade of the
twentieth century. Ethnic workers' camps surrounded the mill at Pahala. As the town around the
mill developed, a school was established at Pahala in 1881 to serve the children of the plantation
workers.
3.1.5 1900s
Life in the early twentieth century continued to center around the activities of the two sugar
operations, Hutchinson Sugar Plantation and the Hawaiian Agricultural Company. Pahala
continued to develop as a town. A 1906 map (Figure 11) depicts the location of a school
approximately 0.5 miles north of the current Ka'u High and Pahala Elementary School (KHPES)
campus location, and a post office in the vicinity of the project area. Figure 11 also illustrates the
approximated boundaries of sugar plantation lands (in red) in relation to the forest lands mauka (in
blue) and grazing lands east associated with Kapapala Ranch. The continued development of
roadways in the vicinity of Pahala Town is also depicted, with the addition of mauka-makai
andlateral routes between the mills at Honu'apo and Pahala (see Figure 11). The portions of these
roadways in closest proximity to Pahala are shown in more detail on the 1914 map (see Figure 8);
the uppermost road shown is labeled "Kau-Volcano Road." The lower roadway extending through
Pahala plantation is not named.
The 1914 map (see Figure 8) includes some additional details about the Pahala vicinity. A trail
is depicted with a dashed line, crossing the northern portion of the current project area and
continuing off the map to the east and west. It is unlikely that any portion of this trail remains
within the town vicinity, which has been completely altered by agricultural and residential
development. Furthermore, a meandering "Plantation Railroad" is shown, extending southwest
roughly parallel to the unnamed roadway and then curving back to the east where it stops abruptly.
Presumably this limited railroad was used to carry cut cane to the mill from some of the nearby
fields. More remarkable upon the physical landscape at this time must have been the systems of
flumes for transporting cane from fields to mills; this was the main method of transporting cane at
the time.
Railway development continued, with the establishment of lines running from Na'alehu and
Hllea to Honu'apo and from Punalu'u to Pahala. A 1929 map of Hawaiian Agricultural Co. cane
fields (Figure 12) depicts the route of the rail line extending from the mill across through the
narrow central portion of the project area and to the west; also shown are the major roadways of
the time merging along the present Maile Street corridor. The 1930 USGS topographic map (Figure
13) shows the Pahala area in better detail, including the narrow-gauge rail line running to Pahala
parallel the coastal road from Punalu'u. The expansion of the town is evident on this map, which
includes additional rows of structures along roadways and around the mill, as well as the locations
of the school (still north of the present campus), a church, a pipeline, and a large stone wall to the
southeast of the town. The route of the major roadway crossing through Pahala Town, labeled
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
25
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Background Research
Base Map. 1906 Dofin Hawaii territory SiKvey Map & Haws* Island. wiffi Lan<3 Use (RM 2060)
Data Sources: C-SH
(, tfSWJr% Jtti
Figure 11. Portion of J.M. Bonn's 1906 map of Hawai'i Island, showing the project area in
relation to Pahala Mill, school, post office, and areas of different land use
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
26
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Cultural Surveys Hawai'i Job Code: HIONAMOA2
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Project Area
MAP
T™Mt
Hawaiian Agricultural Co.
Pahala, Kau. Hawaii,
iw
Sen l | N* . W* tin
Xrmt+i t*
*
Legend
| Project Area
Scale
0 500 1,000 Meters
0 2,000 4,000 Feet
Base Map: 1929 Map of Hawaiian Agricultural Co. Cane Fields (in Conde & Best 1973:31)
Data Sources: CSH
Culturalf~fawai% jnc.
Figure 12. 1929 map of Hawaiian Agricultural Co. cane fields, showing the location of the project area
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
27
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Background Research
Legend
Project Area
Base- Map. USGS Topographic Map. Palima pomi (1930} Quadrangle
Data Sources: C-SH
Figure 13. Portion of the 1930 Palima Point USGS 7.5-minute topographic quadrangle showing
the project area in relation to the mill, school, church, roads, and railroad in the Pahala
vicinity
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
28
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Cultural Surveys Hawai'i Job Code: HtONAMOA 2
Background Research
"Volcano Road," utilizes a new eastward extension, with the portion of the older alignment that
extended north from the town is now labeled "Wood Valley Road."
The flumes and railroads in Ka'u were abandoned by the 1940s with the advent of trucking. In
the 1940s the Belt Road or Mamalahoa Highway (Route 11) was constructed through Ka'u,
running just makai of Pahala Town. A 1967 USGS map (Figure 14) shows this new route and the
continued development of the town. By this time the school had moved southwest into the heart
of the town, and a landing strip had been constructed to the northeast. All of the older road
alignments are still depicted, but not as major roadways, with the exception of a Route 15 looping
off the Belt Road along present Maile Street and Kamani Street. During this latter half of the
twentieth century the residential side-streets within Pahala were also improved with paving and
installation of the culvert at the Huapala and Ilima Streets intersection.
The 1940s Belt Road alignment appears on an undated Olson Trust map (Figure 15) reprinted
in Cleghorn (2016:13). Hand drawn annotations indicate some land uses in the area dating to the
1960s and 1970s. This map indicates the WWTP site and adjacent areas were under pasture; the
easement extending to Maile Street also crosses through a rectangular area labeled "Cane Area
Planted Aug. 1966" and a fence line "Plotted Oct. 1961." Also significant are the locations of a
"Cesspool" (LCC 1), and a concrete flume and lava tube located east of the proposed WWTP site.
This map appears to depict a portion of the former narrow-gauge railroad following a "1.8 %"
grade west of the easement extending south from Maile Street; this illustration may indicate
disturbance to or dismantling of the former railroad route by the mid-twentieth century in the area
crossed by the easement. The Olson Trust drawing also depicts numerous structures along Maile
Street, many of which are no longer present.
A 1977 aerial photo (Figure 16) indicates further expansion of the town to the east amidst large
agricultural plots. Note that the proposed WWTP plant site portion of the project area is not
cultivated in sugarcane at this time; instead, these former cane fields were being readied for
planting of the macadamia orchard that is now fully matured.
The Hawaii Agricultural Company operated until 1972 when it merged with the Hutchinson
Sugar Company to form the Kau Sugar Company, which was renamed as the Kau Agribusiness
Company in 1986 (Dorrance and Morgan 2000:112). Following the demise of the sugar industry
in other parts of the island, Kau Agribusiness Company ceased its sugar operations in 1996
(Dorrance and Morgan 2000:112).
3.1.6 Contemporary Land Use
Pahala continues to serve a small rural population supported by predominately agricultural and
livestock economies. The town is also used as a stop-over for tourists visiting Punalu'u Beach
located 5 miles southwest and/or travelling between Hilo and Kailua-Kona.
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
29
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Background Research
fi' PahaIi
Lindihg Strip
ig ng Station
T«nk // — C
VT»(»r Tank;" K»u High Sch
Pahala^l
—1 ^
Project Area
Cinder P
Cindeu
Milli
Legend
Project Area
Base Map. USG 5 Topographic Map. Pahaia (1967) Qustfangl*
Data Sources: C-SH
Scale
0 300
1,000
$00 Meiers N
1
2.000 Feet
( jikfirjt^ywXrtfy /"jfowvlrV, JfUl.
Figure 14. Portion of the 1967 Pahaia USGS 7.5-minute topographic quadrangle showing the
project area and development within Pahaia Town
AISR for the Pahaia WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
30
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Background Research
Legend
Project Area
Base Map- Undaiwf Field Map or in® Pahala Mm aod Camp (eounesy « Oise« Trusl)
Data Sources: CSH
Scale
0 so
100 Meiere N
1
150 «*> Feet J
C, JyiffVrt/ir f~fjwarX fae.
Figure 15. Portion of an undated field map of the Pahala Mill and Camp reprinted in Cleghorn
(2016:13) showing the project area in relation to plantation features
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
31
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Background Research
Project Area
Legend
~ Project Area
$00 Meters
Base Map. USGS Qrwcphowquaa Asnai Photograph. Pahala (1977) Ouadraogie
Data Sources: C-SH
Figure 16. Portion of the 1977 USGS orthophotoquad aerial photo, Pahala Quadrangle, showing
the project area and continued development of Pahala Town
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
32
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Cultural Surveys Hawai'i Job Code: HtONAMOA 2
Background Research
3.2 Previous Archaeological Research
3.2.1 Previous Archaeological Studies
Eight previous archaeological studies have been conducted in the vicinity of the current project
area in Pahala. These previous archaeological studies are presented in Table 1 and shown in Figure
17.
In 1981, Hamilton Ahlo undertook an archaeological reconnaissance for the U.S. Army Corps
of Engineers Pa'au'au Stream Flood Control project, located east of the current project area along
the Pa'au'au 2 and 'Iliokoloa Ahupua'a boundary (Ahlo 1981; see Figure 17). The study examined
an approximately 4,000-ft (1.2-km) section of Pa'au'au Stream just mauka of the Hawai'i Belt
Road (Route 11) and the adjacent embankments. Extensive prior disturbance was noted along both
sides of the stream; no archaeological features were documented, and no further work was
recommended.
In 2001, Haun and Associates conducted an archaeological assessment (no finds AIS) for an
emergency replacement of the Pa'au'au Bridge, situated east of the current project area along the
Hawai'i Belt Road in Pa'au'au 2 and 'Iliokoloa (Haun 2001; see Figure 17). The 5.256-acre project
area included the bridge over Pa'au'au Gulch, the approaches on either side of the bridge along
the highway, and adjacent areas to the east. Significant prior disturbance from agricultural and
road development and a major flooding event were noted. No archaeological features were
documented, and no further work was recommended.
In 2004, Haun and Associates conducted an AIS on 255.7 acres in Palima and Pa'au'au Ahupua'a,
northwest of the current project area (Haun and Henry 2004; see Figure 17). The study confirmed
extensive prior disturbance from modern and historic agricultural activity dating back to the latter
half of the nineteenth century. One newly recorded historic property was documented: SIHP #
-24119, a 105-m-long section of a historic irrigation flume associated with the former sugar
plantation (Figure 18). No traditional sites were identified, and no further work was recommended.
In 2006, T. S. Dye & Colleagues, Archaeologists, Inc. conducted an archaeological assessment
of a proposed cellular site within a 1,600-sq-ft portion of TMK: [3] 9-6-005:018, northwest of the
current project area in Palima and Pa'au'au 1 Ahupua'a (Jourdane and Dye 2006; see Figure 17).
Prior disturbance associated with commercial agriculture were noted. No archaeological features
were observed.
As part of a state-wide Department of Education (DOE) wastewater systems improvement
project, CSH undertook a literature review and field inspection (LRFI) for two Ka'u District
schools, including KHPES located between the northern portions of the project area (Hammatt and
Shideler 2006; see Figure 17). The LFRI included background research for the Pahala area
including LCA data and previous archaeological studies in the vicinity and noted that the school
is listed on the HRHP under the thematic group "Public Schools on the Island of Hawai'i" (SIHP
# -07522; see Figure 18). Hammatt and Shideler (2006:27) recommended on-site archaeological
monitoring for the project.
In 2009 CSH monitored the DOE wastewater systems improvements project at KHPES
(Wilkinson et al. 2010; see Figure 17). The project involved the installation of a new leach field,
eight septic tanks, and associated sewer lines. While no subsurface cultural deposits were located
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
33
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Cultural Surveys Hawai'i Job Code: HtONAMOA 2
Background Research
Table 1. Previous archaeological studies in the vicinity of the project area
UofcmuT
Typo of Study
l.ocsiliou
Results (SNIP # 50-10-69"""-)
Ahlo 1981
Archaeological
reconnaissance
Pa'au'au Stream between
Mamalahoa Hwy (Route 11)
and Wood Valley Rd,
Pa'au'au 2 and 'Iliokoloa
Ahupua'a; TMK not listed
No historic properties or cultural
materials identified
Haun 2001
Archaeological
inventory survey
(recorded as an
archaeological
assessment)
Pa'au'au Bridge, Pa'au'au 2
and 'Iliokoloa Ahupua'a,
portions TMKs: [3] 9-6-
002:047, 9-6-012:012, 9-6-
013:005, 9-6-023:043
No historic properties or cultural
materials identified
Haun and
Henry 2004
Archaeological
inventory survey
Palima and Pa'au'au 1
Ahupua'a, TMKs: [3] 9-6-
005:017, 018 and 9-6-
006:004
One historic property
documented: SIHP # -24119,
historic irrigation flume
associated with sugarcane
cultivation
Dye and
Jourdane
2006
Archaeological
inventory survey
(recorded as an
archaeological
assessment)
Palima and Pa'au'au 1
Ahupua'a, TMK: [3] 9-6-
005:018 por.
No historic properties or cultural
materials identified
Hammatt and
Shideler 2006
Literature review
and field
inspection
Two DOE schools in Ka'u
District, TMKs: [3] 9-6-
005:008, 039; 9-5-009:006,
015
Noted listing of KHPES on the
HRHP; on-site archaeological
monitoring recommended
Wilkinson et
al. 2010
Archaeological
monitoring
Ka'u High and Pahala
Elementary School,
Pa'au'au Ahupua'a, TMKs:
[3] 9-6-005:008, 039
Noted listing of KHPES on the
HRHP; one other historic
property documented: SIHP #
-27570, lava tube
Escott 2013
Archaeological
inventory survey
Ka'u High and Pahala
Elementary School, TMK:
[3] 9-6-005:008 por.
Explored and mapped
previously recorded SIHP #
-27570 (lava tube system),
documenting three new features;
documented one new historic
property, a historic-era burial
(SIHP # -29501) within the
SIHP # -27570 lava tube
Cleghorn
2016
Archaeological
field inspection
Pa'au'au 1 Ahupua'a, TMK:
[3] 9-6-002:018
Documented scattered surface
artifacts and a lava tube within
former plantation land; AIS
recommended
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
34
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Background Research
Dye & Jourdane 2006
Hammatt & SNdeler 2006
Wilkinson et al. 2010
Haun 2001
Cleghorr»20l6
Legend
I I Project Area
Y/A Previous Archaeological Study Area
Base Map. USG 5 Topographic Map. Pahala 0995) Qus^anjic
Data Sources: C-SH
Scale
o
300
1.000
600 Meters "
2.000 Feet
(_ itkttrjlrtfy /'?,
Figure 17. Portion of the 1995 Pahala USGS 7.5-minute topographic quadrangles showing
previous archaeological studies in the vicinity of the project area
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
35
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2 Background Research
Figure 18. Portion of the 1995 Pahala USGS 7.5-minute topographic quadrangles showing
locations of sites documented in previous archaeological studies in the vicinity of the
project area
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
36
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Cultural Surveys Hawai'i Job Code: HtONAMOA 2
Background Research
during excavation, a lava tube system was breached and assigned a site number (SIHP # 50-10-
69-27570) despite an absence of cultural modifications to the breached portion of the tube system.
The location of SIHP # -27570 is shown on Figure 18.
In 2012, Scientific Consultant Services, Inc., conducted an AIS for a proposed gymnasium and
disaster relief shelter within a 4.5-acre portion of the KHPES campus, adjacent to but outside the
northeastern portion of the current project area (Escott 2013; see Figure 17). The SIHP # -27570
lava tube system was also explored and mapped. A burial site was found within the tube and
designated SIHP # 50-10-69-29501 (see Figure 18). This burial is located away from the limits of
the current project area. Escott (2013) describes the lava tube system as follows:
The lava tube system containing Site 27570 and Site 29501 has three main branches
converging near the tube system opening under a modern storm drain grate [Figure
19], The southern branch does not contain archaeological sites. Sites 27570 and
29501 are located in the northern and western branches of the tube system,
respectively.
The western branch includes two tubes that are situated parallel to each other and
are connected at two points. The western branch of the tube system is closed off by
collapse at its western terminus. Site 29501 is located in the northern tube of the
western branch, roughly 35.0 meters in from the storm grate opening [Figure 20],
The northern branch of the tube system is accessed through an opening in the floor
of the western tube system. The floor of the northern branch is approximately 3.0
meters below the floor of the western branch tube . . . [Escott 2013:17]
No other archaeological features were located within the 4.5-acre project area. Escott (2013:36)
noted SIHP # -29501 would "be preserved in accordance with a Hawai'i Island Burial Council-
approved Burial Treatment Plan," and recommended archaeological monitoring of any future
ground disturbing work "near the northern and western branches of the tube system."
In 2016 Pacific Legacy, conducted archaeological field inspection of TMK: [3] 9-6-002:018,
addressing an earlier and larger version of the WWTP project (Cleghorn 2016; see Figure 17).
Extensive disturbance associated with development of the macadamia nut orchard was noted.
Surface artifacts were encountered within a portion of the macadamia nut orchard that is no longer
within the project area limits (see Figure 18). These artifacts included a single traditional
hammerstone and fragmental historic glass and ceramics. The report also discussed a lava tube
known to exist between the vicinity of the present Royal Hawaiian Orchards processing plant and
KHPES; an opening to the tube on the processing plant property was filled in sometime in the past
to prevent access. Pacific Legacy recommended discussion with SHPD regarding project historic
preservation requirements, noting that an AIS would likely be required. It was also recommended
that the vicinity of the lava tube entrance known to exist near the processing plant be excluded
from the project area (Cleghorn 2016:7).
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
37
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
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27570
Feature 3
27570
Fcalurc 2
29501
meters
,27570
Feature I
Figure 19. Aerial photo showing the Escott (2013) project area and site locations (Escott 2013:18)
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
38
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Background Research
Figure 20. Survey map of SIHP # -29501 burial and SIHP # -27570 lava tube ceiling thicknesses
(Escott 2013:19); note the tube is set back from Kamani Street and Puahala Street
where a portion of the current project area is located
AISR for the Paliala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
39
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Background Research
3.3 National Register-Eligible Historic Properties in the Vicinity
Two historic properties near the project APE have been evaluated as eligible for listing on the
National Register: Ka'u High and Pahala Elementary School and the Mamalahoa Highway.
Neither of these sites are within the project APE.
3.3.1 Ka'u High and Pahala Elementary School
Ka'u High and Pahala Elementary School, located north of and between portions of the project
APE (see Figure 18), is part of the thematic grouping "Public Schools on the Island of Hawai'i"
(SIHP # 50-10-69-07522). SIHP # -07522 is listed on the Hawai'i Register. The school was
nominated to the National Register in May 2002 under the name "Ka'u High and Pahala
Elementary School." The nomination form lists the period of significance as 1935-1950 and areas
of significance as Criteria A (education/social history value) and C (architecture value). This
historic property has not been listed on the National Register.
3.3.2 Mamalahoa Highway
SIHP # 50-10-47-30187 comprises the former and present alignments of the Mamalahoa
Highway (Highway 11/Hawai'i Belt Road); an actively used and contemporary portion of this
roadway is located adjacent to the southern boundary of the proposed WWTP site (see Figure 18).
Under a prior study (Clark et al. 2014:81) this historic property was evaluated as eligible for
inclusion on the National Register under Criteria A and D for its importance in and information
about "late nineteenth and early twentieth events in establishing a regional transportation network
that has its roots in antiquity." The portion of the roadway adjacent to the project area was
constructed in the 1940s. This historic property has not been nominated for listing on the Hawai'i
Register or National Register.
3.4 Background Summary and Predictive Model
Ka'u is a large district known for its dynamic natural environment and fierce people. Despite
the impressions of early visitors that the district was a barren wasteland, its abundant and varied
resources supported a substantial population. However, in pre-Contract times Pahala was not a
habitation center. Villages were located at the coast or in places like Wai'ohinu to the southwest
where water and other resources were more abundant.
In the first 50 years after Contact, the population of Ka'u declined dramatically due to
introduced disease, natural disasters, and outmigration to developing economic centers. Missions
were established in Wai'ohinu and Punalu'u. In the Mahele, a handful of kuleana claims in the
Pahala vicinity indicate land use associated with residence and small-scale farming. The vast
majority of Hionamoa Ahupua'a was awarded as LCA 9971:12 to the ali'i William Pitt
Leleiohoku; this award overlaps the proposed WWTP site. A number of Land Grants were also
made in the Pahala vicinity, including Land Grant 02446 to Kamalo overlapping the northern
portion of the project area.
The historic era in Ka'u was dominated by the development of the livestock and commercial
agriculture industries. Several large ranching outfits were established in Ka'u in the mid-1800s,
including Kapapala Ranch located a relatively short distance east of present Pahala Town.
However, it was sugar plantations that produced the most widespread and lasting impact on the
physical and social landscape of Ka'u. The Hawaiian Agricultural Company was established in
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
40
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Cultural Surveys Hawai'i Job Code: HtONAMOA 2
Background Research
the Pahala vicinity in 1876 and quickly grew. A mill was established and the village of Pahala
began to develop with the influx of plantation workers and their families. The majority of the
project area was under cane at some point in time.
Previous archaeological research in the vicinity has documented very little evidence of pre-
Contact land use, partially due to widespread land alteration for the sugar plantation. Historic
plantation remnants such as cane flumes have been documented in the area. Lava tubes are also
known to be present in and around Pahala. A lava tube system (SIHP # -27570) has been
documented to the north and east of the project area; the lava tube contains a historic to modern
refuse dump and a historic burial site (SIHP # -29501) located on the KHPES campus. The school
itself is on the HRHP as part of a thematic group of historic Hawai'i Island schools (SIHP #
-07522). The Mamalahoa Highway (SIHP # 50-10-47-30187) located just south of the project area
has been evaluated as eligible for inclusion on the NRHP but has not been nominated. The current
project area does not encroach on any previously documented portions of the lava tube system, the
school campus, or the Mamalahoa Highway.
Given the known traditional land use in this area and the impacts of continued agricultural and
residential development, surface pre-Contact sites are not expected within the project area. The
modern development of the macadamia nut orchard has likely also obliterated any plantation-era
sites once present in that portion of the project area; surface features associated with the former
plantation village and/or historic transportation routes may be present in other portions of the
project area. Subsurface historic features related to sugar cultivation could be present throughout
the project area. Furthermore, additional lava tubes may be present and have the potential to
contain pre- and/or post-Contact archaeological features, including human burials.
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
41
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Results of Fieldwork
Section 4 Results of Fieldwork
CSH completed the fieldwork component of this archaeological inventory survey under
archaeological fieldwork permit number 17-08, issued by the SHPD pursuant to HAR §13-282.
Fieldwork was conducted on 18 September 2018, 1-4 October 2018, and 10 January 2019. This
work required approximately 8 person-days to complete.
The fieldwork comprised a 100% pedestrian inspection of the project area and a program of
subsurface testing. The results of the pedestrian inspection are provided in Section 4.1 and the
subsurface testing results are provided in Section 4.2.
Two historic properties characterized as historic-era transportation routes (SIHP #s 50-10-69-
31088 and -31089) were documented within the project area (Figure 21; see Section 5 for full site
descriptions). No pre-Contact features or lava tubes were encountered within the project area.
4.1 Pedestrian Inspection Results
A 100% pedestrian inspection was undertaken with the field crew spaced 3-5 m apart depending
upon the density of the vegetation. Ground visibility was very good throughout most of the
inspection area.
The pedestrian inspection began along the easement located within TMK: [3] 9-6-005:036. This
area has been completely disturbed by prior development. From Maile Street, the easement extends
northwest along an existing paved driveway to an open, asphalted area located along the southern
side of the private roadway used to access Ka'ala'iki Road (Figure 22). This asphalt area is
surrounded by previously graded land presently overgrown with California grass. The easement
crosses the roadway, entering the former sugar plantation maintenance yard. The easement extends
along a dirt driveway between two large, old maintenance buildings that are still in use (Figure
23). These buildings are located outside the easement and project area. North of these structures is
a graded, grassy parking area; the easement crosses this parking area and through a previously
disturbed, heavily vegetated area containing scrap metal and miscellaneous trash located along the
makai side of Hima Street (Figure 24). An earthen storm water drainage channel extends along the
makai side of Hima Street southwest from a culvert at Huapala Street and contains scattered
modern household trash (Figure 25).
Upon exiting the proposed easement within TMK: [3] 9-6-005:036, the survey continued along
various residential streets within the project area, including Pikake Street, Kamani Street, Puahala
Street, Huapala Street, Hala Street, Hinano Street, and Ilima Street (Figure 26 through Figure 29).
These streets consist of one-to-two-lane asphalt travel ways with no curbing or sidewalks. These
streets employ variable use of standard signage and center and outer lane striping. A four-way
crosswalk is located at the Pikake Street and Kamani Street intersection near the KHPES campus
(Figure 30). Kamani Street dead ends at the school and the project area does not cross onto the
campus. The homes lining these residential streets outside the project area are of variable age but
are commonly of post-and-pier "plantation style" design with corrugated metal roofing. Slight
linear depressions are typically present along one side of each street within the asphalt or grassy
shoulder, providing drainage for runoff; these drainages are also outside the asphalt travel ways
comprising the project area. A single culvert constructed in the 1960s was observed running under
the modern Huapala Street surface adjacent to the Ilima Street intersection (Figure 31); this culvert
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
42
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Figure 21. Aerial photo of the project area (Google Earth 2013) showing the locations of newly
documented historic properties
AISR for the Paliala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
43
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Figure 22. Photo showing the portion of the easement in TMK: [3] 9-6-005:036 that extends
from Maile Street along an existing asphalt driveway; view northwest
Figure 23. Photo showing the portion of the easement in TMK: [3| 9-6-005:036 that passes
through the old plantation maintenance yard; the structures present to either side are
outside the project area; view to northwest
AISR for the Paliala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
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AISR for the Paliala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i 4 5
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
Figure 24. Photo showing the forested area between the maintenance yard and Hima Street at the
northern end of the easement in TMK: [3] 9-6-005:036; view to northwest
Figure 25. Photo showing the location where the easement in TMK: [3] 9-6-005:036 exits at
Ilima Street (frame right); the earthen drainage channel extending from the Huapala
Street culvert is beneath the grass to the left of the road; view to southwest
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Cultural Surveys Hawai'i Job Code: HIONAMOA2
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Figure 26. Photo looking down Huapala Street; note linear drainage in grassy lawn on left side of
photo; view to southeast
11
Figure 27. Photo looking up Ilima Street; note drainage in grassy shoulder on right side of photo;
view to northwest
AISR for the Paliala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
46
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Figure 28. Photo looking up Iiinano Street from the eastern Huapala Street intersection; view to
northwest
Figure 29. Photo looking up Hala Street from the Flinano Street intersection; view to north
AISR for the Paliala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
47
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Cultural Surveys Hawai'i Job Code: HIONAMOA2
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Figure 31. Photo of the culvert located at the Huapala Street and Ilima Street intersection; view
to northeast
AISR for the Paliala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
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diverts runoff into the channel located along the makai side of Ilima Street (see Figure 25).
Pikake Street is an arterial route in Pahala lined with commercial establishments in addition to
residences. Research has indicated this present roadway is a portion of a historic road alignment
(SIHP # -31088, Wood Valley Road/Coastal Road; see Figure 21 and Section 5.1). A commercial
center at the Pikake Street and Kamani Street intersection includes a bank, drugstore, post office,
and the Mizuno Superette (Figure 32). The southern portion of Pikake Street approaching its
terminus at Maile Street is technically a private roadway located within TMK: [3] 9-6-005:044.
Pikake Street at the Maile Street intersection includes turn lanes (Figure 33). A broad asphalt
parking area is located along the northeastern side of the intersection, fronting the offices of Olson
Trust. On the western side of this intersection are the offices of Kau Agribusiness Company,
comprising two plantation-era buildings (see Figure 33). Within the grassy yard fronting these
buildings is an old Corliss steam engine once used by the sugar mill. These structures and the
engine are located outside the project area.
The inspection proceeded southwest down Maile Street from the Pikake Street intersection. The
project area includes an approximately 0.25-mile portion of Maile Street located between the old
mill camp road and the Lower Moaula Road intersection (Figure 34 and Figure 35). Research has
indicated this present roadway is a portion of a historic road alignment (SIHP # -31089, Volcano
Road; see Figure 21 and Section 5.2). Along the makai side of Maile Street in this area are an old
plantation house (which has been subsequently used as a store) and visible remnants of the mill
and theater; all these features are located outside the project area. Along the mauka side of Maile
Street in this area are a Hawaiian Telcom building (see Figure 34), a few old plantation homes
serving as residences, and the asphalt parking area noted previously, as well as a section of concrete
sidewalk. Both sides of Maile Street exhibit extensive prior disturbance. No remnants of the old
plantation railroad were observed.
From the vicinity of the Maile Street/Lower Moaula Road intersection, the inspection continued
southeast along the proposed utility easement within TMK: [3] 9-6-002:018. Closest to Maile
Street the easement briefly crosses a previously graded area overgrown in California grass and
other weeds, before entering the macadamia orchard. This easement extends through the orchard
to the proposed WWTP plant site. The orchard contains linear rows of mature trees watered via
surface irrigation lines (Figure 36). Fallen macadamia nuts, leaf litter, and relatively few small
stones are present on the ground surface. Signs of surface water runoff were observed throughout
the orchard. An asphalt road accessing the processing plant from Maile Street forms the mauka
border of the proposed plant site (Figure 37). Bulldozer push piles were observed along the Belt
Road edge and down the center of the orchard (Figure 38 and Figure 39), and bulldozer blade scars
are frequently visible on small exposures of lava bedrock throughout the orchard. During the
survey fieldwork CSH crew observed operation of a machine in an adjacent orchard used to harvest
macadamia nuts off the ground; this machine was observed to scatter small rocks and other natural
materials around.
A few scattered pieces of highly fragmental glass and ceramics were observed in the vicinity
of the proposed Test Excavation (TE) 2 location in the northern-central portion of the proposed
site; testing at this location did not uncover any subsurface cultural materials (see Section 4.2.2).
The nature and density of the fragmental cultural materials observed on the surface within the
macadamia orchard were not sufficient to comprise a significant cultural deposit. These materials
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
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Figure 32. Photo looking up Pikake toward the Kamani Street intersection; commercial center is
visible to the right; view to north
Figure 33. Photo showing the Pikake Street terminus at Maile Street; Flawaiian Telcom building
is on opposite corner; view to southwest
AISR for the Paliala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
50
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Figure 34. Photo of a portion of Maile Street within the project area, showing the Pikake Street
intersection in the background and the HELCO building (left frame); view to northeast
Figure 35. Photo of a portion of Maile Street in the project area, showing the Lower Moaula
Road fork in the far background; view to southwest
AISR for the Paliala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
51
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Figure 36. Representative photo of the macadamia orchard; note the surface irrigation lines
between the trees; view to southwest
Figure 37. Photo of the paved road that passes through the macadamia orchard between Maile
Street and the macadamia nut husking plant; this road forms the mauka boundary of
the proposed WWTP site portion of the project area; view to northeast
AISR for the Paliala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
52
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Figure 38. Photo showing the margin of the macadamia orchard at the southeastern corner of the
proposed WWTP site portion of the project area; a dozer push pile is present beneath
the grass along the left side of the photo; view to southwest
Figure 39. Photo showing a portion of the linear push pile/berm located along the wind break
bisecting the macadamia orchard; view to southwest
AISR for the Paliala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
53
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Results of Fieldwork
were similar in nature to those scattered historic artifacts encountered by Cleghorn (2016) in the
portion of the orchard north of the current project area. No traditional artifacts like the
hammerstone recorded by Cleghorn (2016) were encountered within the current project area.
The last portion of the project area to be inspected was the location of existing LCC 1 and
associated sewer easement in TMK: [3] 9-6-002:016. The sewer line easement was recently
cleared from an area just below Maile Street; the areas surrounding the cleared easement are fallow
with overhead California grass. Ground visibility was excellent along the maintained easement,
allowing for relocation of a sewer manhole (Figure 40) and cleanout along the existing sewer line.
The LCC 1 location at the makai end of the maintained easement is not marked on the ground
surface; a low dirt mound is believed to indicate its location (Figure 41). No remnants of the old
plantation railroad were observed.
4.2 Subsurface Testing Results
Subsurface testing was conducted within the proposed WWTP site portion of the project area,
to determine the nature of the sediments and the potential for subsurface archaeological features
including but not limited to buried cultural deposits and/or culturally modified lava tubes. This
area is a mature macadamia nut orchard. The subsurface testing program involved mechanical
excavation of seven test trenches measuring approximately 5 m (16.5 ft) long and 1 m (3.2 ft)
wide, with an average depth of 1.6 m (5.2 ft). All seven test excavations terminated at bedrock.
The locations of the excavation trenches are depicted on Figure 42 and Figure 43. An archaeologist
was present to monitor the excavations and document the exposed stratigraphy, which was
recorded upon completion of each trench. No subsurface features or deposits were exposed during
excavation, which is consistent with known prior disturbance from sugarcane cultivation and the
present macadamia orchard. The stratigraphic information, profile drawings, and photographs
taken at each trench follow.
The subsurface testing program generally revealed two distinct natural sedimentary layers
located atop decomposing bedrock: a dark, rich silty loam A horizon overlying a dusky red silty
clay loam B horizon. These findings are consistent with the USGS Soil Survey (Sato et al. 1973)
sediment types depicted in Figure 7 and with past and present agricultural land use. The exception
was in TE 1, which contained three stratigraphic layers. Here, the two natural sediment layers are
interposed by a layer of ash deposit. The ash was deposited and subsequently covered up at some
point in time. Of all the test excavations, TE 1 is in closest proximity to the macadamia but
processing plant (see Figure 42) and may be the result of some activity at the former plantation.
No charcoal or cultural materials were present within the ash layer.
4.2.1 Test Excavation 1 (TE 1)
Test Excavation 1 (TE 1) was located in the northern corner of the proposed WWTP site portion
of the project area, where a lagoon is planned for development (see Figure 42 and Figure 43).
Figure 44 shows TE 1 marked out with orange flagging tape prior to excavation. TE 1 measured
approximately 5 m long and 1 m wide. TE 1 was excavated to a depth of up to 230 cm below
surface (cmbs) through two layers of natural Waiaha series sediment (Strata I and III) interposed
by a layer of deposited ash (Stratum II), and terminated at basalt bedrock (Figure 44 through Figure
46 and Table 2). No charcoal or cultural materials were observed within TE 1.
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
54
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Cultural Surveys Hawai'i Job Code: HIONAMOA2
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Figure 40. Photo of the sewer manhole located along the existing, maintained sewer easement
within TMK: [3] 9-6-002:016; view to southwest
Figure 41. Photo showing the LCC 1 location at the makai terminus of the existing, maintained
sewer easement within TMK: [3] 9-6-002:016; view to south
AISR for the Paliala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i 5 5
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
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Cultural Surveys Hawai'i Job Code: HIONAMOA2
Results of Fieldwork
Legend
I I Project Area f >~est Excavation
S-ssa- Map. Google Earth A«nal Imagery (2013)
Data Sources: CSH
Scale
0 SO tQO Meters ^
150
ttvifjrhl.
Figure 42. Aeri al photograph showing the locati ons of the seven test excavation trenches within the proposed WWTP site portion of
the project area (TE 1 through TE 7) (Google Earth 2013)
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
56
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Cultural Surveys Hawai'i Job Code: HIONAMOA2
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ore i?a nows
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Bass- Map. Pahaia WWTP Preliminary Site Plan
Data Sources: CSH
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Fi gure 43. Preliminary WWTP site plan, overlain with locations of the seven test excavation trenches within the proposed WWTP site
portion of the project area (TE 1 through TE 7) (site plan courtesy of client, with Google Earth 2013 overlay added)
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por.. 9-6-005:036 por. and 044, and County Right-of-Ways
57
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Cultural Surveys Hawai'i Job Code: HIONAMOA2
Results of Fieldwork
Figure 44. Photo of TE 1 marked out with flagging tape prior to excavation; view to southwest
Figure 45. Photo of TE 1 northwest sidewall profile; view to northwest
AISR for the Paliala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
58
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Results of Fieldwork
*r tm
TE-1
Surface
• BwJfock
Sit il
Sir. Hi
^ -A -A
A
!«> A AA A ^\, /-x A A -"**
A A- ^
A ./
IJa,esc»taiMl Btdrack
Figure 46. Profile of TE 1 northwest sidewall
Table 2. TE 1 stratigraphic description
Si nilii in
Depth
(cnihs)
Description
I
0-72
A horizon; 7.5YR 2.5/3, very dark brown; silty loam; weak, fine,
granular structure; dry, loose, weak cementation consistence; slightly
plastic; terrigenous sediment origin; clear, smooth lower boundary; roots
common; no cultural material present; natural Waiaha series sediment
II
72-123
Ash; 5Y 7/1, light gray; ash; structureless (single-grain); dry, loose, no
cementation consistence; non-plastic; unknown origin; diffuse, wavy
lower boundary; few roots; no charcoal or cultural material present; ash
deposit possibly associated with former plantation
III
123-230
B horizon; 2.5YR 3/4, dusky red; silty clay loam; moderate, medium,
subangular blocky structure; dry, weakly coherent, weak cementation
consistence; slightly plastic; terrigenous sediment origin; abrupt, wavy
lower boundary, terminated at bedrock; few roots; no cultural material
present; natural Waiaha series sediment
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
59
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Results of Fieldwork
4.2.2 Test Excavation 2 (TE 2)
Test Excavation 2 (TE 2) was located within the northern-central section of the proposed
WWTP site portion of the project area, where a wetland is planned for development (see Figure
42 and Figure 43). Figure 47 shows TE 2 marked out with orange flagging tape prior to excavation.
TE 2 measured approximately 5 m long and 1 m wide. TE 2 was excavated to a depth of up to
120 cmbs through two layers of natural Waiaha series sediment (Strata I and II) and terminated at
basalt bedrock (Figure 48, Figure 49, and Table 3). Despite the presence of a few small pieces of
highly fragmental historic materials on the ground surface in the TE 2 locale (see Section 4.1), no
cultural materials were observed within TE 2.
4.2.3 Test Excavation 3 (TE 3)
Test Excavation 3 (TE 3) was located near the center of the proposed WWTP site portion of the
project area, where a lagoon is planned for development (see Figure 42 and Figure 43). Figure 50
shows TE 3 marked with orange flagging tape prior to excavation. TE 3 measured approximately
5 m long and 1 m wide. TE 3 was excavated to a depth of up to 180 cmbs through two layers of
natural Waiaha series sediment (Strata I and II) and terminated at basalt bedrock (Figure 51, Figure
52, and Table 4). No cultural materials were observed within TE 3.
4.2.4 Test Excavation 4 (TE 4)
Test Excavation 4 (TE 4) was located along the eastern boundary of the proposed WWTP site
portion of the project area, where a grove is planned for development (see Figure 42 and Figure
43). Figure 53 shows TE 4 marked with orange flagging tape prior to excavation. TE 4 measured
approximately 5 m long and 1 m wide. TE 4 was excavated to a depth of up to 155 cmbs through
two layers of natural Waiaha series sediment (Strata I and II) and terminated at basalt bedrock
(Figure 54, Figure 55, and Table 5). No cultural materials were observed within the TE 4.
4.2.5 Test Excavation 5 (TE 5)
Test Excavation 5 (TE 5) was located in the southeastern section of the proposed WWTP site
portion of the project area, where a grove is planned for development (see Figure 42 and Figure
43). Figure 56 shows TE 5 marked with orange flagging tape prior to excavation. TE 5 measured
approximately 5 m long and 1 m wide. TE 5 was excavated to a depth of up to 162 cmbs through
two layers of natural Waiaha series sediment (Strata I and II) and terminated at basalt bedrock
(Figure 57, Figure 58, and Table 6). No cultural materials were observed within TE 5.
4.2.6 Test Excavation 6 (TE 6)
Test Excavation 6 (TE 6) was located along the western boundary of the proposed WWTP site
portion of the project area, where a grove is planned for development (see Figure 42 and Figure
43). Figure 59 shows TE 6 marked with orange flagging tape prior to excavation. TE 6 measured
approximately 5 m long and 1 m wide. TE 6 was excavated to a depth of up to 160 cmbs through
two layers of natural Naalehu series sediment (Strata I and II) and terminated at basalt bedrock
(Figure 60, Figure 61, and Table 7). No cultural materials were observed within TE 6.
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
60
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Figure 47. Photo of TE 2 marked out with flagging tape prior to excavation; view to southeast
Figure 48. Photo of TE 2 southwest sidewall; view to northeast
AISR for the Paliala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
61
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
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——~ te-2
•Lr ' ,'I™6fER5 j '
Svifm
^7C/n ^/x /'
-A t
l
' 3«vil Itatiutk
Figure 49. Stratigraphic profile of TE 2 southwest sidewall
Table 3. TE 2 stratigraphic description
Sli'iiliiin
Depth
(cmhs)
Description
I
0-45
A horizon; 7.5YR 2.5/3, very dark brown; silty loam, weak, fine,
granular structure; dry, loose, weak cementation consistence; slightly
plastic; terrigenous sediment origin; diffuse, smooth lower boundary;
roots common; no cultural material present; natural Waiaha series
sediment
II
45-120
B horizon; 2.5YR 3/4, dusky red; silty clay loam; moderate, medium,
subangular blocky structure; dry, weakly coherent, weak cementation
consistence; slightly plastic; terrigenous sediment origin; abrupt, smooth
lower boundary, terminated at bedrock; few roots; no cultural material
present; natural Waiaha series sediment
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
62
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Cultural Surveys Hawai'i Job Code: HIONAMOA2
Results of Fieldwork
Figure 51. Photo of TE 3 west sidewall; view to northeast
AISR for the Paliala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
63
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Results of Fieldwork
137" TN
TE-3
,-OPWKTHW
Surface
sc-
150-
SIR I
Sir. II
\ f\ ¦ ¦ '\ S\ S\ S\ S\ /\ ^ ^ 4 t v , /V A. ^ ^
Uimfavattd ftedrnck
300-
Figure 52. Stratigraphic profile of TE 3 northeast sidewall
Table 4. TE 3 stratigraphic description
Si nilii in
Depth
(cnihs)
Description
I
0-82
A horizon; 7.5YR 2.5/3, very dark brown; silty loam; weak, fine,
granular structure; dry, loose, weak cementation consistence; slightly
plastic; terrigenous sediment origin; diffuse, smooth lower boundary;
roots common; no cultural material present; natural Waiaha series
sediment
II
82-180
B horizon, Natural; 2.5YR 3/4, dusky red; silty clay loam; moderate,
medium, subangular blocky structure; dry, weakly coherent, weak
cementation consistence; slightly plastic; terrigenous sediment origin;
abrupt, smooth lower boundary, terminated at bedrock; few roots; no
cultural material present; natural Waiaha series sediment
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
64
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Cultural Surveys Hawai'i Job Code: HIONAMOA2
Results of Fieldwork
Figure 53. Photo of TE 4 marked out with flagging tape prior to excavation; view to south
Figure 54. Photo of TE 4 northwest sidewall; view to northwest
AISR for the Paliala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
65
-------
Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Results of Fieldwork
«*TM
HlEBfUIMPtS
TE-4
Surfact
I /
~
m-
m-
»•
s«r,i
Ktr.ll
/"\ S\
S\
•A, ^ ,/\ /\ /\
/V
/x ^ ^ •
Figure 55. Stratigraphic profile of TE 4 northwest sidewall
Table 5. TE 4 stratigraphic description
Mmliim
Depth
(cmhs)
Description
1
i) (-,()
A horizon, 7 5YR 2 5 3, \ciy dark hroun, weak, line, granular sliiicliiie,
dry, loose, weak cementation consistence; slightly plastic; terrigenous
sediment origin; clear, smooth lower boundary; roots common; no
cultural material present; natural Waiaha series sediment
II
60-155
B horizon; 2.5YR 3/4, dusky red; silty clay loam; moderate, medium,
subangular blocky structure; dry, weakly coherent, weak cementation
consistence; slightly plastic; terrigenous sediment origin; abrupt, wavy
lower boundary, terminated at bedrock; few roots; no cultural material
present; natural Waiaha series sediment
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
66
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Cultural Surveys Hawai'i Job Code: HIONAMOA2
Results of Fieldwork
Figure 56. Photo of TE 5 marked out with flagging tape prior to excavation; view to southwest
Figure 57. Photo of TE 5 southwest sidewall; view to south
AISR for the Paliala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
67
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Results of Fieldwork
MO" TN
a IS 50 CENTIMETERS
TE-5
Surface
= Bedrock
Mr. I
50-
100-
S
-------
Cultural Surveys Hawai'i Job Code: HIONAMOA2
Results of Fieldwork
Figure 59. Photo of TE 6 marked out with flagging tape prior to excavation; view to southwest
Figure 60. Photo of TE 6 southeast sidewall; view to southeast
AISR for the Paliala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
69
-------
Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Results of Fieldwork
rtr th
0 » mcmmmnm
TE-6
Surface
tfroefs
V"
50-
100-
/\ s*
230-
250-
300-
Str.f
Stnii
/\ /\ /\ ,A. y\
""X S\ ,/\ /X /x /x
/X /X /
li«n)wk
Figure 61. Stratigraphic profile of TE 6 southeast sidewall
Table 7. TE 6 stratigraphic description
Si nilii in
Dcplli
(cmhs)
Description
I
0-70
A horizon; 7.5YR 2.5/3, very dark brown; weak, fine, granular structure,
dry, loose, weak cementation consistence; slightly plastic; terrigenous
sediment origin; clear, smooth lower boundary; roots common; no
cultural material present; natural Naalehu series sediment
II
70-160
B horizon, Natural; 2.5YR 3/4, dusky red; silty clay loam; moderate,
medium, subangular blocky structure; dry, weakly coherent, weak
cementation consistence; slightly plastic; terrigenous sediment origin;
abrupt, smooth lower boundary, terminated at bedrock; few roots; no
cultural material present; natural Naalehu series sediment
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
70
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Results of Fieldwork
4.2.7 Test Excavation 7 (TE 7)
Test Excavation 7 (TE 7) was located in the western corner of the proposed WWTP site portion
of the project area, where a grove is planned for development (see Figure 42 and Figure 43). Figure
62 shows TE 7 marked with orange flagging tape prior to excavation. TE 7 measured
approximately 5 m long and 1 m wide. TE 7 was excavated to a depth of up to 175 cmbs through
two layers of natural Naalehu series sediment (Strata I and II) and terminated at basalt bedrock
(Figure 63, Figure 64, and Table 8). No cultural materials were observed within TE 7.
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
71
-------
Cultural Surveys Hawai'i Job Code: HIONAMOA2
Results of Fieldwork
Figure 62. Photo of TE 7 marked out with flagging tape prior to excavation; view to southwest
Figure 63. Photo of TE 7 south sidewall; view to southeast
AISR for the Paliala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
72
-------
Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Results of Fieldwork
231* TH
o, » ;»ctniiiscrosS
50-
100-
150-
200-
m-
300-
/\ /s
TF-7
Suitae#
Mr. II
Bedrock
^ndrock
Figure 64. Stratigraphic profile of TE 7 southeast sidewall
Table 8. TE 7 stratigraphic description
Si nilii in
Dcplli
(cmhs)
Description
I
0-90
A horizon; 7.5YR 2.5/3, very dark brown; weak, fine, granular structure,
dry, loose, weak cementation consistence; slightly plastic; terrigenous
sediment origin; clear, smooth lower boundary; roots common; no
cultural material present; natural Naalehu series sediment
II
90-175
B horizon; 2.5YR 3/4, dusky red; silty clay loam; moderate, medium,
subangular blocky structure; dry, weakly coherent, weak cementation
consistence; slightly plastic; terrigenous sediment origin; abrupt, wavy
lower boundary, terminated at bedrock; few roots; no cultural material
present; natural Naalehu series sediment
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
73
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Cultural Surveys Hawai'i Job Code: HINAMOA 2
Historic Property Descriptions
Section 5 Historic Property Descriptions
Two historic properties (historic-era road alignments) were identified within the project area
during this AIS. They are summarized in Table 9 and their distributions are depicted on Figure 21.
Table 9. Sites identified within the current project area
SIMP #(50-10-69)
l-'orm:il Type
I' ll net ion
-31088
Road alignment (Volcano Road)
Transportation
-31089
Road alignment (Wood Valley Road/Coastal Road)
Transportation
5.1 SIHP # 50-10-69-31088
FORMAL TYPE:
Road (Wood Valley Road/Coastal Road)
FUNCTION:
Transportation
NUMBER OF FEATURES:
1
AGE:
Late 1800s-1920s
TAX MAP KEY:
[3] 9-6-005:999 (county right-of-way)
LAND JURISDICTION:
C ounty of Hawai' i
PREVIOUS DOCUMENTATION:
None
SIHP # 50-10-69-31088 consists of a 1.16-km (0.72-mile) section of the historic Wood Valley
Road/Coastal Road alignment located within the current project area (see Figure 21). The section
of this alignment within the project area follows the present Maile Street and Pikake Street
alignments located between the Lower Moaula Road fork and Pakalana Street on the west and
northern edges of Pahala Town, respectively (see Figure 4). Construction of the modern Maile
Street and Pikake Street roadways, which are approximately 5-10 m (16.5-33 ft) wide, has
impacted all the constructed elements of the corresponding portions of the former Wood Valley
Road/Coastal Road roadway (see Figure 32 through Figure 35).
Background research, particularly examination of historic maps from the Pahala and greater
Ka'u areas, indicate a coastal route extending from Na'alehu to the Punalu'u vicinity and then east
and north through Pahala Town, where it merged with the original (late 1800s) "Volcano Road"
alignment further upslope (see Figure 8, Figure 10, Figure 11, Figure 65, and Figure 66). With the
construction of the new Volcano Road (SIHP # -31089) in the 1920s the Wood Valley
Road/Coastal Road alignment became obsolete as a primary route (see Section 5.2), and the central
portion of the stretch between Pahala and Na'alehu was abandoned after the development of SIHP
# -31089 (see Figure 65). Above Pahala Town the route is still called Wood Valley Road, but it is
used by residents of Wood Valley located approximately 5 miles to the northeast and not as a
primary route to Kllauea.
SIHP -31088 (Wood Valley Road/Coastal Road) is a primary transportation route that linked
Kllauea with Na'alehu from the late 1800s-1920s. Pursuant to HAR §13-275-6, SIHP # -31088
is assessed as significant under Criterion d for the information it has yielded about primary
transportation routes in the Pahala vicinity during the late nineteenth and early twentieth centuries.
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
74
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Cultural Surveys Hawai'i Job Code: HINAMOA 2
Historic Property Descriptions
Legend
H Pfoject Area Road to Volcano, 1885-1900
— Volcano Road, 1920s-1930s
Wood Valley Road/Coastal Road. 1900
Base Map USGS TopO^aphie Map, wood valley {1995). Pahala (1995),
Pwaiuu (1995) and Naalahu (1995) Quadrangles.
Oata Sources; CSH
Scale
0 2
-------
Cultural Surveys Hawai'i Job Code: HINAMOA 2
Historic Property Descriptions
Road to Pahala Sugar Mill ami Coast
Shewn on Maps post-l&DO
labeled "Wckks valley Roa
-------
Cultural Surveys Hawai'i Job Code: HINAMOA 2
Historic Property Descriptions
5.2 SIHP # 50-10-69-31089
FORMAL TYPE:
Road alignment (Volcano Road)
FUNCTION:
Transportation
NUMBER OF FEATURES:
1
AGE:
1920s-1930s
TAX MAP KEY:
[3] 9-6-005:999 (county right-of-way)
LAND JURISDICTION:
C ounty of Hawai' i
PREVIOUS
DOCUMENTATION:
None
SIHP # 50-10-69-31089 consists of a 0.47-km (0.29-mile) section of the historic Volcano Road
alignment located with the current project area (see Figure 21). The section of this alignment within
the project area follows the present Maile Street alignment located between the Lower Moaula
Road fork and Pikake Street, overlapping along Maile Street with the SIHP # -31088 alignment.
Additional portions of these two historic routes also overlapped further west toward Na'alehu (see
Figure 65). Construction of the modern Maile Street roadway, which is approximately 10 m (33
ft) wide, has impacted all the constructed elements of the corresponding portions of the former
Volcano Road roadway (see Figure 33 through Figure 35).
Background research, particularly examination of historic maps from the Pahala and greater
Ka'u areas, indicate a route extending from Kllauea Crater to Na'alehu called "Volcano Road,"
replacing the similarly named route located more mauka on maps from the late 1800s and early
1900s (see Figure 12, Figure 13, Figure 65, and Figure 66). With the construction of the
Mamalahoa Highway (SIHP # 50-10-47-30187) in the 1940s the Volcano Road alignment became
obsolete as a primary route; the 1967 USGS map (see Figure 14) shows the portion of the Volcano
Road alignment along present Maile Street as part of a "Route 15" looping through Pahala from
the Belt Road, while the current USGS map (see Figure 1) does not label the route at all.
SIHP -31089 (Volcano Road) is a primary 1920s-1930s transportation route that linked Kllauea
with Na'alehu.
Pursuant to HAR §13-275-6, SIHP # -31089 is assessed as significant under Criterion d for the
information it has yielded about primary transportation routes in the Pahala vicinity during the late
nineteenth and early twentieth centuries.
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
77
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Significance Assessments
Section 6 Significance Assessments and Register Eligibility
This AIS identified two newly documented historic properties: SIHP #s 50-10-69-31088 and -
31089, overlapping historic-era roadways crossing through the project area and APE. Section 6.1
provides significance assessments for these historic properties under HRS §6E, while Section 6.2
provides National Register and Hawai'i Register eligibility determinations.
6.1 Significance Assessments under HRS §6E
Under HRS §6E, for a historic property to be significant under HAR §13-275-6 (applicable to
government projects), the historic property should possess integrity of location, design, setting,
materials, workmanship, feeling, and/or association, and meet one or more of the following
significance criteria:
a Be associated with events that have made an important contribution to the
broad patterns of our history;
b Be associated with the lives of persons important in our past;
c Embody the distinctive characteristics of a type, period, or method of
construction, represent the work of a master, or possess high artistic value;
d Have yielded, or is likely to yield, information important for research on
prehistory or history; or
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
group's history and cultural identity.
The segments of SIHP #s -31088 and -31089 within the current project area only maintain
integrity of location as all the constructed elements of the original roadways are no longer present
today. While the corridors remain active roadways, they no longer function as the primary routes
they once were; furthermore, the plantation setting has been altered to one based more on
residential and commercial use, and the route names themselves have also changed. Pursuant to
HAR §13-275-6, SIHP # s -31088 and -31089 are assessed as significant under Criterion d for the
information they have yielded about primary transportation routes in the Pahala vicinity during the
late nineteenth and early twentieth centuries.
6.2 National Register and Hawai'i Register Eligibility Determination
Under Section 106, historic property significance is evaluated as eligibility for listing on the
National Register pursuant to 36 CFR 60.4. An evaluation of eligibility for listing on the Hawai'i
Register pursuant to HAR §13-198-8 is also included in this section. To be considered eligible for
listing on the National Register and/or Hawai'i Register, a historic property should possess
integrity as described in Section 6.1 above, and meet one or more of the following broad
significance criteria:
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
78
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Significance Assessments
A That are associated with events that have made a significant contribution to
the broad patterns of our history;
B That are associated with the lives of persons significant in our past;
C That embody the distinctive characteristics of a type, period, or method of
construction, or that represent that work of a master, or that possess high
artistic values, or that represent a significant and distinguishable entity
whose components may lack individual distinction;
D That have yielded, or may be likely to yield, information important in
prehistory or history.
As discussed in Section 6.1, none of the constructed elements of the subject portions of the
original SIHP #s -31088 and -31089 roadways are evident today, and these portions of the historic
properties lack integrity apart from their location (determined in consultation with SHPD; see
Appendix D). These segments of these historic properties have limited relevance and importance
in illustrating the historic context of vehicular transportation systems on Hawai'i island. Therefore,
SIHP #s -31088 and -31089 are evaluated as not eligible for inclusion on the National Register or
Hawai'i Register.
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
79
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Cultural Surveys Hawai'i Job Code: HINAMOA 2
Summary and Interpretation
Section 7 Summary and Interpretation
The entire project area was covered in close pedestrian sweeps. Except for a couple small areas
of dense vegetation, access and visibility were good during the survey. The project area has been
completely altered by past agricultural and residential/town development. Historic remnants of the
sugar plantation are present throughout Pahala Town and surrounding the project area, but these
remnants are all located outside the limits of the project area.
No significant artifacts or cultural deposits were observed on the ground surface within the
proposed WWTP site portion of the project area; this area experiences ongoing disturbance by
storm water runoff and macadamia harvesting operations. No lava tube openings were encountered
within the project area.
A program of subsurface testing was conducted within the proposed WWTP site and consisted
of mechanical excavation of seven test trenches. The subsurface testing generally revealed two
distinct natural strati graphic layers atop decomposing bedrock; these sediments are consistent with
known sediment types in the area and with past and present agricultural land use. In one trench
(TE 1) the two natural sediment layers are interposed by a layer of culturally sterile ash deposit,
likely associated with activity at former sugar plantation. No cultural deposits or lava tubes were
encountered during the testing.
Two historic properties were newly documented within the project area based on a review of
historic maps. These include SIHP #s -31088 and -31089, overlapping historic-era road corridors
which functioned as primary transportation routes throughout the greater Pahala/eastern Ka'u area.
None of the constructed elements of the subject portions of the original SIHP #s -31088 or -31089
roadways are evident today, and these portions of the historic properties lack integrity apart from
their location. While the project would involve ground disturbance within the existing
corresponding road corridors (Maile Street and Pikake Street), it would not create new impacts to
the historic corridors nor change their present characteristics.
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
80
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Project Effect and Mitigation Recommendations
Section 8 Project Effect and Mitigation Recommendations
8.1 Project Effect
Following consultation among EPA, DOH, DEM, and SHPD regarding the project effect for
the segments of the Wood Valley/Coastal Road (SIHP # 50-10-69-31088) and Volcano Road
(SIHP # 50-10-69-31089) within the project area under HRS §6E-8, per HAR § 13-275-7(a)(l)
the County of Hawai'i DEM's project effect determination is "no historic properties affected." In
accordance with federal regulations (36 CFR 800.5), the AIS results support a determination of
"no historic properties affected."
8.2 Mitigation Recommendations
No mitigation commitments are recommended for the portions of SIHP #s 50-10-69-31088 or
-31089 within the project area. The portions of these historic properties within the project area
only maintain integrity of location as all the constructed elements of the original Wood
Valley/Coastal road and Volcano road are no longer evident today.
While this project will have no effect on historic properties, archaeological monitoring during
construction for identification and/or cautionary measures is proposed. This is based on the
location of the project being within the "Pahala Historic District" (SIHP # 50-10-69-07362), as
well as the presence near the project area of three historic properties as follows:
• a lava tube system (SIHP # 50-10-69-27570) with some cultural modifications beneath
Pahala town;
• Ka'u High and Pahala Elementary School (SIHP # 50-10-69-07522), a National
Register-eligible historic property; and
• the Hawai'i Belt Road, (SIHP # 50-10-47-30187), a National Register-eligible historic
property south of the proj ect area.
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
81
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
References Cited
Section 9 References Cited
Ahlo, Jr., Hamilton M.
1981 An Archaeological Reconnaissance of the Pa 'au 'au Stream Flood Control Study
Area, Pahala, Ka'u, Hawaii. Science Management, Inc., Honolulu.
Chinen, Jon J.
1958 The Great Mahele: Hawaii's Land Division of 1848. University of Hawaii Press,
Honolulu.
1971 Original Land Titles in Hawaii. Publisher unknown.
Clark, Matthew R., J. David Nelson and Robert B. Rechtmann
2014 An Archaeological Inventory Survey of Sections of the Mamalahoa Highway and
Napo'opo'o Road Rights-of-Way (and Portions of Adjacent Parcels) for the
Construction of the Proposed Mamalahoa Bypass Interchange Portions of TMKs:
(3) 8-1-06: 062, 074, 188; 8-1-08: 003, 004, 005, 020, 021; and8-1-09: 006, 007,
010, Oil, 012, 013, 050, 057, 999, Ka'awaloa Ahupua'a, South Kona District,
Island ofHawaiRechtman Consulting, LLC, Kea'au, Hawai'i.
Cleghorn, Paul L.
2016 Archaeological Field Inspection of a 42.5 Acre Property in the Ahupua'a of
Pa 'au 'au 1, Ka 'ft District, Hawai 'i Island [TMK: (3) 9-6-002:018]. Letter report.
Pacific Legacy, Kailua, Hawai'i.
Conde, Jesse C. and Gerald M. Best
1973 Sugar Trains: Narrow Gauge Rails of Hawaii. Glenwood Publishers, Felton, CA.
Cordy, Russ
1986 South Point: Early historic land use patterns in the ahupua'a of Kama'oa, Pu'ueo,
Mohowae, Waiopua, and Kea'a. Ms., Historic Sites Section, Division of State
Parks, Department of Land and Natural Resources, State of Hawai'i, Honolulu.
Donn, John M.
1906 Hawaii Territory Survey map of Hawaii Island (colorized). Registered Map 2060.
Hawai'i Land Survey Division, Department of Accounting and General Services,
Honolulu.
Dorrance, William H. and Francis S. Morgan
2000 Sugar Islands: The 165-Year Story of Sugar in Hawai'i. Mutual Publishing,
Honolulu.
Dye, Thomas S. and Elaine H.R. Jourdane
2006 Archaeological Assessment for the Proposed Cingular Wireless Pahala Cell Site
HAWIHII060, Pahala, Ka'u, Hawai'i Island, TMK:(3)9-6-005:018 por. T.S. Dye
& Colleagues, Archaeologists, Inc., Honolulu.
Ellis, William
1963 Journal of William Ellis: Narrative of a Tour of Hawai'i with Remarks on the
History and Traditions. Advertising Publishing Company, Honolulu.
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
82
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
References Cited
Escott, Glenn
2013 Archaeological Inventory Survey Report for a Lava Tube and 4.5-Acre Portion of
the Ka'u High School and Pahala Elementary School Campus in Pa'au'au 1
Ahupua 'a, Ka 'u District, IslandofHawa 'i [TMK: (3) 9-6-005:008por.]. Scientific
Consultant Services, Inc., Kea'au, Hawai'i.
Giambelluca, T.W., Q. Chen, A.G. Frazier, J.P. Price, Y.-L. Chen, P.-S. Chu, J.K.
Eischeid, and D.M. Delparte
2013 Online Rainfall Atlas of Hawai' i. Bulletin of the American Meteorological Society
volume 94, pp. 313-316, doi: 10.1175/BAMS-D-l 1-00228.1. Electronic document,
http://rainfall.geography.hawaii.edu (accessed 10 April 2014).
Google Earth
2013 Aerial photographs of Hawai'i. Google Inc., Mountain View, California. Available
online atwww.google.com/earth.html.
Hammatt, Hallett H. and David W. Shideler
2006 Archaeological Literature Review and Field Check Study of Two DOE Schools,
Ka 'u District, Island of HawaiHawai 'i Inter-Island DOE Cesspool Project,
TMK: (3) 9-6-005:008, 039; 95-009:006, 015. Cultural Surveys Hawai'i, Inc.,
Kailua, Hawai'i.
Handy, E.S. Craighill and Elizabeth G. Handy
1972 Native Planters in OldHawaii: Their Life, Lore, and Environment. Bishop Museum
Bulletin 233. Bishop Museum Press, Honolulu.
Haun, Alan E.
2001 Archaeological Assessment, Emergency Replacement of Pa 'au 'au Bridge, Lands
of Pa 'au 'au 2 and 'Iliokoloa, Ka 'u District, Island of Hawai 'i. Letter report. Haun
& Associates, Kea'au, Hawai'i.
Haun, Alan E. and Dave Henry
2004 Archaeological Inventory Survey, TMK: 9-6-5:017, 018 and 9-6-6:004, Lands of
Palima and Pa 'au 'au 1, Ka 'u District, Island of Hawai 'i. Haun & Associates,
Kea'au, Hawai'i.
Hawai'i TMK Service
2014 Tax Map Key [3] 9-6-002 and 9-6-005. Hawai'i TMK Service, Honolulu.
Kamakau, Samuel Manaiakalani
1961 Ruling Chiefs of Hawai 'i. Kamehameha Schools Press, Honolulu.
Kelly, Marion
1980 Majestic Ka'u: Mo'olelo of Nine Ahupua'a. Report 80-2. Department of
Anthropology, Bernice Pauahi Bishop Museum, Honolulu.
King, James
1784 A Voyage of the Pacific Ocean. G. Nicol and T. Cadell, London.
Kuykendall, Ralph S.
1966 The Hawaiian Kingdom, 1874-1893, the Kalakaua Dynasty. 3 Vols. University of
Hawaii Press, Honolulu.
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
83
-------
Cultural Surveys Hawai'i Job Code: HIONAMOA 2
References Cited
Lyman, F.S.
1877 Map of Hawaiian Agricultural Company Sugar Cane Lands. F.S. Lyman, Surveyor.
Registered Map 949. Hawai'i Land Survey Division, State of Hawai'i, Department
of Accounting and General Services, Honolulu. Available online at
http: //dags. Hawai' i. gov/ survey/search. php.
Malo, David
1951 Hawaiian Antiquities (Moolelo Hawaii). Second edition. Nathaniel B. Emerson,
translator. Bishop Museum Special Publication No. 2. Bernice Pauahi Bishop
Museum, Honolulu.
Menzies, Archibald
1920 Hawai 'i Nei 128 Years Ago. W.F. Wilson, editor. New Freedom Press, Honolulu.
Paris, John D.
1848 Report from Kau. May. 1848. Waiohinu, Kau Mission Station Report. Compiled
and digitized by Hawaiian Mission Houses. Electronic document,
http://www.missionhouses.org/index.php/library/digital-collection.
1926 Fragments of Real Missionary Life. Unknown publi sher
Pierce, R.F.
1914 Map of Kaalaala and Moaula-Kopu-Makaka Makai Government Tracts. Hawai'i
Territory Survey (HTS) Plat 104. Hawai'i Land Survey Division, State of Hawai'i,
Department of Accounting and General Services, Honolulu. Available online at
http: //dags. Hawai' i. gov/ survey/search. php.
Pukui, Mary Kawena, Samuel H. Elbert, and Esther T. Mookini
1976 Place Names of Hawaii. Revised and expanded edition. University of Hawaii Press,
Honolulu.
Sato, H., Warren Ikeda, Robert Paeth, Richard Smythe, and Minoru Takehiro, Jr.
1973 Soil Survey of the Island of Hawaii, State of Hawaii. U.S. Department of
Agriculture, Washington, D.C.
Shipman, W.C.
1860 Report of the Kau Church: May 22nd, 1860. Mission Statement Reports for
Waiohinu, Ka'u. Compiled and digitized by Hawaiian Mission Houses. Electronic
document, http://www.missionhouses.org/index.php/library/digital-collection.
Soehren, Lloyd
2010 A Catalog of Hawaiian Place Names. Compiled for the Records of the Boundary
Commission and The Board Commissioners to Quiet Land Titles of the Kingdom of
Hawai'i. Collected and annotated by Lloyd J. Soehren. Online at the Ulukau
Website, http://ulukau.org/cgi-bin/hpn?l=en.
U.S. Department of Agriculture
2001 Soil Survey Geographic (SSURGO) database. U.S. Department of Agriculture,
Natural Resources Conservation Service. Fort Worth, Texas.
http://www.ncgc.nrcs.usda.gov/products/datasets/ssurgo/ (accessed March 2005).
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
84
-------
Cultural Surveys Hawai'i Job Code: HIONAMOA 2
References Cited
U.S. Geological Survey
1930 Palima Point USGS 7.5-minute series topographic quadrangle. USGS Information
Services, Denver, Colorado.
1967 Pahala USGS 7.5-minute series topographic quadrangle. USGS Information
Services, Denver, Colorado.
1977 USGS Orthophotoquad (Aerial photograph), Pahala Quadrangle. USGS
Information Services, Denver, Colorado.
1995 Naalehu, Pahala, Punaluu, and Wood Valley USGS 7.5-minute series topographic
quadrangles. USGS Information Services, Denver, Colorado.
Waihona 'Aina
2018 The Mahele Database. Electronic document, http://waihona.com (accessed
10 November 2018).
Wall, W.A.
1886 Hawaii Government Survey Map of Hawaii Island. Registered Map 1438. Hawai'i
Land Survey Division, State of Hawai'i, Department of Accounting and General
Services, Honolulu. Available online at http://dags.Hawai'i.gov/survey/search.php.
Wilkinson, Sarah, Rosanna Runyon, Aulii Mitchell, and Hallett H. Hammatt
2010 Archaeological Monitoring Report for Ka Ti High and Pahala Elementary School,
Hawai 'i Inter-Island DOE Cesspool Project, Pa 'au 'au Ahupua 'a, Ka 'ft District,
Island of Hawai'i, TMK: [3] 9-6-005:008, 039. Cultural Surveys Hawai'i, Inc.,
Kailua, Hawai'i.
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
85
-------
Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Appendix A
Appendix A APE Land Jurisdiction
1
mmomti
• r>.v -v.-'-'Ji'-h.i.;
86 719
¦
KAMEHAMEHASCHOOLS
42 5
COUNTY OF HAWAII
Q.41
EDMUND € OLSON #2 TRUST
3S6SC6044
EDMUND C OLSON #"2 TRUST
mm:r
336814001
MC0EATH.BAR8ARAANN
a. i7M
0eCKEM.PH8.IP ALEXAMDSR TR8T *tal
CU731
396014003
FUKINAGA.FAMILYTR
"
396014004
POLIOO.SANDftAA
o.t7«e
396014005
branch, young. fLENA
396014006
BRANCH. YOUNG ELENA
ft 1774
396014007
i m •
396014008
/> "i. '¦ h l ¦ !,¦: tr.
v'i'A' * "¦'V-VV
99SM4WO
rs ^ 15 •< T' *. i. \-i
> »
396014011
'-'V ¦ » 1 Vl T f''Vl
,
396014012
. r '. .1 ^ -L'i A" : i.
r> imij
39601401$
ST WE .ELIZABETH&tart
396014014
s >,/ - W -\.|
396014017
II , ' ,, ( ¦ • | " \ ill ^ ^
3set>«oi#
- -Ji
s "L >
396014019
" '.V. N 1 5
''I » 1 1 ' s •» fit . i ' ,f >
396014021
, 11 ** » if *> # j r < "¦ „ M r u
1"'" \T-V « x \ 11
mmms
v" , »" '• i ;,1 »•; I '¦ 1 .it1
¦J ^
386014083
M "> ^ ^ . '• . 1 ?!
396014024
T [1 M > v < •"
¦
39G0140Q5
( * 1' - »V-V-' /-l|
mm.mm
, ,\\ »*' ^ " 1 V
,1
396014027
J ^ it(
'i
396014008
\" " -• :• ¦¦ if' : I- ' :5 \v t V 5 u* J
39G014Q29
-:fi t-\ v.." ""[ i
It " Ik 11 1 1-* ' - 1 > e
r ¦ ;
39W14031
„ " !> ^ ' ¦ M , -As
l" if »"1
v.",, -i i. ii ry..j. !
BEDOER,PHILIP A Mat
¦¦*, * s, ¦< " i a • n
396014035
r, ,e,i .|„t ^ 7
396014036
H*,L f • ,h^ •' . 1 AKt ^ - !j
396014037
V'V1"- *,( ! S «" i-» • "i rr'
¦ '¦
396014039
ftSISTIN, ALFREDO Mai
396014040
s- ^ , -- s i •. - n » , ¦»
396014041
. m M,' ht\"i r
390014042
: *« - ! * h"
tmomrn
3#ffi14€l44
f\ !, * - -Y "lV
^f- ^
, -L .A
h^
- *
39601404$
hiQ" f, (-.
396014047
.'.\v •. - ,
3S6O1404B
W,. j*/\A-Ql
'1 -,k U ^ r,s ' 1-' r-j
396014D50
M "«^l - „ * ,t. k (•
' "• ' ' ' f 1 k E i1
396014051
KAWACH1, MICHAEL N
" ¦»"'
396014052
SUMIDA.TSURUO fR
r..'- a-A-.. • , rq.-- A,f -h 11 '{1 s
396014056
'' 1 '• -V 'I M V'J
39»140«
"-¦/ i t 1
386014Q57
r.^ '.'r•" ¦">" ^ '."^T
¦if1 »
396015001
1 -
: .h*i;.
¦
-------
Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Appendix A
396015006
2
UEDA.HAJIME TRST «U
0 3464
396015007
MEUiNO.STANLEV KAZUO TR
01662
396015008
YAM AGUCHI.SAU Y C TRUST
mmmm
CAfcia*.GLORIA Mai
0 6415
zmmen
MANAMTAN.RUBY M
0 2271
asioiscii?
HIGASHi. CHUCK fetal
0 2939
39601501ft
HAWAII METHODIST UNION
0 262
38601SOIS
DACALIO, MILTOK #t§l
396015020
tamondong.gary mm
396015021
TAMGNDQNG.JSHANDON i /#!•!
0,9644
390015022
YQ6HJMURA.H1SAKO 1 MM
39601S029
KAU60HANC i»
0 3247
306015024
NISHIMURA.NEO NOBOCWGAIL TOVOKO TT6ES
02443
396019026
GAUMBA.KELL Y KEOKI ietal
0 3829
' -
YOKOMIZO.FAMILY TRST fetal
0 3485
396015027
DACALIO, MORGAN
0 29341
396015028
MABQA,ROYA.UCINOA R TR
swotscsa
HAWAII METHODS! UNION
1332
396016036
OLDMEN, MICHAEL J MM
0,4
396016039
BARAN.EVELYN BARS*!?A
0.3017
396016040
NEAL.. JUUA A letai
0 6606
396016041
IMWS-NATMGAD.BRYAN RUDY Mai
0 6259
396016042
PROVOST, AKKO
0 6402
396016043
DACALIO, DON F RANCISCO iWat
0 4293
396016044
AH SAN, JOHN L
0 4253
396018045
NEAL.JULIA ft fetal
396016046
CAM0A.GLORIA
396020001
OtSON,EDMUND C TRUST NO "2
01907
imsmi
ORTEGA,MCHEIA6 M
0184
RYDER.FRANK. Iliietai
C18S6
390020004
G«O*,RA,PiCR0fetaii
01801
KOSALES, OAWf L C fetal
01767
EVANGELIST* ROORIGO R .fetal
01788
SOtlZA DAVID M TR MM
01768
388)28908
C ABAT1WGAN, ABDOW «8l
0111®
Py€fi'T6,fl,C86M0Ci I'elil
01733
REQUELMAN,EDWARCWC TR
01689
396020011
*0iRi«T0,F6lJP6C«al
01661
396020012
portk.io.wioo chaiito martins
0.1677
396020013
IVERSOW, LESTER MATT
01633
396020014
GA8IN{,SQNMY A MSI
396020015
RBARA ft
0.2236
'
AQLIA. JOSEPH Postal
0 2478
396020017
NAVARRO-VI6RRACRISTEN OOLLY
0ECKER.PHJ
0 2215
MMAKURA.CLARITA «fl
01549
¦
VILLA,TEOflLO
01495
396020021
LGRE1NZO-OLEYTE.LENQRA II ietal
01609
396020022
SANTIAGO.DENNS E
01489
396020023
CABUDOL.APOUNARIO fetal
0 166
39B020024
ANDRADE,EDWARD fetal
'
396020025
DELOS SAW OS, MAR 1ANQ V MM
01592
396020026
PENERA.FREODIE L Mil
0 2018
i,„CWIS,AlBfSTG»tal
0 2044
YAMAKI,JAMES II
HIONAMOA 2 AJ^_TMKJ3#r<*ls
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
87
-------
Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Appendix B
Appendix B County of Hawai'i
Correspondence to SHPD
n ! ctif- !""¦> D
t) NR "S'.ne !'••».'! If I'r.. M' !,'•>! P .i 0'
603 Kat"-iI:« PD'« -v-ifj
iwpotet, Hawari S4707
fit**: <808)69241019
f#K (SCSI
SttijKts Request for a Stale Historic Preservation Division deterrntoatlon letter
i#it per HAH for a Wastewater Treatment DUpowl System Project in
PSMa, Pfi'jo'iu 1, JCi'Ci District, Hawaii Island (TMK: |3> 9-6-00?;018|
IV m fv J ti^O
Hit- Caj ity oi Hawaii WMtewiti-r Division is tupestliig * state mstorie Pre®nation OMtton
(SHPW MmMM tetter (as mf KM S13-I7'S-I> far • W#stew»ter Treatment arid Ditpoul
System Project in Pihala, H'wfw 1, Irt District, Hawat Mend flfcltti ui y-tnuufcOlt),
The prelect is to service the HMl community and Is l«t«t on a 42-5 acre propertf near tl»
stutlern edge of Pihala Town presently awrtri % Kamehameha Schools and under lease to Kay*I
Hawaiian Orchards, Almost the entire parcel Is planted iiv a commercial macatfamka wt orchard
with a mriMi nut processing plinl parking lot ir> the southeastern coffttr.
The project will tacMt ¦ Wastewater Treatment Plant (WWTP) on the 42 J acre property thsrt wM
connect to a line ommHh dliehargtng wastewater Mo two (2) Urge Capacity C«tpooli {ICCsJ
which arelava tubes, Hit project may «l» tadude • network of sewerikne improvements Id Pfthaia
Town on the southwest ami southeast sitiei of Krt Hlffi I Pihala Elementary School, This project
will use the SUM RwbMri Pnwfc 1ft addition to an fp* Grant JIPA Grant XP-96942401-S) which
incMet federal and state monies, m Section im consultation wilt alio be respired.
To supply background Information to facilitate SHP0 propel review, we are providing an
fl,rciwmfo§ tail fkti I'KfWffc* of a 42,5 Acre Property if* tftt Maim* «# te'mrtm I «ort District,
HawttfilsMnaftMX; (3Ji 94-002.H18} iOegiww, 2G»i«|.
The project's point, of contact at County of Hawaii Wastewater DMskm Is:
Mi, Oora leek, PJL
Wastewater Division Chief
County ©I Hawaii Wastewater Division
lis Railroad Awrnue
Mo, Haw*! mm
WAS IIVVA I Lit DIVISION;
it
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
88
-------
Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Appendix B
^ vf {" IS ,t ¦ sk', jl" • L;, . ' l"? n i k>,"r 'A j '¦ * ii f. if if 1 h n
Should yen hmt m-t questions « comMints stout this ff eject,. please feel free to «tt me j| ||#S)
, Wastewater Deputy
He look forward to m SKPO determination letter s ss s»er h Aft I134J5-I) to guide this prefect
lj.tr.t ?««.;(• P{
>:..r Will im A Mirhar'ki, DM.1 inrcrtor
N'ltfU ill V!
»"< «T ifJ P F, , Prj.VA'"" -J'hI i. .lldv, Pi!
t .h! 'A'I M 11 OUmntu A'.VjiWlc.
PI"
* I n
S rsu'ru 1^
2
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
89
-------
Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Appendix B
Mart* Kim William A, KuttersM
Wilfred M. Otwbc
uj D'tv to*
af plafcaf 1
1)1 I'\k I Ml NT OK I wTuoWll \1 \l M \\ M.I MI M
345 m*mrn'i itttm, Swfc 4] ¦ Mfe n»»*»-» m»
m.mmvu-mB¦
em^rnam-iwmmiM
VI a ft h 22, 201X
Via .email: iilaii.s,fev%^nerij;tiii»ii i.gtw and 1,1 S. MM
Alan S. Downer, !%.IX, Administrator
Slate Historic Preservation Division
Deportment ofland and Natural Ronm
601 Kiniokilii Boulevard, Room 555
KajwJei Hawaii 96707
Subject; Request br CtHttmet ®f Proposal Pilitte W*
Treatment Flint mm! Sfwer Siat# i» Project and the
fftventore S#my Approach fur the Project
Hioiiiimmi Ahupua'a, Ka O District, Hawaii Island
Tin*. Map Ki>; Multiple
Dear Dr. Downer:
On October 17,2011, the County of Hawaii Department of Environmental Mnpnent,
Wastewater Division, the project proponent, provided a written reqiiesl to the State
Historic Preservation Division (SHPD) for a letter of determination« accordance with
Hawai'i Administrative Rules pi AR) 13-275-3 for a proposed KM* Wastewater
Treatment Plant (WWTP) surf Sewer System Project
Attached with dw detenninaiion request to SHPD, lie County supplied a November 11,
20lit, letter report from Pacific Legacy,anarchaeoiotpc&I fin*, addressed to Dora Beck,
PIL, Wastewater Division Chief for the Department of Environmental Management's
Wastewater Division, the subject of which is an Archaeological Field Inspection of a
42J Acre Property in the Miffim'a ofPit'mt'm I, Ka'u Distrkl, Hawaii IshmtlflMK:
($) 9*6-002:018], The letter repels on the finds of an archaeological field inspection
conducted by Pacific Legacy of the proposed finals WWTP and Sewrar System Project
area.
County of Hawaii it an Equal Opportunity Pfovldsf and Emptor*'
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
90
-------
Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Appendix B
Alan S. Downer, PIt.D„ Administrator
state iliMwic I'reservation Division
Vlm-h 22.
Wiw 2
C»« Iwh-iwij 22. Z<» 4 k, I >avid Stiileler of Cultural Surveys 1 liwai % Inc. (€'514) met with
SUM! Archaeotogv Branch Chief Df, Susan Lrto to follow up on the County of Hawaii's
determination request. Tt»ey dfcewssed the proposed Mhata Wastewater Treatment PltM
and Sewer System Ptoject in fte Hionaitv;! ,\hnt*M-.% K.ifl District, Hawaii Island,
which has multiple tax map keys. Attached is tlie original correspondence from €811. the
contents Of which we also described below. The site map showing the popmcd layout
and location of the proposed test excavation was is attached to CSH'f correspondence.
The reported outcome of the February 22,2(111, discussion between CSII and Dr. Lute is
summarized as follows:
IOr,. Lebo indicated a desire for an archaeological inventory survey addressing
lie entire are* erf proposed ground disturbance, with subsurface testing.
2. Dr. Lebo indicated particular concern for a g«xl faith effort lo address possible
Java tubes within the area of proposed ground disturbance. Related
investigations would include an effort to develop available information on the
location of any such lavs tube*, tether pecteslrian work, and subsurface
testing,
3. Dr> Lebo indicated ft schema of a tola! of six baefchoe assisted excavations Cone
in i ajwm 1. mur m i iaMmi 4, and one in each of Sarins 1,2,3, and 4) which
would only need to n>» dtcp .i> flu* prupind! riuntmum excavation for the
lagoons' basins. This would probably be all of the indicated snfaiirfacc testing
required.
4 Dr. Ldw indicated a desire thai all bkiis of project-related ground disturbance
tfaM wore not addressed in the Pacific Legacy 2016 report be addressed in the
AiS, in particular, this would include consideration of the lalcimi installation,
mm, predominately located along existing residential subdivision roadways,
MB efforts in ffcese later instalistian areas probably would not require
interface testing,, but would include documentation aid an evaluation of lie*
these streets might relate to a possible historic plantation village' or historic
property designation.
Baefchoe excavations would likely measure JSP long by 2* wide. The depth of excavation
at each trench would be determined by whichever of the Mowing is tended first;
bedrock; msKimum depth of project-related ground disturbance indicated for that location;
or a depth of 6 feel, which is (he appraxirnate maximum depth of tic naturally occulting
MdimMi throughout lie project area. Typicatly, this subsurface testing schema would. 1*;
Reftiicd sn ;f»c <«uvr »>f consultation with the SHI*! i «> .irfieiible during the
surface
-------
Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Appendix B
Alio S, Dovrncr. Fh.D., MrMmot
Stale lii.vuiftc Preservation Division
Maich 22, 2(1 IK
I'y^c ?
* Refuted to address new iocstioos encountered in tie surface survey that
t]t!i.d.K*®fffe' •) piobibi 1 ity of ^ui5siiirfi|i.C'$ ctiiuit^sil wd
• Reined to avoid trees, tree toots* mmi ether conflicting constraints,
\\ 'v Juiully nfM concurrence of this AIS strategy.. Please feel free to contact me im.Ii
any ,jue«i»w or concern*.
WKUmtsl
'VUidinient- t'SI! V| * IX letter
tv I Jr. Sy ,( i with ailaehinenl I
I)»hi« IfccL F.l .. Wastewater I >h isUw iwiih attachment)
Craig Lefcven, Brown andC&tdwclf (w/o attachment)
Sincerely,
i
Dia\i«>r
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
92
-------
Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Appendix B
Slate Historic Preservation Division
IIRS SE Submittal F«rm
Per |c5li Hawaii Kerned Statutes Kike Ftoject requires renew by the Sate Historic Preservation Division ISIIPD),
please renew iiikI fill tan this form m suomilai requested information to SHPD. Plena submit this form aid pejus*
4x*#5ertii»»n «i«tr#!ile»i* »:
ilMjriIal;c;sh|*l!"3liawiiii go*
1 ryew a« unable la sAim it ele«f«iie»! ty, pka,se cwilact SHJCi at (801) CTO-Sill 5. Matalo
The submission date of this fontn is; ^ §
I APPLICANT (s«le« one)
D Property Owner 13 Government Agency
2, AG»C¥ (select one)
~ Planting Itejmitiiierit fl Department of PliMic Works B Oilier (specify): County of If iwati,
1' ype of fctnii it Applied ft*: Concurrence with AIS approach
J, APPLICANT CONTACT
3.J) Kane: William AKucharsb 3.2) Tide: Director
3.3) Street Address: 345 KAiianatfli Street Suite 41
M) Connh'' liliwstft AS) State: HI J.6) .ZipCwlr. 96120
1.7) PiiOfW. m Email: -CW2:0W
4 3) mm Address: a#ws« to Ivfaifc Street, Pshala
4.4) County: Hawai'i 4.5} Sale: HI 4.6) Zip Code: 96777
4.T) Total Properly Acreage: 423 aew:s
4.8) ftoject Am gtyare feet) m acres
4iu List iiiv previous SHPD corresjxindeiiee (LOG Number & DOC Number, it iiBBiicablelr
LOG NO. 20I8.007T DOC NO.
$. PROJECT INTORMATION
5, t > Does the Project involve a Historic Property? A Historic Property is any building, structure, object,
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
93
-------
Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Appendix B
district, area, or site,, including heiauand underwater .file, which 11 mew Si year* old (HftS
~ Yes
5 2) Tilt tltteis) of «»wim:!i«i ft* the Wswrit property fbuiWing. structure. object district area, or site.
iueludsBf Ikhib andunderwatersite) is ^
5 3) Is lbs Property listed cm the Hawaii ami or National Register of Historic Pl»c4s" To ebeek
hup ."•'nitorJ»w«li.gov /slipl/
U Yes B! No
5.4) Detailed Project l'te«rip»»n irnrf Scope of Work:
Wastewater Treatmentand Disposal SysMtft Proje« in Piiiiifa, PaWtiu I, Ka'uDistriet. Hawaii 1$I#«J
(TMK: (3) The project is lei service the Pithah communis is irc;i[«i i.:r= h m
property mat the southern «l|« of Fihftla Tow* pieaaily owned by Kamehameha Sdtoob and and**
5.5) Descnpl n >1 t« t >»u»^ - i- >, j disturbance (e.g. pre* < • t> i > i i1 bing):
Majority i.il p scnlij" ttificiMltisniil nut orchard ffiict I'ssi'Mfentiui ft€i|§lit®itRXxl
5.6) Description of Breamed wound disturbance (e.g. # of trenches, Length ;s Width x Depth)
Protect will involve ecms»«ton4iislal!alKjn of land application Me
grove,, a polishing constructed wettaiwL and mrnxmM points and «tmw
5. 7) Tiie Agency shall ennnre whether historic properties arc present in the firqjeel area, and, if so, i stall
cuaiie that tee properties aw properly KfeiUifted and inventoried identify all known Intone properties:
No archaeological inventory survey has been completed for (he updated. Fatal* WWTP project
> 81 unc* a ftisiofic property is iJiilitled fan an mmm of significance skill occur.
Integrity (check all thai. apply)'
O Location O Resign O Setting ™ Matemfe " Wcrt:m;ifiui.iti . reeling O Association
Criteria (check all that apply)
O a .. associated wiik embiMtarenade mimportant contribution»the bread patterns of «r
history
Li b associated with the lives of persons important in cur pi*
. s;s5rr»;H.f"< #1 a tvpe. fxrtcxl of mcllicsi of i%.¥islTUtli«i, repre*enl UiC
work ^ •! nut.' . : ;. ;j'i t :i : t • , !, •
LI 4 -¦ have vickled, ct ®. Ifely \® yteki iafomuakm impoxlirti f« tm preliisk>i*y 01 liii^orj
O e - hare at aptM 'Wtlue le Ihe Mat wc fliwuiari people or to another ethnic poap at ll* aale dm
wilh CilhlMll pRIClkeiS OtWf Olfl'Md.Ml Oil1 ¦,';)!! •.iiflici QUI, lit fc 1* diiC 10
msxmuam' wili tmditonal behefe, «vcnls„ or oftl wxtmm - - line* mmmtmm bensg. iiBpcutaal
l» ike puf't Musty and cuSlwrtl iA:n.lil.y
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
94
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Appendix B
53) The effects or impact* est" • project on iigfijCt«ifit historic properties shall 'be determined by if* agency.
Effect r*ieti»iwitic« (select amy
Q No Hisfcwk Properties Affected
O Effect willi Agreed Upun Miligaikm Commitments f§i5li-42,1 IRS)
~ Elect, with Proposed Mitigation Commitments C|6B-i. ICRS)
5.10) This project is (check all fiat apply, if applicable).
El an activity. or prep* fu er the itKCft or n*lir«4j*nsciictK>n of a Federal
agency. incliKlmgil^ caniedortbyorcwbehs.il s>.l ai-iMm; jsmsv.?:
ii.1 earned out wtlh federal financial assistance; and or
0 requiring a K«taai permit, license or i
If any of these bows are checked. then the Project may also be subject to ewnpliwice wilt Section 10$ of
the XiniiMiitt Haws ftwata Act (NHPA).
S, PROJECT Slfl&f'ITTAILS
(i I) Please subfint» copy of He Tax Map Key (TMK.) map
fk 2) Pteswe submit a copy of the property map stowing Ik project area m ¦ , ,
sawillur thiiii the property are*
6 J) ^ Pfeise subfiiit si fwiisfl cil cfeiwiigs A pcrits.il. set. is a set of drawiap prepared wid signed 'by «licensed
i$J) Meymnmhmi '
~ Yes 0 Mo
Specify Survey.
6.S) Did SHPD request the .ajney*'
O Yes P Net
Tf' Yes*, then please jmwute the date, SHPD LOG MO, smi f»€ Kt">
Date: LOti NO. DOC NO.
6.IS) SI.TRVEY REVIEW FEES, fee ft* Re-view of Ktfxms ami. t-ieiiiis t» l.xrt-4 and 284-4). A filing fee
will 1* charged for all reports aivi pter» scummed »«* office far renew. Hew* go to:
wibmilw
-------
Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Appendix B
Tie following are the iniiiiiiiuin number and l>|>£ of color photographs respired:
(Quantity
Inscription
1-2
. 1 ' .0*',' 1 .1 ]IK- u' . i „• it:J 111 Ulkl I:.
i '2
Overview of" exttriof wok am
!
¦ ' ¦' tWapptoWci
exterior photo of ihe South elevation (if applicable)
• photo of the Kast elevation ««i applicable)
1
«xktht photo of Sk West etwalicm fif applicable")
tmwwr plwtosl's) of Birens affected (if applicable)
CHECKLIST
57 SHFI» FORM 6E fihis latin}
S PHOJ BCT SI.' M ITT.4IS (any requested ioeuineiitalioii: for items t>. I - 6.7 of this fonii)
E FlUMC FEE FORM (if applicable)
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
96
-------
Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Appendix B
-------
Cultural Surveys Hawai'i Job Code: HIONAMOA2
Appendix B
AISR for the Paliala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
98
-------
Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Appendix B
;-'T! j • ~• '\ : ,^-n! '¦>,*
I >, |»"t "nI ¦•">•", ,i ¦ >• vv "• "t ~ nav fit -r.i - i->,.i i fa; I :y *'< "•>' v .*¦ tr -.f i i
.-•mviiH i -«"> c - -.rCy t1 > "ir, 5 f-'">• *-tti *"«, r > r; i -1' -. ,i 'iri'tyvv.i
i. • ii. i-H' -¦'* ? i«. i >.*- -ir in ( it", m _>r .i i r 4J :¦ t. • _ !"-i I v .If f-1 >:(¦«- .•!!'.it -!.i
"-.vie'1 ."'ity 'i ,.y ' ;i<"' .'¦!,< c>, An
l">. rr fi'> p.i'v.-i r ;*i »" tpvt 1 r>ii"i1a'- i •- ^ --[.-itS w !>.,! n t rr,
I ',p i » r s I. >"k r !l >¦ * .i Mi'-d'.l- -r t • <• rf
'»• ;>• . ¦ ' w.i1 il ! i' w "v, { is t. sty I I'. ('¦ ' ',)
' n :i*i !¦;« t n'i> -f « .',?*»¦ s»y v i'r i .P.l- .• .«!¦; *'• '> >i ,»t i-* A .)>,<•" (I-l",ft m .1": X* '-'•I, . . v't. »! •' uf v-'I'fi ,'1 it 1. r- «¦ 1 jli _ !.c 1 t';,u f-J
ic , .r 1 (-in >¦ 11.1f* >¦ *! *t» 1 .- t '
! J !1 »• ' f\v '.V,111" . I", !,,¦•> >,y1' w, !" '.1. I*i u | i.Iml n>jtl >? «.V,iy I V '«V-. 1 "< 1111-
rj'M «• c< 11 in j 1 *y T"•!. -it n't- w.f> M ?\i! f v'i'ti 'i'i Ty r.r.'iA-. j ai"i ,i p" ilf :
i'AJj _ •, r fa - _ • h 1 -j mrr "VT'T "' jr, s-.wjl-". V ¦' ."SL-t't:,
^ !¦ ! '• iVr f '.!! N ''t- 'Mv'a V' Si !" ¦ i* " t- (. " f''- ! !
j 1 fr<¦_ jCf" 11 1 '"-(.'t; i>dtt t"1 ill 1 J. "'•i> t'tf"V». I s = 1>_ 1 ¦ iLjui * Z-i
ji'.i j".n..f ti»e 11 .,Ji. 1'. ,-1!»1'>" 1* ,j'>o a . ti.* mi'. "i.t. r^_;t
!' In * 11• - in 'i I 1." p iVt1 r.yl 1 I ' PVi I j¦ 1 ;¦><• «'i 1." i . i . i. % i >t i" ! f f
1 i'8V» 1 ',*u'"'br" ,'."••'A't"-> t < s_>1 ¦ ft' »i" ^ "ivt J 1 *l ¦ni.iri> 1)a .t ii U > t '
• !'*> I *' *1| i ! H' [ (}• * fi K' i 11' " ^ > 1 <.'t »jt th'i *}! T t'l *"f 'i ill'i
.•t« 11 J 111 r- - i"t. iftiri' n»* II i-. ~i- f tyf -J <,t w 1 I t'S. rt '• !"• • V>.: v» Jt
!• a ,„,• -fc1 ; »r,«l
Il.rii J ti f-.Wily I* !!.•[..I',!,.. •) Ilil I'. • ' :i 't f.l- ' * - JWJ ."'.-(Mi:. -1. ! t '! * .J"vt. .'Id1 I'-
' ,-if iv ly * h r 'Cf ',itc w.' r.,py f >n Jt C*1 t TV. "i i- , i . IC<- >1 r
H-T' '"r'.i' V • i! i y 1 Ji''1 ! "• -I. I* ¦ ry .-rfv)*'*!' rt 'A.'! -,e f;>i* rr> .1 ! i • ,i "vr
i'L'l J'j.".- ; I I- fy ' IJI let ,1.- I.'! tr-" ' :u» t * I ' I > !hi* ii <¦"' .hi • ite Wm " wi ' li-.tL-
I ii i : ti . i'.i- .•';ic,-i !*ti; .n j ji-|, .< i'i ]i*y
Th» » S-acre trtatmeftl mi dispesal faeilftf will consist of: an aim for htfttfwotfcs arid
operations bo-iWing: 4 togoow to treat the effluent; * wmibiq area lor fwlter tmtmM »nd
disinfection; 4 plaftted grows for disposal of tht treated ellluent Each of th# iccoom wM
* •» t? Hv d * II wDOUX lit pioHTBO «IOQU * & *v?l 8^19 IFI© 3vQU\ 1
See figure —
II !• i !•••-"1 v.f'i .it 1 "" ' ' 'til ,1 <; ¦ '4 i'. (I f.i. I "y »v i !:¦¦ w". I 11 I t] i' ,i!« .: : (> f' >¦
¦- ,i.rv r?i-r> ¦" it "f '"ry,i ".nr--«"'T"i r^l.Tni'- •!>« -,t -i i' >. i.-r, vv 1 I n r. r.i I' i." I.k
-------
Cultural Surveys Hawai'i Job Code: HIONAMOA2
Appendix B
AISR for the Paliala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and Comity Right-of-Ways
100
-------
Legend
I I Project Area i I Proposed Test Excavation
Base Map: Pahala WWTP Preliminary Site Plan
Data Sources: CSH
;S
2
&
o
O
o
Oh
PL<
O
Qultural 3 urve.us j~jawai% Inc..
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Appendix C
Appendix C SHPD Correspondence
August 20, 2i.H»
STATE OF HAWAII
department orw(Biw»«*TOwi msowcb
STATE HISTORIC PRESERV AHOSi DIVISION
K AKUHtKEW A iltl liDiMlS
sol kAMoiaia Btvi). sn: s,»
KM'OIB, HAWAII WW
t A Kuchatski, Di»«« IN REPLY REFER TO.
County ctf Hawaii'» DepMeM of Environmental Management l.ef No. 2WS'.t»?22
MS KekOsnfc'a Si! >•,v iU- « Doc. No. i SWJACG
Hiito f inwii i ¥®?» Aicliiwkify
wmamMMOmMmmasmmMm.
Dear Mi. Kudiaraki:
51, 'BJECT • Chapter i-E-t aid NatUmal HUtorie PnmwimMm Aet fNl-lPA)- SMm 1M -
lor Acn-pUnvr nl iNt VrehawtaRleal Inventory Snq'Approachfor Proposed
I'llisila WartnmttrTMtanf HaniihmI Sewer System.ftiijtrt
Hfonanwa Alntpn'ii, Ka't flfatrfrt, Haw*!' i bM
lasmMjfiMii
This letter provides the Sate Historic fttmtmm J>i«-sttm".s (SHPO's) response to the County of Hiiwsiri
Department of Enwroiirnerila.1 Management (DEM) cITb's Match 22, .3)111 leier ccocernir® the subject tubil
far Cmtmrmmm of PrvfismJ Mimis tVanhmsim- TrmitmemS Plan! mi Siwtr SysMm f'mjm atvi llu
Afeimaksgiml Itmmmy Survty Afpmmii fiw ikt Project Ifummtmt Aiaifm 'it Km "$ imrkt if mmt Isbmi Tm
Map Kay: fif %6-0O2:OI8 (William A. KiKlmrsti, March 2011:). The SHRD received this request on. March 2.3,
2tli8 {Leg 3018.W.'?22> and; a follow up tetter en. April. 27,. 201S (Log No. 20!$.€>1021)
This fetter stl» reviews Arte mMMomI docume** received electronically by SHI1!!" on August 2, 30J1. These
documents, which include two- aerial pbts.miri aao;»sexi summary. finnliae the boundaries fcr the proposed Pffhata
Wastewater Treatment Hart and Sewer System project area. and the locations and plans for seven tm trenches to be
i>.iaI.!rnv s m. H.t rehaeolagiealiwwwiyawvtjr (AIS) The AISwtl!beconducted by Cultural Sun*eys
tiawt j"i, Inc., (OH), si the request of the County of Hawai'i
The submittal renewed here follows a February J obtain SHPS's
concurrcncsc wilii il*- plan, Aiiclili.oiia.1 cerrespofidence in SHW)"s files includes CSHs Miircfc 15, 2CH8, letter to
Ilm» unci Caldwe-ll, wtlji » copy to 5H.P.D, »l» follcufing, »«p lt»c fclmswy 22. 2(Hf, SHPD-CSSI cwwJaiiat
rfgiiftltg the tesiing approa*
The prcfssetl pfijeel will «plftc< tm cunwnt Hhalu Lurge Clipiciiy C«s5fc»l, m ii [»it»n of Plhula in IPtfati'iiU 1
Ahupa'a. Tfctt «-«|Wil is, cs« «f two tofg,«.-«j*eiw eesspcab ifiat will etesc when the pmfrtmi prujett is
completed.
The project will mm * new eoB bo* dcsig|i«l to a«*c the.
Piliila cfflniiiumil}*-. The proposed collection portion of the project area mill be located on County rcwis si?t,.s .sijtvts,
where- t««d*s. up » 6 fe« *«p will b# «c«safc S'4l-t;i«:)5 Puree!* tH4 anii i>J6 or 'hi i M.k nrnitomajp. connect the town K*l neEwtiii, with the mm).
find di»pe«aUE8e«ity project »m i
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
102
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Appendix C
uchafski
August 20. 201S
Puge 2
the treatment and disposal facility will oonpf 14.9 sicks in a portion of a 42,5-sene property south of PShala town
tint is Miiwily owned by Raiadiliiitehii Schools and leased to Royal Hawaiian Orchards. Moil of the pawtl is
tocaM in. s» commwfial nut o«ti«riJ, » tnacadami* m p«>«e«ng plant flicking tot occupies iHe
sotiiJxiist easier. The IW«» project m » bounded on the soothfast by Hawai'i Belt. Iloatl (MSiiialaI*si
Highway), «i the southwea by Mailc Slrcet, on ike nciftfewtst side by orchard. iiwl on the northeast wtii' !>v .j iw
this is m labeled in ihi available maps
SHPD accept* the MS approach. The seven uiitis will inchxk one in LagiX* 1,. one in t.agtion. 4. and mw cacti in
Bibibs 1, 2, 3,4, and 5.
Please send t»o hard copies efeafiy watted FINAL. along with a copy -v. ... trehable
PI* vasion t* CD to ll* Rstpwiei SHPD office, attention SHPt) Litany
PleiBecontactDr. hmAllenaC»8)byumiI ,e < .t..«-r.t •»-.. anyiiwtx*m
if « can I* of assistance
Aloha.
Mmm Bmif
Alan S. Downer, fliD
Athitii»ain*jf. Sane Historic Preservation DMrmi
Deputy Stale Hisioric Preservation OfTwarr
A:
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
103
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Cultural Surveys Hawai'i Job Code: HIONAMOA 2
Appendix D
Appendix D SHPD Meeting Notes
SUP© Meeting (Dec 201(f) Agenda Mattets to Ilfensa wilt SIIPD
Location: Kapalel
Time: \t»n
Attendees: SHPP -Simii.Lelw.fS.Li and .lam- Mini (J V)
CSH - PS fllpiiil, WP flpiiii
• HlONAMOA 2 Determining MwAwfer APE far Piilialu Wastewater Project
S|,: every tot will need to he put of the APE do not cancan yourself with each lot
WF: anvthifis with a latent! or i® receive a lateral will be in the API??
SI.AIA. IXC will I* inducted in the Al'E,
WF: H»« casement for a section of the new sewer line, ami buildings related to Che old mill
operations thai aw to receive new laterals are all within one large parcel Will we need to
include the entire parcel in the APE?
S1../JA.:. yw will taw a portion of the TMK puree! in (he APE that includes (he buildings;
the 'building in your APE will be historic building, Those hii. Wings will nc«d to be reviewed
by Architecture branch wliicii may ask for an LRS for than, but the underground
installation of WW line will not affect the hiking, you will still end up with no adverse
elfteMw historic properties effect - contact architecture they may request a "mini" LIS,
We need to search lo detenmne if the ptanialion may lave n SHIP #,
WF: "lie Pah ill a. historic district map showing the SHIP # 7362 (Pahata Historic District)
for the 1970*5 state wide inventory the Sllf&'Sialc Parks did in the ?(»"»,
51„: there is a SHIP # 7362. Did you contact Sean? Or here? in the district it depend* if tie
ii.rdiiwol.ogy is a component of (he district, Email SW and Scan an email about historic
district of Psimla, Statewide inventory of historical districts.
WF: Yes, We will check again with Sean and mil Dr. Lebo
WF: So building would be contributing cleaMMi of a new SHIP or the 1970*8 historic
district number if someone wished to nominate these for the registers,
St; 2-3 building associated with plantation; are they significant or on the State or Historic
register*? This should be addressed to architecture branch.
WF: do we need to address the fonr roads since they are documented on historic maps.
Si..: You would indicate tint there are historic roads, which are not in pur project, and
indicate which are wiihirthmugh your APE. Obtain SHIP numbers lew the roads. Will yon
AISR for the Pahala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
104
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Cultural Surveys Hawai'i Job Code: HIONAMOA2
Appendix D
do anything lo impact the roads? SHIP # integrity for the toads are only the location or the
corridor. No change to the alignment; no impact.
Your project effect would he no effect for determination. With respect to that you
are not creating any new impact and not changing characteristics.
Monitoring could he recommended for identification'cautionary measures not for
Data Recovery.
Under 106 do you have any historical properties, single house lots not eligible for
an historic property.
Notifications of homeowners that their house is within the APE will need to be
done via public meetings arid consultation letters
DS; passive consultation with homeowners?
\VF: I here will he public meetings.
SL: Give the home owners the project description at the public meeting. Who is the lead
agency?
WF: EPA
SL: they w ill get inpul from you 011 APE, They need to do consultation identification
process to start the 60 days.
Identify historic properties within the APE.
Testing is not needed for the entire APE.
Staging areas need lo be added within the APE. APE in letter and AIS need to be
include text staling "staging areas "ill he w ithin the existing road, (he PA and APE" or
something similar.
Funding of EPA and subject to 6E and 106. Ask for SHPD concurrence on APE.
When you complete the 6E document (AIS). support county as no historic
properties affected, Precautionary monitoring, to extensive excavation.
Under I IRS 6E review "No historic properties affected": means the project will have no
effect on significant historic properties. The Coll makes this determination and asks for
SHPD concurrence. Supporting documents lor this determination should be sent toSHPD
Archaeologv Branch and Architecture Branch
For Federal projects (under Section 106) "No adverse cllccl" means historic properties are
present hit there is no adverse impact to the properties. The EPA makes this determination
and asks for SHPD concurrence.
EPA IfKi determination of "no historic properties affected".
LRS - identification purpose, no impact, no historic properties affected.
End time: 2:IS
AISR for the Paliala WWTP Project, Hionamoa, Palima, and Pa'au'au 1 and 2, Ka'u, Hawai'i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
105
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Wilfred M. Okabe
Managing Director
Harry Kim
Mayor
William A. Kucharski
Director
Diane A. Noda
Deputy Director
DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
345 Kekuanao'a Street, Suite 41 • Hito, Hawai'i 96720
Ph: {808) 961-8083 • Fax: (808) 961-8086
Email: cohdem@hawaiicounty.gov
October 9, 2019
Via email (alan.s.downer@hawaii.govl and U.S. Mail
Alan S. Downer, Ph.D., Administrator
Hawai'i State Historic Preservation Division
Department of Land and Natural Resources
601 Kamokila Boulevard, Suite 555
Kapolei, Hawai'i 96707
RE: Pahala Wastewater Treatment Plant and Sewer System Project
Hionamoa, Pali ma, and Pa'au'au 1 and 2 Ahupua'a, Ka'u District, Hawai'i Island
TMKs: (3) 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County
of Hawai'i Right-of Ways (Bautista et al. 2019)
Acceptance of Archaeological Inventory Survey Report (LOG No. 2018.000722)
Dear Dr. Downer:
The County of Hawai'i (COH) is proposing to undertake construction of the Pahala Large
Capacity Cesspool Replacement Project in Pahala, Pa'au'au 1, Ka'u District, Hawai'i Island. The
project includes a new collection system and treatment and disposal facility to service the
Pahala community as well as closure of two Large Capacity Cesspools (LCCs). The collection
system will be located primarily on County streets. The treatment and disposal facility will
occupy 14.9 acres and is located on a portion of a 42.5-acre parcel, TMK (3) 9-6-002:018, near
the southern edge of Pahala Town. A Final Environmental Assessment is currently being
prepared for this project. This project will use funds from a U.S. EPA Grant (EPA Grant XP-
96942401-7) and from the State Revolving Funds (C150090-05, C150090-08) which includes
federal and state monies.
On March 11, 2019, the County submitted to SHPD a Draft Archaeological Inventory Survey
(AIS) for the Pahala Wastewater Treatment Plant and Sewer System Project, Hionamoa, Palima,
and Pa'au'au 1 and 2 Ahupua'a, Ka'u District, Hawai'i Island (Log No. 2018.000722). In May
2019, the EPA contacted Sean Naleimaile of your staff and confirmed that SHPD was reviewing
the Draft AIS for both NHPA Section 106 consultation and HRS 6E-8 concurrence purposes.
County of Hawai'i is an Equal Opportunity Provider and Employer
-------
Alan S. Downer, Ph.D., Administrator
October 9, 2019
Page 2
On September 26, 2019, the EPA confirmed by letter that the EPA has determined that no
historic properties will be affected by the undertaking. The basis for this determination was
explained further in the Draft AtS submitted to SHPD in March 2019 by the County of Hawai'i,
EPA's NHPA Section 106 designee. The two enclosed figures from the Draft AIS show the Area
of Potential Effect (APE) and the treatment and disposal facility project site.
Based on the findings of the March 11, 2019, Draft AIS and the EPA's September 26, 2019,
determination letter, we respectfully request that you review and accept the findings in the
Draft AIS. Your acceptance of the Draft AIS is necessary so that needed final environmental
assessment, design work, and eventually construction can proceed for the Pahala Community
Large Capacity Cesspool Replacement Project.
If you have any questions or desire additional information, please contact Dora Beck at (808)
961-8513 or dora.beck@hawaiicountv.gov
Encs: Draft AIS APE
Draft AIS Treatment and Disposal Facility
cc: Craig Lekven, Brown & Caldwell
Kate Rao, EPA
Dora Beck, Wastewater Division Chief
S. Wilkinson, CSH
WK:mef
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(firenfl
[._ I tires -cli?niia1 Ef pel AIS HrojcrtA'cs
5 EkImiq Cipaci/CSKWrtllCC)
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Figure 1. Area of Potential Affect and AIS Project Area for the Pah a la Com m unity
LCC Replacement Project
(Note: this is Figure 5 in the AIS)
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Scale
0 60 100 Meters *
150 3SQ Feet >
rji^ysJnr\ij,y / /ill
Legend
I 1 Project Area < J Proposed Test Excavation
Bas* Map Pahaia WWTP Preliminary Site Plan
Data Sources CSH
BISHOP estates
fKAMFHAMEHA JiCHOOLSi
1«K C3|. 94402 D1«
«s-Acefs
existing Access vtA
KAWFHAVO W SCHOOLS
FOR OtHFRS TO REM^Hh
(S&ACRFS)
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f ASEMEKT *0 M ACRESl
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STfBAC*
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and odor control
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property
I INC, TYP
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Figure 2. Pahala WWTP Preliminary Site Plan showing AIS test excavation locations
(Note: this is Figure 43 in the AIS)
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Final EA, Pahala LCC Replacement Project
Pahala, Ka'u District, Hawai'i
Appendix D-1
National Historic Preservation Act Section 106 Consultation
February 2020
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Final EA, Pahala LCC Replacement Project
Pahala, Ka'u District, Hawai'i
THIS PAGE INTENTIONALLY LEFT BLANK
February 2020
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^°ST^
'if
¦ eL~. b
jgjg? | UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
\ REGION IX
*1. PRo-tt°
75 Hawthorne Street
San Francisco, CA 94105-3901
Certified Mail No.: 7008 1830 0002 6279 3093
Return Receipt Requested
September 26, 2019
Alan Downer, Ph. D., Administrator
Hawai'i State Historic Preservation Division
Department of Land and Natural Resources
601 Kamokila Blvd., Suite 555
Kapolei, Hawai'i 96707
RE: National Historic Preservation Act (NHPA) Section 106 Consultation for the Pahala
Community Large Capacity Cesspool Replacement Project (EPA Grant XP-96942401)
Dear Dr. Downer:
The U.S. Environmental Protection Agency Region 9 (EPA) authorized our grantee, the County
of Hawai'i (County), to initiate the NHPA Section 106 consultation process with the Hawai'i
State Historic Preservation Division (SHPD) pursuant to 36 C.F.R. § 800.2(c)(4) for the above-
referenced project in correspondence to you dated February 28, 2018.
On March 11, 2019, the County submitted to SHPD a Draft Archaeological Inventory Survey
(AIS) for the Pahala Wastewater Treatment Plant and Sewer System Project, Hionamoa, Palima,
and Pa'au'au 1 and 2 Ahupua'a, Ka'u District, Hawai'i Island (Log No. 2018.000722). In May
2019, EPA contacted Sean Naleimaile of your staff and confirmed that SHPD was reviewing the
Draft AIS for both NHPA Section 106 consultation and HRS 6E-8 concurrence purposes.
However, Mr. Naleimaile recently contacted my staff seeking EPA's effect determination to
complete the Section 106 process. While it was EPA's understanding that the County's March
2019 submission would be sufficient to convey EPA's effect determination, I am sending this
letter to confirm that EPA has determined that no historic properties will be affected by the
undertaking. The basis for this determination is summarized below and explained further in the
Draft AIS submitted to SHPD in March 2019 by EPA's NHPA Section 106 designee.
Description of the Undertaking
The proposed undertaking involves construction of an improved wastewater system to replace
two large capacity cesspools (LCCs) in the community of Pahala, in the Ka'u District, Island of
Hawai'i. See Figure 1 for an overview of the existing LCCs, new collection system, and new
treatment and disposal facility locations. Under the proposed undertaking, the County will
perform the following actions:
1
Printed on Recycled Paper
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1) Acquire, or otherwise obtain the right to develop and use, a portion of a 42.5-acre
parcel, identified as Site 7, that is currently owned by Kamehameha Schools, then
construct a new secondary wastewater treatment and disposal facility within a portion
of the parcel (see Figure 2);
2) Construct a wastewater collection system, primarily within the public right-of-way
and two short segments within easements in the Pahala community, to collect and
convey sanitary waste from the residential lots to the new treatment and disposal
facility;
3) Close and abandon two LCCs, according to Hawai'i Department of Health (DOH)
closure procedures; and
4) Abandon the existing wastewater collection system in place.
The new secondary wastewater treatment and disposal facility will be located on a 14.9-acre
portion of the 42.5-acre parcel identified as Site 7. This 42.5-acre parcel (Tax Map Key (TMK):
3-9-6-002:018), located adjacent to LCC 1 about 0.5 miles (2,600 feet) south of the developed
area of the community, is owned by Kamehameha Schools and used as a macadamia nut orchard.
See Figure 2 for a preliminary site plan showing the proposed location of the treatment and
disposal facility within the southeast portion of Site 7.
The new wastewater treatment and disposal facility will consist of a headworks and an odor
control unit, an operations building, four lined aerated lagoons, a subsurface flow constructed
wetland to remove nitrogen, an adjacent disinfection system to remove pathogens, and four slow-
rate land treatment basins for disposal of the treated effluent. Construction will involve grading,
excavating, and fill activities at Site 7. Excavation to depths of approximately 4 to 10 feet will be
required to provide necessary capacity for the lagoons, constructed wetlands, and planted groves.
An approximately 4-foot tall berm will be constructed on all four sides of the groves to contain
rainfall from a 100-year, 24-hour storm event.
The proposed wastewater collection system will be located within 8 public streets: Maile Street;
'flima Street; Huapala Street; Hlnano Street; Hala Street (all located in the southern portion of
the community) and Puahala Street; Kaimani Street and PTkake Street (located on the eastern end
of the community). These streets serve the residential areas and have two travel lanes with
unpaved shoulders and no improved sidewalks. The new collection system will consist of a total
of approximately 12,150 linear feet (2.3 miles) of corrosion-resistant polyvinyl chloride (PVC)
piping, ranging in size from 8-inch diameter to 16-inch diameter. Construction of the new
wastewater collection system will require trenching in locations throughout the Pahala
community, primarily within the right-of-way of public streets plus two short segments within
easements. Trenches will typically be about 3 feet wide and at least 6 feet deep. Once the line is
placed in the trench, the affected area will be backfilled to restore the existing topography.
The two LCCs in Pahala are readily accessible for closure activities. LCC 1 is located in a parcel
that has been previously cleared and is currently overgrown with tall grasses. It may be necessary
to clear a path for construction vehicles and equipment to access LCC 1. Clearing an access road
(or other similar work) will not be necessary to access LCC 2, which is located in the backyard
2
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of a residential lot with access via the house driveway. The specific methods to be used for
closure of the LCCs have not yet been determined but will be compliant with DOH requirements.
Abandonment and closure of the two LCCs and the existing wastewater collection system will
likely require minor earthwork. The area of potential effects (APE) described below is designed
to encompass all potential closure activities.
Area of Potential Effects
In accordance with 36 C.F.R. § 800.4(a)(1), EPA has defined the APE as the entire project area
that will potentially experience ground disturbance due to excavation, trenching, grading, filling,
vegetation removal, construction vehicle use, establishment and use of staging and laydown
areas, and other similar activities. The APE encompasses the wastewater treatment plant
development parcel, the entire length of the new wastewater collection system, utility and sewer
line easements, the sites of the two existing LCCs, and properties with existing sewer laterals
(see Figure 1).
Identification of Historic Properties
The County conducted a search for historic properties within the APE for this undertaking and
two road segments were identified and documented as historic features in the Draft AIS.
However, after further review and evaluation, the County determined that they were not eligible
for inclusion on the National Register of Historic Places due to the lack of integrity apart from
their location.
If potential artifacts or archeological resources are discovered during construction activities, the
contractor will stop work immediately at that location and take all reasonable steps to secure the
preservation of those features.
Native Hawaiian Organization Consultation
In accordance with the requirements of the National Historic Preservation Act, numerous
stakeholders were consulted during the development of the Draft Environmental Assessment for
the Pahala Community Large Capacity Cesspool Replacement Project (Draft EA), including 14
Native Hawaiian Organizations that may attach religious or cultural significance to properties
affected by the undertaking. On March 29, 2018, each of the following organizations was sent a
copy of a project summary and a request for their written comments on the undertaking.
Attachment A provides an example of the correspondence that was sent to all 14 organizations
listed below. As of the date of this letter, no responses have been submitted to the County.
Hawai'i Island Burial Council
Association of Hawaiian Civic Clubs
Charles Pelenui Mahi 'Ohana
Friends of 'Iolani Palace
Hawaiian Civic Club of Hilo
Kamehameha Schools
Kanu o ka'Aina Learning 'Ohana
Ko'olau Foundation
Maku'u Farmers Association
Na Koa Ikaika Ka Lahui Hawai'i
Office of Hawaiian Affairs
Pacific Agricultural Land Management
Systems
Partners in Development Foundation
Pi'ihonua Hawaiian Homestead
Community Association
3
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Qtifrcich
Dunns: the public comment period fur the Draft I:A i September .as ?U|N ¦ December 10, 2U1K,i,
F.PA iind (hi* Count) leceived public comments t*\|nc\Miig concern teuuFtliug mijviclv to "a
burial cave with human skeletal remains and or shehirn'" ihat is ":n die area where the County
w.)!v> s io put .1 S w astew.iUT ireaimeM plant.*" Based on the available mhirmalion, hi'A utui
the County beiic^e that these comments rel'er to the filled Uiva tube opening identified in the
2t)lf> aiehaeoloi-ieuS held inspection report thai is described iit Sectior, I 2 of the Draft AIS- lu
ensure tint tb.e undertaking does nut alk\t this i»uJuu\iI ivsouice, Che CoujiI) eordieuied the site
plats loi the pioposed wastcwutei 'tealmenl and disposal laeilit) io ensure that the location of this
htv;i tube opening would lv outside the APH for this undertaking.
bjudum o1,Nn IhsUuic I'toperties Atleeied
In aecoiiLince with 3b CX.R, § »S(¥),4id,i, IIPA has rt'.K.hed a biiding of r,o hisfoih' pi,i|vnu*s
affected [or (his uildeilaking Since then* are no kilobit hfstoue or aiclteologieul sites, wilbui the
API-!, ami since apprupsiale piesei\ution measures will be taken should archeologieal resources
be discovered during construction. this undertaking will have no effect on any historic or cultural
lesoutces ot on any tiaitiltoual and eiistoituuy practices. In aiiihtion, the potential for
encountering unexpected arehce-logica! resources within the site of the proposed treatment and
disposal facility is tow due to historical ground modiiicatious and onpunp harvesting actio Hies.
I am requesting vuti couctiiieucc with the API; and the Jetemimatiori of no historic properties
ailecka! w Uhm days ol receipt ol this letter. If 1 do not recehe a response w ithin 30 days ;ij
receipt. I will assume euocurrence from your office and 1 PA will authorize the giant iceipienl to
proceed ttach the project ;n ac cot dance w ith M-> ('.[ R. § Sffil.-h'dM I ilil.
If you require additional information or have questions regarding this request, please contact
Kale Rao, Groundwater Protection Section, at (415) 972-1533 or via email ai rao.kate@cDa.gov,
Sincerch.
Manager, Croumiw utcr Protection Section
W ater i)ivision
William Kucharski, County of Hawaii
Dora Beck, County of Hawaii
4
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Attachments:
Figure 1 -- Area of Potential Affect andAIS Project Area for the Pahala Community LCC
Replacement Project
Figure 2 — Preliminary site plan showing the 14.9-acre Pahala WWTP within the southeast
portion of Site 7.
Attachment A - Native Hawaiian Organizations Correspondence
5
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C320CKS33
eacsMiiviMaaia^
eassa
LCC 1
PA HA HA
BawMap Occ^ feolh A«?ial NT«o«ry <2013) .
Date Scmw; CSh C *v
Figure X. Area of Potential Affect and AIS Project Area for the Pahala Community
LCC Replacement Project
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Figure 1. Preliminary site plan showing the 14.9-acre Pahala WWTP within the southeast portion of Site 7. (Courtesy of Cultural
Surveys Bawai'i]
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Harry Kim William A. Kucharski
May0r Director
Wilfred M. Okabe Diane A- ^oda
Managing Director ^ Deputy Director
(ttnuttfjj ni^nimxx
DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
345 Kekuanao'a Street, Suite 41 • Hilo, Hawai'i 96720
Ph: (808) 961-8083 • Fax: (808) 961-8086
cohdem@co.hawaii.hi.ijs
hlti)://vn\'\v.l)awaiicou[)tv.gov/environmen
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County to comply with EPA regulations requiring closure of large capacity cesspools (LCCs)
and to construct a system meeting current State of Hawai'i Department of Health (DOH) and
DEM design guidelines for the collection, treatment and disposal of the treated effluent. The
Pahala Community Large Capacity Cesspool Replacement Project improvements would be
owned, operated and maintained by the County. A project summary sheet and location map are
enclosed for your information.
The new wastewater collection system will be located within public rights-of-way, and the new
treatment and disposal system will be located 011 a currently privately owned parcel (TMK: 9-6-
002:018) which will be acquired by the County. The wastewater collection system would be
located within 7 public streets; Maile Street, 'Ilima Street, Huapala Street, HTnano Street, and
Hala Street, all located in the southern portion of the community and Puahala Street; and Plkalce
Street located on the eastern end. The collection system would consist of approximately 11,000
linear feet of gravity flow piping ranging from 8 to 12 inches in diameter. The collection system
is not anticipated to include County pump stations, nor will the system collect stormwater runoff.
The County's sewer standards show the trenches for sewer lines would require at least 4 feet of
cover from the top of the pipe to grade and 12 inches of cushion material on both sides of the line
and 6 inches below the line. Therefore, the typical sewer trenches will be about 3 feet wide and
at least 6 feet deep.
The proposed treatment and disposal system would occupy about 14 acres and consist of a
headworks with screens to remove debris and an odor control unit, four lined aerated lagoons of
about 0.3 acres each, an operations building with adjacent disinfection system to remove
pathogens, a subsurface flow constructed polishing wetland to remove nitrogen and four slow
rate (SR) land treatment basins planted with native Hawaiian trees that will be surrounded by
berms on all four sides. SR land treatment involves irrigation of land and vegetation with the
treated effluent. Significant additional treatment is provided as the water percolates through the
soil. The vegetation uptakes the nutrients in the effluent as fertilizer, and transpires a portion of
the applied water. A security fence will be constructed along the perimeter of the site.
An archaeological inventory survey, including the excavation of trenches, will be conducted
within the treatment and disposal project site to identify the presence of historic properties as
defined in U.S.C §300308.
Consultations
We welcome any comments you have on this Project's proposed improvements. We are
particularly interested in any information you may have on the historic and cultural sites that
have been recorded in tire area or any other historic or cultural sites about which you may have
knowledge.
Section 106 consultation letters have also been sent to other organizations or individuals that
might attach significance to this area and inviting them to participate in the process. The attached
list shows the organizations that are also being consulted as part of this Section 106 consultation.
In addition, if you are acquainted with any persons or organization that are knowledgeable about
the proposed project area, or airy descendants with ancestral lineal or cultural ties to or cultural
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knowledge or concerns for, and cultural or religious attachment to the proposed project area, we
would appreciate receiving their names and contact information.
We would appreciate a written response within 30 days from date of receipt of this letter to Dora
Beck, P.E., Project Manager, County of Hawai'i Department of Environmental Management, by
U.S. Postal Service to County of Hawai'i Department of Environmental Management, 108
Railroad Avenue, Hilo, Hawai'i 96720.
Please feel free to contact Dora Beck by telephone at (808) 961-8513 if you have any questions.
We look forward to working with you and the State Historic Preservation Division on these
needed improvements.
Very truly yours.
Director
WK/DB:mef
Attachment and enclosures
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Pahala Community Large Capacity Cesspool Replacement Project
Pa'au'au, Xa'u, Hawai'i
Native Hawaiian Organizations Consultation List
Hawai'i Island Burial Council
Association of Hawaiian Civic Clubs
Charles Pelenui Mahi 'Ghana
Friends of 'Iolani Palace
Hawaiian Civic Club of Hilo
Kamehameha Schools
Kanu o ka'Aina Learning 'Ghana
Ko'olau Foundation
Maku'u Farmers Association
Na Koa Ilcaika Ka Laliui Hawai'i
Office of Hawaiian Affairs
Pacific Agricultural Land Management Systems
Partners in Development Foundation
Pi'ihouna Hawaiian Homestead Community Association
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PROJECT SUMMARY
Pahala Community Large Capacity Cesspool Closure
Pa'au'au, Ka'u, Island of Hawai'i
Tax Map Key: 9-6-002:018
1. introduction
The community of Pahala is located about 52 miles southeast of Hilo, in the Ka'u District, Island of
Hawai'i. Pahala is located west (mauka) of Mamalahoa Highway (State Route 11) about 3.8 miles
from the shoreline with most of the community lying between 980 feet mean sea level (msl) on the
western end and approximately 800 feet msl on the eastern end. See Figure 1. The Pahala
community had its start in 1876 with establishment of the Hawaiian Agricultural Company to develop
the sugar industry in Hawai'i. For the next 120 years or so, Pahala was a major sugar producing area.
However, by the early 1990s there was a major downturn in the sugar market. Thus, beginning in
1994, the sugar mill in the town was shut down and dismantled. By 1996, the Ka'u Sugar Company,
the successor to the Hawaiian Agricultural Company, closed and, subsequently, the sugar cane fields
were cleared and the lands now grow macadamia nut and coffee trees. The population in Pahala was
approximately 1,405 persons in 2016, the most current estimate.
Founded in 1826, C. Brewer was both the oldest company in Hawai'i and a major developer of the
sugar industry in Pahala. For about the last 60 years, approximately 50 percent of the residential
units in Pahala have been serviced by a wastewater collection and disposal system constructed,
operated and maintained by C. Brewer. The collection system consisted of sewer lines, some of
which were located in the streets and others routed in the backyards of private parcels. The disposal
system consisted of two large capacity cesspools (LCCs) within the community.
In 1998, the US Environmental Protection Agency (EPA) issued regulations (40 CFR 144.14) requiring
the elimination or closure of all large capacity cesspools used for wastewater disposal by April 5,
2005. In 2003, C. Brewer requested assistance from the County to close their LCCs. Subsequently,
the County held a community meeting to present sewer system replacement alternatives. Voting took
place by mail to choose the preferred sewer improvement alternative, resulting in 87 percent of
returned ballots in favor of installing a new sewer collection, treatment and disposal system to be
operated and maintained by the County.
In 2006, in anticipation of its dissolution, C. Brewer requested the County construct and maintain a
new community sewer system. The County subsequently agreed by way of a County Council
Resolution, to enter into a formal agreement to assume ownership of the C. Brewer constructed
collection system and the two LCCs by April 30, 2010 and to construct and maintain a new community
sewer system. As part of the County's agreement, C. Brewer agreed to install laterals to certain of the
residential properties.
In 2007, the County proposed a new collection system and a wastewater treatment system, consisting
of large capacity septic tanks and converting the existing LCCs into seepage pits for disposal of the
treated effluent. In 2008, the combination of the LCCs being in poor and failing condition and the poor
results from soil percolation tests influenced the County to consider acquiring a larger land area to
construct a secondary treatment system. Such a system could allow a higher level of wastewater
treatment and disposal, as well as accommodate existing Pahala properties not currently served by
the LCC system in addition to expanding the system to accommodate possible community growth.
2. Project Description
The County of Hawai'i. Department of Environmental Management (DEM) is proposing to construct
wastewater system improvements to replace the current system servicing Pahala, now owned by the
County. The wastewater system improvements would allow the County to comply with EPA
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PROJECT SUMMARY
Pahala Community Large Capacity Cesspool Closure
Pa'au'au, Ka'u, Island of Hawai'i
Tax Map Key: 9-8-002:010
regulations requiring closure of the LCCs and to construct a system meeting current State of Hawai'i
Department of Health (DOH) and DEM design guidelines for the collection, treatment and disposal of
the treated effluent. The Pahala Community Large Capacity Cesspool Closure project improvements
would consist of a new wastewater collection system located within the public right-of-way and a
treatment and disposal system located on a currently privately-owned parcel (TMK: 9-6-002: 018)
which will be acquired by the County. The Pahala Community Large Capacity Cesspool Closure
project would be funded by an EPA Special Appropriation Grant and by the State of Hawai'i Clean
Water State Revolving Fund (SRF) loan program.
The wastewater collection system would be located within 7 public streets; Maile Street; 'llima Street;
Huapala Street; HTnano Street; Hala Street; all located in the southern portion of the community and
Puahala Street; and PTkake Street located on the eastern end. These streets serve the residential
areas and have two travel lanes with unpaved shoulders and no improved sidewalks. The collection
system would consist of approximately 11,000 linear feet of gravity flow piping ranging from 8 to 12
Inches in diameter. The collection system is not anticipated to include pump stations, nor will the
system collect stormwater runoff. The number of manholes in the system will be determined during
the detail design phase. The County's sewer standards show the trenches for sewer lines would
require at least 4 feet of cover from the top of the pipe to grade and 12 inches of cushion material on
both sides of the line and 6 inches below the line. Therefore, the typical sewer trenches will be 3 feet
wide and at least 6 feet deep.
The treatment and disposal system would be a land-based system located southeast of the developed
community and would be designed to treat flows of approximately 190,000 gallons per day. The EPA
defines land treatment as "the application of appropriately pre-treated municipal and industrial
wastewater to the land at a controlled rate in a designed and engineered setting. The purpose of
the activity is to obtain beneficial use of these materials, to improve environmental quality, and to
achieve treatment goals in a cost-effective and environmentally sound manner".
The proposed treatment and disposal system would occupy about 14 acres and consist of a
headworks with screens to remove debris and an odor control unit, four lined aerated lagoons of
about 0.3 acres each, an operations building with adjacent disinfection system to remove pathogens,
a subsurface flow constructed polishing wetland to remove nitrogen and four slow rate (SR) land
treatment basins which will be surrounded by berms on all four sides. SR land treatment involves
irrigation of land and vegetation with the treated effluent. Significant additional treatment is
provided as the water percolates through the soil. The vegetation uptakes the nutrients in the
effluent as fertilizer, and transpires a portion of the applied water. A security fence will be
constructed along the perimeter of the site.
3. Anticipated impacts
Project impacts would be primarily related to construction of the trenches for placement of the
collection system lines and construction of the land-based treatment and disposal system. These
activities would create dust and noise while work occurs in the streets and in the area of the land
treatment and disposal system, which will include removal of existing macadamia nut trees within the
14 acre project site. As the collection system is constructed, the streets will be restored for vehicle
travel. Upon completion of the treatment and disposal facilities, the project will operate without the
need for DEM employees to be on-site. Weekly monitoring visits will be sufficient to insure routine
proper operation, and a telemetry system will alert DEM employees of abnormal conditions to allow
timely response when they occur.
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FIGURE 1
PROJECT LOCATION MAP
PAHALA COMMUNITY LARGE CAPACITY CESSPOOL CLOSURE PROJECT
COUNTY OF HAWAII DEPARTMENT OF ENVIRONMENTAL MANAGMENT
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^£D sr*%
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^ PRCtf^
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION !X
75 Hawthorne Street
San Francisco, CA 94105-3901
HAR 0 8 2018
Mililani B. Trask, Convenor
Na Koa Ikaika Ka Lahui Hawaii
PO Box 6377
Hilo. HI 96720
RE: U.S. Environmental Protection Agency Region 9 authorization to allow the County of
Hawaii to initiate consultation with the State Historic Preservation Officer and Native
Hawaiian organizations for the Pahala Community Large Capacity Cesspool Replacement
Project
Dear Ms. Trask;
The U.S. Environmental Protection Agency Region 9 (EPA) awarded a Special Appropriation Act
project grant to the County of Hawaii for the Pahala Community Large Capacity Cesspool (LCC)
Replacement Project. This project may have effects on properties included in, or eligible for
inclusion in, the National Register of Historic Properties. The National Historic Preservation Act
(NHPA), 54 U.S.C. §300101 etseq., and its implementing regulations, 36 CFR Part 800, require
federal agencies to consider the effects of their undertakings on historic properties.
Pursuant to 36 CFR §800.2(c)(4), a Federal agency may authorize an applicant for federal
assistance to initiate consultation with the State Historic Preservation Officer (SHPO) or Native
Hawaiian organizations provided that: (1) the Federal agency remains legally responsible for all
findings and determinations charged to the agency official; and (2) the Federal agency notifies the
SHPO or Native Hawaiian organizations when an applicant is so authorized.
In accordance with 36 CFR §800.2(c)(4), EPA hereby authorizes the County of Hawaii to act on
EPA's behalf when initiating the NHPA consultation process in connection with tire Pahala
Community LCC Replacement Project. Effective immediately, the County of Hawaii may consult
with the SHPO and Native Hawaiian organizations (see enclosed list) to initiate the review
process under 36 CFR Part 800 including identifying and evaluating historic properties, assessing
effects, and proposing mitigation measures where necessary. However, EPA Region 9 will remain
responsible for participating in the consultation process if:
® the County of Hawaii determines that the "Criteria of Adverse Effect" under 36 CFR
§800.5 applies to this project; or
® there is disagreement between the County of Hawaii and the SHPO or Native Hawaiian
organizations regarding the scope of the area of potential effects, identification of historic
properties, or evaluation of effects; or
Printed on 100% Postconsumer Recycled Paper. Process Chlorine Free.
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© there is an objection from consulting parties or the public regarding findings or
determinations or the implementation of agreed provisions; or
« there is potential for a foreclosure situation or intentional adverse effects as described
under 36 CFR §800.9(b) and (c).
hi accordance with 36 CFR §800.2(c)(2), EPA shall ensure that all consultations with Native
Hawaiian organizations are conducted in a sensitive manner concerning the needs of such
organizations.
If you have any questions, please contact Kate Rao, Drinking Water Protection Section, at (415)
972-3533 or via email at rao.lcate@,epa.gov.
Water Division Director
Encl.: Pahala Large Capacity Cesspool Replacement Project
Native Hawaiian Organizations Consultation List
cc: William Kurcharslci, County of Hawaii
Dora Beck, County of Hawaii
Craig Levken, Brown and Caldwell
Earl Matsukawa, Wilson Okamoto Corporation
John Sakaguchi, Wilson Okamoto Corporation
David Shideler, Cultural Surveys Hawaii, Inc
2
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Pahala Large Capacity Cesspool Replacement Project
Native Hawaiian Organizations Consultation List
Hawaii Island Burial Council
Association of Hawaiian Civic Clubs
Charles Pelenui Mahi Ghana
Friends of lolani Palace
Hawaiian Civic Club of Hilo
Kamehameha Schools
Kanu o ka 'Aina Learning 'Ohana
Koolau Foundation
Malcu'u Fanners Association
Na Koa Ilcaika Ka Lahui Hawaii
Office of Hawaiian Affairs
Pacific Agricultural Land Management Systems
Partners in Development Foundation
Piihonua Hawaiian Homestead Community Association
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Final EA, Pahala LCC Replacement Project
Pahala, Ka'u District, Hawai'i
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Final EA, Pahala LCC Replacement Project
Pahala, Ka'u District, Hawai'i
Appendix E
EPA and County of Hawai'i Responses to Comments on the Draft EA
February 2020
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Pahala, Ka'u District, Hawai'i
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Appendix E:
U.S. Environmental Protection Agency
and County of Hawai'i
Response to Comments on the Draft
Environmental Assessment
for the
Pahala Large Capacity Cesspool (LCC)
Replacement Project
EPA Grant XP-96942401
Pahala, District of Ka'u, County of Hawai'i, Hawai'i
TMK: 9-6-002:018
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Final EA, Pahala LCC Replacement Project - Appendix E
Pahala, Ka'u District, Hawai'i
Contents
1 Index of Comments Received on the Pahala Large Capacity Cesspool Replacement
Project Draft EA 1
2 EPA Response to Comments 3
2.1 Resource Area Impacts 3
2.1.1 Flood Risk 3
2.1.2 Public Services 6
2.1.3 Visual Characteristics 7
2.1.4 Socioeconomic 7
2.1.5 Archeological and Cultural Resources 11
2.1.6 Air Quality 13
2.1.7 Other Impacts 14
2.2 NEPA Processes 16
2.2.1 Purpose and Need 16
2.2.2 Scope of the Proposed Action 17
2.2.3 Cumulative Effects 19
2.2.4 Federal and State Consultations 20
2.2.5 NEPA Procedures 22
2.3 Public Involvement and Outreach 24
2.3.1 Outreach 24
2.3.2 Accessing the Draft EA 28
2.3.3 Public Information Meeting 28
2.3.4 Na'alehu and Pahala LCC Conversion Project - 2007 Final EA 30
2.3.5 State and Local Agencies 31
2.4 State and Local Processes 31
2.4.1 State of Hawai'i Office of Planning 32
2.4.2 Hawai'i Environmental Policy Act (HEPA) 32
2.4.3 Hawai'i Department of Business, Economic Development and Tourism,
Land Use Commission (LUC) 33
2.4.4 Ka'u Community Development Plan (CDP) 34
2.5 Project Location and Design 34
2.5.1 Proximity to Schools 34
2.5.2 Location of Preferred Alternative 35
2.5.3 Extent of Collection System 36
2.5.4 Treatment Alternatives 37
2.5.5 Technical Design 38
2.6 Other Comments 41
2.6.1 Miscellaneous and Other Comments 41
2.6.2 Na'alehu Large Capacity Cesspools Closure Project 43
2.7 Comments Not Related to NEPA 44
3 County of Hawai'i Response to Comments 46
February 2020
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Final EA, Pahala LCC Replacement Project - Appendix E
Pahala, Ka'u District, Hawai'i
1 Index of Comments Received on the Pahala Large
Capacity Cesspool Replacement Project Draft EA
A Draft Environmental Assessment (EA) for the Pahala Large Capacity Cesspool (LCC)
Replacement Project1 was released for public comment on September 23, 2018. Initially, a 30-
day public comment period was planned; however, due to requests from the public for additional
time, the U.S. Environmental Protection Agency (EPA) and the County of Hawai'i (County) agreed
to republish the Draft EA on November 8, 2018 which extended the comment period. The
comment period closed on December 10, 2018. Table 1 lists the comments received, including
the names of the commenters and a comment number assigned to each comment. In total, 77
comment letters were received, some of which included multiple individual comments.
Table 1
Index of Comments Received on the Pahala LCC Replacement Project Draft EA
Number
Commenter
Date
1
S
Demoruel
e
9/24/2018
2
S
Demoruel
e
9/24/2018
3
s
Demoruel
e
9/24/2018
4
s
Demoruel
e
9/24/2018
5
s
Demoruel
e
9/25/2018
6
s
Demoruel
e
9/25/2018
7
s
Demoruel
e
9/25/2018
8
s
Demoruel
e
9/25/2018
9
s
Demoruel
e
9/28/2018
10
s
Demoruel
e
9/28/2018
11
s
Demoruel
e
9/28/2018
12
s
Demoruel
e
9/28/2018
13
s
Demoruel
e
9/29/2018
14
s
Demoruel
e
10/1/2018
15
s
Demoruel
e
10/1/2018
16
s
Demoruel
e
10/3/2018
17
s
Demoruel
e
10/6/2018
18
s
Demoruel
e
10/10/2018
19
s
Demoruel
e
10/12/2018
20
s
Demoruel
e
10/13/2018
21
s
Demoruel
e
10/21/2018
22
s
Demoruel
e
10/24/2018
23a
S. & J. Demoruelle
10/22/2018
23
[Comment combined in 23a]
24
[Comment combined in 23a]
25
[Comment combined in 23a]
26
T. Tuttle
10/10/2018
27
S
Demoruelle
10/10/2018
28
N. Hong
10/10/2018
29
N. Gilmour
10/17/2018
30
J. Warren
10/19/2018
31
N. Gilmour
10/20/2018
1 Preconsultation letters and other materials related to this project may use a slightly different project title
(e.g., Pahala Community Large Capacity Cesspool Replacement Project).
February 2020
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Final EA, Pahala LCC Replacement Project - Appendix E
Pahala, Ka'u District, Hawai'i
Table 1
Index of Comments Received on the Pahala LCC Replacement Project Draft EA
32
State of Hawai'i Office of Planning
10/17/2018
33
E. Andrade Jr.
10/19/2018
34
C. & T. Tuttle
10/22/2018
35
State of Hawai'i Department of Hawaiian Home Lands
9/27/2018
36
County of Hawai'i Police Department
10/2/2018
37
R. Javar
10/10/2018
38
L. Lopes
10/22/2018
39
S. Demoruelle
10/23/2018
40
Pahala Residents per Pele Defense Fund
10/23/2018
41
S. Hanoa
10/23/2018
42
J. Moses
10/24/2018
43
A. & A. McDowell
10/22/2018
44
D. Loper
9/29/2018
45
S. Demoruelle
10/31/2018
46
S. Demoruelle
10/31/2018
47
S. Demoruelle
10/31/2018
48
S. Demoruelle
10/31/2018
49
S. Demoruelle
10/26/2018
50
S. Demoruelle
11/2/2018
51
S. Demoruelle
11/5/2018
52
S. Demoruelle
11/6/2018
53
S. Demoruelle
11/8/2018
54
S. Demoruelle
11/13/2018
55
A. & M. Ibarra
11/13/2018
56
W. & D. Wong Yuen
11/14/2018
57
S. Demoruelle
11/16/2018
58
S. Demoruelle
11/2/2018
59
L. Navarro
11/19/2018
60
L. Gollin
11/19/2018
61
T. Ibarra
12/1/2018
62
P. Fuerte
10/10/2018
63
G. Sorensen
11/2/2018
64
S. Demoruelle
12/10/2018
65
S. Demoruelle
12/10/2018
66
S. Demoruelle
12/10/2018
67
T. Napeahi, Pele Defense Fund
12/10/2018
68
D. Kalua
12/4/2018
69
T. Napeahi, Pele Defense Fund [Duplicate of Comment 67]
12/10/2018
70
T. Napeahi, Pele Defense Fund [Duplicate of Comment 67]
12/10/2018
71
State of Hawai'i Department of Land and Natural Resources
12/7/2018
72
State of Hawai'i Department of Education
12/7/2018
73
N. Gilmour
12/10/2018
74
K. Fox
12/10/2018
75
S. Demoruelle
12/10/2018
76
N. Hong
10/28/2018
77
State of Hawai'i Department of Land and Natural Resources
10/22/2018
February 2020
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Final EA, Pahala LCC Replacement Project-Appendix E
Pahala, Ka'u District, Hawai'i
2 EPA Response to Comments
EPA's responses to comments received are detailed below. Due to the number of comments
received, comments and responses are grouped by subject matter. Each section contains a
summary of comments received, followed by EPA's responses.
As explained in the Preface of the Final EA, EPA and the County elected to prepare a joint EA in
order to promote consistency and avoid duplication of efforts. Due to the fact that it is a joint
document, the Final EA contains information related not only to compliance with the National
Environmental Policy Act (NEPA) and federal cross-cutting authorities, but also information
related to compliance with state and local requirements, such as the Hawai'i Environmental Policy
Act (HEPA), otherwise referred to as Hawai'i Revised Statutes (HRS) Chapter 343. EPA is only
responsible for addressing compliance with NEPA and federal cross-cutting authorities, and thus,
EPA's responses to comments are focused on these issues. The County is responsible for
complying with additional state and local requirements and has prepared separate responses to
individual comments that are included in Section 3 of this Appendix. The County responses use
the same numbering system as Table 1 (see Section 1).
2.1 Resource Area Impacts
Responses to comments received regarding the impacts to the resource areas as described in
the Draft EA associated with the proposed project have been arranged into the following
categories:
• Flood Risk
• Public Services
• Visual Characteristics
• Socioeconomic
• Archeological and Cultural Resources
• Air Quality
• Other Impacts
2.1.1 Flood Risk
Comment
• I am concerned about the flooding potential of the WWTP, specifically relating to the
culvert that carries water beneath the highway from the macadamia nut orchard.
(Comments 22, 41)
• What will prevent the "lagoon style treatment plant" from overflowing in the event of heavy
rains and flooding due to tropical storms and hurricanes, which may be more frequent with
climate changes? (Comments 28, 33, 56)
• There has been historical flooding that is a major concern to the community, to the
proposed area. (Comment 40)
• Flooding at the sewage treatment plant site will cause health and safety issues.
(Comments 63, 76)
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Final EA, Pahala LCC Replacement Project - Appendix E
Pahala, Ka'u District, Hawai'i
• Flooding at the site will create hazardous and dangerous scenarios. Flooding will impact
emergency routes, may impact travel to hospitals or emergency facilities and could isolate
emergency first responders, fire and EMS vehicles and equipment. (Comments 41, 67,
68)
• The location of the plant should be reconsidered because of the history of flooding in the
area. Overflow of the reservoirs could transport toxins, bacteria, and chemicals over
Highway 11, through conservation and preservation areas, and into the ocean.
(Comments 55, 76)
Response
Due to the nature of the comments received, the responses to flooding-related comments were
broken into two response categories:
a) Flood Risk: Response addressing concerns regarding the potential for the location of
the wastewater treatment and disposal facility and collection system to flood; and
b) Overflow of Wastewater Treatment and Disposal Facility: Response addressing
concerns regarding the design of the facility and concerns related to overflow inside
the facility.
a) Flood Risk
As stated in the Draft EA Section 3.9.1 (Flood Risk - Existing Conditions), the Federal Emergency
Management Agency (FEMA) Flood Insurance Rate Map (FIRM), Community Panel No. 155166
1800F, effective date September 29, 2017, shows that most of the Pahala area is located in Zone
X, which designates areas determined to be outside the 0.2-percent annual chance (500-year)
floodplain. A small portion of the community of Pahala, including some land within the collection
system project site, is located within Zone X - Other Flood Areas, indicating areas within the 0.2-
percent annual chance (500-year) floodplain, or areas with a 1-percent annual chance of flooding
with average flood depths less than 1 foot. The County of Hawai'i Department of Public Works (in
its April 16, 2018 response to the pre-assessment notification) confirmed that the proposed
wastewater treatment and disposal facility site is outside the 500-year floodplain. As such, the
site is not considered to be in a high flood risk area. The wastewater treatment and disposal facility
would not result in construction of new facilities within the 500-year floodplain. Although a small
portion of the proposed collection system is located within the 500-year floodplain, the associated
trenching operations would be temporary and would not alter the 500-year floodplain. No impacts
to the existing floodplain are expected.
The wastewater treatment and disposal facility would be designed to minimize the creation of new
stormwater flow and to avoid disrupting existing stormwater flow patterns. Current drainage
patterns are influenced by two existing culverts that allow stormwater to flow across the
Mamalahoa Highway in the vicinity of the proposed wastewater treatment and disposal facility.
The first is a box culvert located at the intersection with Maile Street that conveys stormwater
under the highway. The second culvert is located approximately 600 feet east of the Maile Street
intersection and was used to convey sugar mill flume water across the highway for disposal.
Please see the Final EA Section 3.23.1 (Infrastructure - Drainage System) for a map showing the
location of the two culverts.
The proposed wastewater treatment and disposal facility would include an on-site drainage
system to address stormwater surface runoff created by new impervious surfaces within the
facility. The site would include a system to collect runoff via grated inlets or swales, and flows
would be conveyed to on-site drainage detention systems, such as subsurface linear infiltration
or depressed detention basins (see Draft EA Section 3.23.2).
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Pahala, Ka'u District, Hawai'i
The Pahala LCC Replacement Project would have minimal impact on existing stormwater flows.
The Site 7 parcel, including the proposed site of the wastewater treatment and disposal facility,
slopes from approximately north to south (mauka to makai) such that, during rain events, surface
flows drain through the existing orchard to the southern (makai) end where the flows eventually
drain through the culvert located at the Maile Street - Mamalahoa Highway intersection to the
areas below the highway. Stormwater drainage flows generated upstream of the wastewater
treatment and disposal facility project site would be directed around the perimeter via diversion
swales that would convey flow back to the existing drainage pattern to the culvert at Maile Street.
During heavy rain events, stormwater may temporarily back up behind the culvert. However, these
ponding events are typical and expected at any culvert and would not be exacerbated as a result
of the Proposed Action because there would be no net increase in runoff or drainage flows from
the site up to and including design storm events. Due to the topography of Site 7, stormwater
drainage flows from onsite are not anticipated to flow through the second culvert mentioned above
due to its elevation and location to the east which means it is generally upgradient from the onsite
drainage patterns.
As a result, the Pahala LCC Replacement Project is not anticipated to contribute to any increased
risk of flooding of Mamalahoa Highway, Maile Street, or downstream properties. The State of
Hawai'i Department of Transportation (DOT) Hawai'i District office was contacted to discuss the
historical roadway flooding concerns expressed by the community at the wastewater treatment
and disposal facility project site and the culvert at the Maile Street - Mamalahoa Highway
intersection. The District office indicated the DOT owns and maintains the culvert at the Maile
Street intersection, and that they have no record of the roadway being inundated by stormwater
drainage at that location during precipitation events.
Furthermore, the Pahala LCC Replacement Project would be constructed in accordance with all
applicable design criteria related to minimizing flood risk. As stated in the Draft EA Section 3.23
(Infrastructure - Drainage System), the on-site stormwater management system would meet the
requirements of Hawai'i County Code (HCC) § 27-20(e) (Standards for subdivisions and other
developments), which mandates a site drainage plan to "comply with sections 27-20(a) and (b)
and section 27-24, and shall include a storm water disposal system to contain runoff caused by
the proposed development, within the site boundaries, up to the expected one-hour, ten year
storm event as shown in the department of public works 'Storm Drainage Standards' unless those
standards specify a greater interval." To act as secondary containment in the event of a large
storm event, landscape buffers with dirt berms may also be constructed around most of the
perimeter of the facility; these berms would be subject to a geotechnical engineering assessment
of berm stability during the design process.
In addition, to meet the requirements of HCC § 27-20(f), the wastewater treatment and disposal
facility would be designed to not alter the general drainage pattern above or below the
development. Thus, no increase in flow amount for HCC design storm events would be directed
to either of the culverts at the highway as a result of the site development. HCC § 27-20 requires
an on-site drainage plan to accommodate any runoff caused by a proposed development.
Therefore, a drainage study would be prepared during the design process to evaluate the
improvements that are needed to comply with the County Code requirements. These additional
requirements and impact avoidance measures are stated in the Final EA Sections 2.3.1 and 3.23.
Finally, the Pahala LCC Replacement Project is not anticipated to impact emergency routes. The
Draft EA Section 2.3 (Proposed Action - Site 7 Alternative) Figure 2.2 showed that the Pa'au'au
Gulch near the hospital is located about 0.735 miles north of the wastewater treatment and
disposal facility site and lies at approximately 780 feet above mean sea level (about 140 to 200
feet above the site), which means surface flows at the site would not affect the gulch. Similarly,
the Kaimani Street and Mamalahoa Highway intersection lies about 0.72 miles north of the
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Final EA, Pahala LCC Replacement Project - Appendix E
Pahala, Ka'u District, Hawai'i
wastewater treatment and disposal facility site and at about 780 feet above mean sea level, which
means surface flows at the site would also not affect that intersection. As stated above, the project
would not increase the risk of flooding of Mamalahoa Highway or Maile Street as it would not
increase the amount of runoff. Emergency access to Ka'u Hospital would not be impacted as a
result of the Proposed Action because flooding of the roads due to stormwater and surface flow
is not expected to increase as a result of the Proposed Action. The entrance to the Ka'u Hospital
on Kamani Street is about 3/4 mile northeast of the proposed wastewater treatment and disposal
facility site.
b) Overflow of Wastewater Treatment and Disposal Facility
The wastewater treatment and disposal facility and collection system would be designed to
accommodate the peak flows during design wet weather flow events, including precipitation on
the area occupied by the lagoon treatment system. In the Draft EA Appendix B (Preliminary
Engineering Report), Section 2.2, the anticipated peak wastewater flows from the community
provided are based on the applicable design standards. The Draft EA Section 2.3.1 (Acquire Site
7 and Construct New Secondary Wastewater Treatment and Disposal Facility) stated the lagoons
would be lined with high density polyethylene liners to prevent water seepage through the bottom
and sides of the lagoons. The Draft EA Appendix B Section 5.3 showed the lagoons would have
sufficient operational freeboard to contain and to equalize design flows during peak weather
events. In addition, the slow-rate land application groves would be designed to completely contain
both anticipated peak wet weather effluent flows and on-site captured precipitation from a 100-
year, 24-hour storm event. This would be accomplished by constructing berms around the land
application tree groves. The tree groves would be designed in accordance with the EPA's
"Process Design Manual, Land Treatment of Municipal Wastewater Effluents." Effluent would be
applied at a hydraulic loading rate that is a small percentage of the percolation rate of the soil,
ensuring sufficient capacity for assimilation of peak effluent flow rates and precipitation from the
design storm event. Thus, the collection system, the lagoons themselves, and the land application
groves would be designed to include sufficient extra capacity to limit overflows during design
storm events. Due to these flood mitigation measures, no overflows would occur for storms up to
the 100-year, 24-hour storm event.
Additional information concerning the flood risk of the proposed treatment and disposal facility
and collection system has been added to the Final EA Section 2.3.1 (Acquire Site 7 and Construct
New Secondary Wastewater Treatment and Disposal Facility) and 3.23 (Infrastructure - Drainage
System).
2.1.2 Public Services
Comment
• Maile Street is an emergency route in and out of Pahala. If the county fences the property,
will the road be closed if there is an emergency? Will Mamalahoa Highway be closed too?
(Comment 41)
Response
The fencing of the wastewater treatment and disposal facility (Site 7) would not affect emergency
routes. As discussed in the Draft EA Section 3.17 (Traffic), the Proposed Action is "outside the
Mamalahoa Highway ROW and would not require any disturbance or other impacts within the
Mamalahoa Highway ROW." Maile Street would be impacted only to the extent needed for typical
traffic control operations and no permanent or temporary fencing would be constructed in a way
that impacts Maile Street or Mamalahoa Highway. This is also depicted in the Draft EA Figure
2.3, which shows no project elements affecting Maile Street or Mamalahoa Highway. Prior to
implementing the Proposed Action, traffic control plans would be developed and approved by the
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Final EA, Pahala LCC Replacement Project - Appendix E
Pahala, Ka'u District, Hawai'i
County which would include measures to allow for emergency access during project construction.
As stated in the Draft EA Section 3.17.2, the traffic control plans would provide directions to
temporarily divert traffic or close travel lanes during the construction period. Normally, such plans
call for these diversions or closures during non-peak travel times to minimize disruptions to traffic
flow. No long-term road closures would be needed for the Proposed Action. This information has
been repeated and clarified in the Final EA.
2.1.3 Visual Characteristics
Comment
• Why should people here in Pahala have to see a sewage plant when entering our town?
(Comment 41)
• The treatment plant will be visible during times of high winds, as the surrounding trees and
foliage bend and sway. (Comment 56)
• The plant will be an eyesore at the entrance to our community. (Comments 63, 67)
Response
As discussed in the Draft EA Section 3.19 (Visual Considerations and Light Pollution), the
Proposed Action is not expected to adversely affect the views or viewsheds identified in the
County General Plan. Above grade structures, such as the operations building and, headworks
cover structure, would be screened by existing Cook pine trees along Maile Street, most of which
would remain. The wastewater collection system would be installed below the streets and
therefore would not impact views. Visual impacts would also be mitigated by the 8.0 acres of
planted trees in the disposal groves, and by the rise in elevation between the highway and the
facility. Exterior lighting at the proposed wastewater treatment and disposal facility would be
designed in accordance with HCC § 14-50 and would be limited to manually switched lights under
the roof overhang at the entrance to the operations/electrical building and at the headworks area.
Lights would be installed with down-shielding to prevent excess light pollution. When an operator
or maintenance staff are not present on-site, lights would not be on. The Final EA Section 3.19
has been revised to include that the maximum height of the wastewater treatment and disposal
facility above-grade structures would not exceed 25 feet. For more information, please refer to
the County responses provided to the above comments.
2.1.4 Socioeconomic
Cost of the Project
Comment
• The costs of the project are excessive and will cause economic harm of the county into
the future. The cost will be over $250,000 per LCC household. (Comment 45)
• The Pahala project cost is excessive ($40.5 million). The cost of the project should be kept
under $10 million. (Comments 45, 46)
• The cost estimates for the Pahala WWTP Project are inaccurate. The project will cost
approximately $40 million. (Comment 51)
• The combined costs of both WWTP projects in the County are excessive. (Comment 51)
• These Wastewater Projects have become a total boondoggle. Please stop this waste of
tax dollars and set a firm budget of under $10 million! (Comment 52)
• The costs of the project have skyrocketed. (Comment 61)
February 2020
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Final EA, Pahala LCC Replacement Project - Appendix E
Pahala, Ka'u District, Hawai'i
• The County and Ka'u taxpayers cannot afford to spend $81 million the two projects.
(Comment 66)
• The cost of the project is grossly underestimated. (Comment 23a)
Response
NEPA does not require a monetary cost-benefit analysis of a project, particularly where there are
important qualitative considerations. See 40 CFR § 1502.23.2 In this case, the "No-Action
Alternative" would not satisfy the intended purpose and need for the Proposed Action as outlined
in the Draft EA Section 2.2 (Purpose and Need for Action), which is to provide the infrastructure
necessary to enable the County to comply with the Safe Drinking Water Act (SDWA) and fulfill
the compliance provisions of the Administrative Order on Consent (AOC) between EPA and the
County with respect to closure of the Pahala LCCs by April 2023.3
Though not required under NEPA, planning-level cost comparisons for the Pahala LCC
Replacement Project were summarized in the Preliminary Engineering Report (see Appendix B
of both the Draft EA and Final EA). The capital cost of an aerated lagoon/constructed wetland/land
application treatment and disposal facility is estimated at $16 million (plus $2 million for concrete
lagoon lining if required) and has an estimated annual operations and maintenance cost of
$227,000. The capital cost of closure of two community LCCs and a new collection system is
estimated at $14 million. These numbers represent a conceptual planning-level construction cost
estimate and do not include planning, design, land acquisition, or past project costs. Of the
treatment alternatives that were deemed feasible and compared in Appendix B, the proposed
wastewater treatment and disposal facility design has the lowest estimated capital cost and
estimated annual operations and maintenance cost. Thus, even if a cost-benefit analysis were
performed (which is not required under NEPA), it would likely support the Proposed Action.
Information on anticipated project costs has been added to the Final EA Section 2.1.2 (Project
Funding).
County Financial Capacity
Comment
• I am concerned about the impact of the Pahala project on the credit capacity of the county
of Hawai'i given the diminishing tax base. Why wasn't the financial standing and debt
burden of the county discussed in the DEA? (Comment 12)
• The Draft EA did not consider the economic impact of CWSRF loans on the County.
(Comment 23a)
• The Draft EA has no cost analysis for borrowing funds to pay for the Pahala project.
(Comment 27)
Response
The federal action triggering NEPA review of this project is the award of a federal earmark grant
(not a loan), which would not require repayment. The County has proposed to finance the
remainder of the project using funds from the Hawai'i Clean Water State Revolving Fund (SRF),
which provides low-interest loans for the construction of publicly owned wastewater treatment
2 While the above-cited regulation applies specifically to the preparation of an EIS, the rationale behind it
applies equally to the preparation of an EA.
3 In September 2019, EPA accepted the County's request to extend the Pahala LCC closure date from
June 2021 to April 2023.
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Final EA, Pahala LCC Replacement Project - Appendix E
Pahala, Ka'u District, Hawai'i
works. The SRF loan process is managed by the State of Hawai'i Department of Health and is
outside of the scope of this NEPA analysis.
Economic Impacts on the Community
Comment
• The Draft EA did not consider the economic impact of costs on Pahala households.
(Comment 23a)
• The costs of connecting newly accessible properties will fall on many elderly residents
with fixed incomes. (Comment 41)
• Pahala is an economically depressed community with a high percentage of people on
welfare, social security, pension, or other fixed income. How are they going to afford any
hook up fees, maintenance fees, or any other fees that will likely come with this wastewater
treatment plant? (Comment 56)
• The county or state needs to find alternate sources of funding to cover hook-up costs for
all lots within the planned project area. The expense of joining the new sewer system will
place a burden on the sensitive populations of Pahala. (Comment 73)
• The cost of connecting the "newly accessible lots" to the new system will have a
devastating financial impact on the community and could result in the loss of community
support for the project. (Comment 31)
• Why are some residents paying hookup fees and others are not? Should not discriminate.
(Comment 67)
• What is the cost to be on the county sewer? Residents who are not on the LCC will be
penalized with enormous fees, which is a large burden to older residents on fixed incomes.
(Comment 55)
• I am really upset that lots that were not hooked up to the C. Brewer system will have to
pay a lot of money to hook up to the new system. Many of these lots are owned by low
income or elderly people who cannot afford to hook up to the new system on their own.
(Comment 42)
• Including the whole community of Pahala in the new system places an unnecessary
financial burden on both the homeowners and the County. (Comment 61)
• I have no money to hook up to the sewage plant. (Comment 37)
• The community is being divided because the County is covering costs for certain houses
to be hooked up to the new system and requiring other homeowners to pay to hook up.
(Comment 42)
• The costs of the two Ka'u projects far exceeds the taxable value of the lots to be
disconnected from the LCCs. (Comment 65)
• Funding should be available for the entire project. Pahala is a poor and poverty district,
with 85% of residents retired or living on fixed incomes, limited employment opportunities.
(Comment 40)
Response
The purpose of the Proposed Action is to bring the County into compliance with the SDWA by
constructing an alternative means of wastewater disposal that would allow the County to close
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Pahala, Ka'u District, Hawai'i
the existing LCCs. NEPA does not require consideration of socioeconomic impacts that are
unrelated to an impact on the physical environment. See 40 CFR § 1508.14.
The Proposed Action is expected to result in the connection of 111 existing connected lots to the
new collection system and wastewater treatment and disposal facility. In addition, due to their
proximity to the new collection system, 65 to 66 additional lots would become accessible to the
sewer. Sewer laterals to the property line would be installed as a part of this project. Under the
Proposed Action, the design of the new collection system would include sewer service stub-outs
to the lot lines of adjacent properties, including the newly accessible, to accommodate their
eventual connection. Accordingly, to close the existing LCCs, there would be additional properties
in Pahala that would be required to connect to the new wastewater collection system, at their
expense, after it becomes operational. Such properties are near the existing service area but are
presently connected to individual wastewater systems. To conform to the HCC, the respective
newly-accessible property owners would be responsible for the design, permitting, and completion
of sewer service connections between the County stub-outs and improvements for stated uses
on their property, as well as for the proper closure of their individual wastewater systems. It is not
accurate that the whole community of Pahala would be included in the new sewer system.
The Draft EA Section 3.16 (Socioeconomic Characteristics) provided information regarding the
socioeconomic characteristics of the Pahala community in comparison to the County of Hawai'i.
The information for the 2012-2016 period shows the median age for Pahala is 42.4 years,
compared to 41.8 years for the County. By age group, Pahala shows a total of 65.7 percent less
than 60 years old, compared to 74.2 percent for the County. The median household income for
Pahala is $47,625, compared to $53,936 for the County. For Pahala, 85.1 percent of households
have an income less than $99,999, compared to 77.6 percent for the County. Overall, the
Proposed Action is expected to benefit residents by providing a cleaner and longer-lasting
wastewater treatment system. This information has been repeated and updated in the Final EA.
The Final EA Sections 3.16 (Socioeconomic Characteristics) and 5.7 (Environmental Justice
Executive Order 12898) have been updated to clarify that, despite the relatively high proportions
of low-income, minority, and children residents in Pahala compared to the County overall, the
Proposed Action would not result in disproportionately high and adverse human health or
environmental effects on these sensitive populations.
EPA acknowledges commenters' concerns over hook-up fees, maintenance fees, and other
potential fees. However, it is the responsibility of the County to determine how to finance their
portion of the Proposed Action. Additional research and outreach regarding financing options for
residents was provided by the County in response to comments from the community. On March
21, 2019, the County held a meeting in Pahala which included a presentation to provide
information on financing options available to residents whose lots would become accessible to
the new collection system. The purpose of the meeting was to fulfill a County commitment made
in October 2018 to research financing options available to the newly accessible residents of the
Pahala community by March 2019. This information has been included in the Final EA Section 7
(Public Participation).
Sources of Funding
Comment
• Did C Brewer give the County funding? (Comment 67)
• No consideration has been given of other funding types for the project. (Comment 23a)
• Should the County of Hawai'i fund the whole project, including hook ups? (Comment 67)
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Response
The Draft EA Section 2.1.2 (Project Funding) discussed the two funding sources that would be
used to support the Pahala LCC Replacement Project: an EPA Special Appropriations Act Project
(SAAP) grant and Clean Water State Revolving Funds. An EPA SAAP grant was awarded to the
County in 2005, and subsequently amended. The total amount of the award is $1.842 million.
The second source of funding for the project is the Hawai'i Clean Water State Revolving Fund.
The Hawai'i Clean Water State Revolving Fund receives annual funding from the EPA, which the
State of Hawai'i Department of Health is then responsible for allocating among eligible projects.
The Final EA Section 2.1.2 has been updated to include additional information about this source
of funds.
As stated previously, the proposed project is expected to result in some costs to owners of lots
that become accessible to the new wastewater collection system. A discussion of the County's
efforts to identify additional financing options for homeowners to pursue can be found in the
section above (Economic Impacts on the Community). The Final EA Section 3.16 (Socioeconomic
Characteristics) has been updated with this information.
Please refer to the Draft EA Section 2.1.4 (History of Wastewater Management in Pahala) for a
discussion of C. Brewer's involvement. Additional information has been added to the Final EA
Section 2.1.4 for clarity.
2.1.5 Archeological and Cultural Resources
Comment
• The proposed plant may be located in proximity to an archeological or burial site.
(Comment 33)
• There are burials and caves within the proximity of proposed site. Community members
have witnessed seeing the caves and burials. It was deemed a site not to be used by the
County back in 2008. (Comment 41)
• There are cultural and historic resources, including caves and bones, at the site.
(Comment 42)
• There are many caves and unrecorded burial sites in Pahala. There needs to be a
thorough EIS, and in-depth testing, not just surface testing that was done, to document
any archeological findings. (Comment 56)
• Lava tubes and burials were identified during previous development projects in Pahala.
No subsurface testing for these resources was completed on the site, and these areas
could be affected during development or flooding of the site. (Comment 67)
• Possible burial sites are suspected to be present on or near the site. (Comment 68)
• Concerned about use of the current site due to the presence of historically sensitive areas.
Elders should be consulted about these resources. (Comment 73)
• The location of the burial cave (believed to be in the southeastern corner of the site) should
be ascertained and this area protected. Once the location of the cave has been identified,
consultation with descendants, SHPD, and the Hawai'i Island Burial Council can be
completed to determine appropriate physical buffers for the facility. It is very important to
ascertain that the burial cave is located at a higher elevation than the proposed facility to
ensure that the cave is not subjected to contact with treated or untreated wastewater.
(Comment 74)
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Response
As discussed in the Draft EA Section 3.15.1(a) (Archeological and Cultural Resources - Existing
Conditions), after consultation with the State Historic Preservation Division (SHPD), the County
initiated an Archeological Inventory Survey (AIS) to "fully document, map, date and collect [any]
surface artifacts" located at the proposed site. An AIS plan was approved by the SHPD on August
20, 2018.
Since the publication of the Draft EA, the Draft AIS for the Pahala Wastewater Treatment Plant
and Sewer System Project was completed and submitted to the SHPD on March 11, 2019, for
review. The AIS was generated based on a literature review and research, pedestrian surveys,
and subsurface testing. The AIS report did not identify any pre-Contact features or lava tubes
within the project area. The AIS report referenced the findings of a November 2016 survey which
did identify a known lava tube access within former plantation land to the east of and outside of
the treatment and disposal facility project site, and just north of Mamalahoa Highway that has
been blocked. No impacts to this lava tube are expected since it is located outside of the treatment
and disposal facility project site. The Draft EA Section 2.3.1 (Acquire Site 7 and Construct New
Secondary Wastewater Treatment and Disposal Facility) stated the aerated lagoons would be
lined with high density polyethylene liners to prevent water seepage through the bottom and sides
of the lagoons. Thus, untreated wastewater would not enter the ground beneath the wastewater
treatment and disposal facility.
To determine the location of the lava tube that may be what is referenced by commenters, the
County sent a follow-up letter to Commenter 40, the Pele Defense Fund, requesting information
about the known lava tubes in the project area via email to the address from which the comment
was submitted and via certified mail on November 14, 2018 but received no response.
Overall, the AIS results supported a determination of "no historic properties affected" by the
proposed project. This information is updated in the Final EA Section 3.15 and the Draft AIS report
has been included as an Appendix to the Final EA.
Consultation regarding historic properties has been completed according to applicable laws and
regulations. The Draft AIS report was provided to SHPD in accordance with the requirements of
the National Historic Preservation Act (NHPA) and was made available to the public by the EPA
on June 5, 2019 through a publicly available web posting on the project page for the Pahala
project (see: https://www.epa.qov/uic/proposed-Pahala-communitv-larqe-capacitv-cesspool-
replacement-proiect-draft-environmental). In the AIS, the area of potential effect was determined
to be 57.7 acres and includes the following:
1. The 14.9-acre wastewater treatment plant (WWTP) site, within which all project-related
staging, including for the collection system and the treatment and disposal facility, will be
located;
2. An approximately 1,500-foot (ft) long by 25-ft wide utility easement (about 0.94 acres)
located entirely within Tax Map Key (TMK) [3] 9- 6-002:018 to connect the collection
system line and other utilities to the WWTP;
3. The path of the new sewer collection lines, to be located within the 22- to 24-ft wide travel
surface of select county streets;
4. Sewer line easements of similar width (22-24 ft) through TMKs [3] 9-6-005:036 and 044
connecting the collection lines to the proposed Pahala WWTP site;
5. The existing LCC 1 and 2 locales (located in TMKs [3] 9-6-002:016 and 9-6-016:041,
respectively), and an approximately 100-m (328-ft) long by 15-m (49-ft) wide corridor along
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the existing sewer line easement in TMK [3] 9-6-002:016 between Maile Street and LCC
1; and
6. Numerous single-family residential/other properties with existing sewer laterals, some of
which may need to be replaced/repaired/rehabilitated by the County.
In accordance with the NHPA (36 CFR § 800.4(d)), EPA reached a finding of no historic properties
affected for this undertaking and requested SHPD concurrence with this determination on
September 26, 2019. No response from SHPD has been provided to date. In accordance with 36
CFR § 800.4(d)(1)(i) and as specified in the September 26 letter, because no response was
received within 30 days of SHPD receipt of the adequately documented finding, EPA has fulfilled
their Section 106 responsibilities for this undertaking. However, construction would not proceed
until SHPD has approved the Draft AIS.
Though pedestrian surveys were conducted throughout the APE to identify potential lava tubes
and none were visually observed at the site, the AIS was not able to conclusively establish that
lava tubes are not present within the area surveyed as part of the AIS. Therefore, in addition to
the field methodology presented in the AIS, and to limit ground disturbance, the County is in the
process of performing Ground Penetrating Radar and soil resistivity surveys as part of the project
design phase, and would adjust the final design of the Proposed Action as needed to mitigate
impacts to any potential lava tubes identified as a result of these surveys. The discussion in the
Final EA Section 3.3 (Geology) has been updated to reflect this.
The Hawai'i Island Burial Council was consulted as part of the Draft EA preparation process. As
stated in the Draft EA Section 3.15 (Archeological and Cultural Resources), on March 29, 2018,
the County also conducted outreach to Native Hawaiian Organizations as part of the Section 106
consultation for this project. Consultation letters were delivered to invite comments from
organizations that may attach religious or cultural significance to properties affected by the
Proposed Action. A total of 14 letters were mailed to various Native Hawaiian Organizations
requesting comments (see the Draft EA Section 10); no responses have been submitted to the
County. In addition, outreach for the Draft EA included talk story sessions that were open to all
members of the public, including elders.
On September 26, 2018, a public notice was published in the Hawaii Tribune Herald and West
Hawaii Today newspapers to advertise that on October 10, 2018, a public information meeting
was to be conducted by the County in Pahala at the Ka'u Gym Multi-Purpose Conference Room
to discuss the Draft EA and that a second part of the meeting would also address Section 106 of
NHPA. Although eight persons signed in to comment on Section 106, no comments or information
were forthcoming regrading Section 106 during the October 10th meeting. This information is
included in the Final EA Section 7 (Public Participation) and Section 3.15.
It is not true that the site of the Preferred Alternative (Site 7) was "deemed a site not to be used
by the County back in 2008." It appears that the commenter is referring to the 2007 Na'alehu and
Pahala LCC Conversion project Final EA (the "2007 Final EA"), which evaluated a proposed
project to install septic tanks to replace the existing LCCs. The 2007 Final EA did not evaluate
Site 7 as an alternative location for the septic tank project and did not identify it as a site "not to
be used by the County."
2.1.6 Air Quality
Comment
• Residents of Pahala have a high rate of asthma and studies have shown that there are
negative impacts on residents who live next to a sewage plant. Not only do we have the
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chemicals left in the ground by C, Brewer, we have the dust and chemicals from the
Macadamia Nut Co. and the vog from Tutu Pele. (Comment 41)
• The smell of the facility is a concern. (Comments 33, 56, 67, 68)
• The treatment plant could cause an increase in harmful airborne bacteria. (Comment 67)
Response
Odor and smell impacts were addressed in the Draft EA Section 3.14.2(a) (Air Quality - Impacts
and Mitigation Measures) which stated "to mitigate potential nuisance odors, the headworks [of
the wastewater treatment and disposal facility] would be equipped with an odor control system
with a GAC scrubber to remove odor [...] the treatment lagoons would be equipped with
mechanical aerators capable of maintaining sufficiently aerobic (with oxygen) conditions within
the water column, which would prevent nuisance odor conditions from occurring" under normal
operating conditions. This information has been repeated in the Final EA.
For other air quality impacts, the design and operation characteristics of the new wastewater
treatment and disposal facility would limit pathways for off-site migration of aerosols. As stated in
the Draft EA Section 2.3.1 (Acquire Site 7 and Construct New Secondary Wastewater Treatment
and Disposal Facility), the lagoons would be equipped with high-speed floating aerators. The plant
design would not result in migration of aerosols outside of the site boundaries. The land
application system would use a piping system with slots at ground level to distribute treated and
disinfected wastewater; because this process distributes disinfected water and does not create
an aerosol, risk of exposure to pathogens through inhalation is minimal.
Furthermore, the wastewater treatment and disposal facility would be located at least 0.5 miles
away from the developed area of the community, which provides a buffer to mitigate potential
concerns associated with nuisance odors or aerosol migration that could arise outside of normal
operating conditions.
2.1.7 Other Impacts
Comment
• Is this project going to affect the whole community? (Comment 62)
• Will outside community waste be transported into Pahala? (Comment 67)
Response
In the Pahala community, between 176 and 177 lots would be affected directly by the new
collection system of the Proposed Action (111 lots on the existing LCC system and 65 to 66 newly
accessible lots). This information has been revised in the Final EA Section 2.3.2 (Construct New
Wastewater Collection System). The collection system and the treatment and disposal facility are
to serve only the Pahala community.
Comment
• The sewer will attract pests. (Comment 67)
Response
The existing wastewater collection system is an aging system that has flaws and cracks that can
provide access to pests such as rats and cockroaches. When the new collection system is
installed, the existing system would be abandoned, and the subsequent lack of use would reduce
available habitat and pest food sources. The new collection system would be more resistant to
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Pahala, Ka'u District, Hawai'i
developing cracks and openings, resulting in fewer opportunities for pests to access the sewer as
compared to existing system.
Closure and abandonment of the existing LCCs would eliminate potential pest attractants. In
addition, the wastewater treatment and disposal facility would be located farther from the Pahala
community than the existing LCCs, thus conveying sewage to a facility that would incorporate
design elements and operation practices to reduce attractiveness to pests. These design
elements and operation practices would include features such as appropriate removal and
management of waste from screening mechanisms to reduce food sources; use of aerators in
lagoons to agitate water sources that otherwise could attract mosquitoes; and intermittent dosing
of effluent to avoid standing water in groves. The Proposed Action would not be expected to
contribute to pest-related concerns in Pahala. This information is included in the Final EA Section
3.13 (Fauna).
Comment
• The current site location causes concerns about impacts in the event of a natural disaster.
Topics to be addressed include developing a hazard plan, response to fires and spills
resulting from pump failure, and assuring sources of power and water at the site.
(Comment 67)
Response
As stated in the Draft EA Section 3.4 (Seismic Hazard), the wastewater treatment and disposal
facility would be designed and constructed to meet the requirements of the International Building
Code, 2006 Edition (IBC) as specified in HCC Chapter 5 and would comply with seismic loadings
established for the County of Hawai'i. This would minimize the potential for an uncontrolled
release of untreated or partially treated sanitary wastewater, emergency generator diesel fuel, or
disinfection chemicals from the facility during a seismic event. Hazards related to hurricanes, such
as wind, rain, and flood loads, would be taken into account during detailed design. In addition, the
treatment processes would be appropriately designed to have capacity to accommodate upset
conditions, including pump and other equipment failures by use of back-up generator for power
as described below, alarm conditions for operators and a communication system.
Information pertaining to fire systems, water supply, and electrical systems is located in the Final
EA Sections 3.21 (Public Services - Fire Protection), 3.22 (Infrastructure - Water System), and
3.24 (Infrastructure - Electrical and Communication Systems), respectively. As explained there,
fire protection and related services would be provided to the treatment facility from a fire station
located in Pahala, and the treatment and disposal facility would include a fire protection line sized
as required during design to be used in the event of a fire. Department of Water Supply and the
Fire Department would have an opportunity to review construction plans for the Proposed Action
during the project design phase. All alternatives would be designed according to NFPA 820
"Standard for Fire Protection in Wastewater Treatment and Collection Facilities." In accordance
with Hawai'i Fire Department requirements, Fire Department access and water supply to the
proposed Site 7 would be designed to comply with Chapter 18 of NFPA 2006 Uniform Fire Code
as amended by the County of Hawai'i. This information is included in the Final EA Sections 2.3.1
(Acquire Site 7 and Construct New Secondary Wastewater Treatment and Disposal Facility) and
3.22.
Water service does not currently exist at Site 7. Water for the proposed wastewater treatment and
disposal facility would be provided by extending the existing water main operated by the County
of Hawai'i DWS (located approximately 2,000 feet northeast of the proposed wastewater
treatment and disposal facility) and by installing a service line to connect the new facility to that
extended water main. The proposed site (Site 7) was deemed preferable to two other sites
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Pahala, Ka'u District, Hawai'i
considered (Sites 8 and 9) because, among other reasons, potable water and fire protection lines
would need to be extended further to reach the latter two sites. Operation of the sewer system
would not require a water source external to the proposed treatment and disposal facility. As
stated in the Draft EA Section 3.22.2, construction plans would show the estimated maximum
daily water usage calculations prepared by a professional engineer licensed in the State of
Hawai'i. After review of the calculations, DWS would determine if enough water is available and
a water commitment could be issued.
It is anticipated that electrical power would be provided by Hawai'i Electric and Light Company
(HELCO) overhead power lines and a pole-mounted transformer. Backup power would be
provided by a diesel generator and aboveground fuel tank with capacity to support three
consecutive days of operation. In addition, the electrical service panel would support a connection
to a portable trailer-mounted generator in the event of a power outage lasting longer than three
days. This information has been repeated in the Final EA Section 3.24.
2.2 NEPA Processes
Responses to comments regarding the federal NEPA process for the Proposed Action have been
arranged into the following categories:
• Purpose and Need
• Scope of Proposed Action
• Cumulative Effects
• Federal and State Consultations
• NEPA Procedures
2.2.1 Purpose and Need
Comment
• Why does the small community of Pahala need a wastewater treatment plant (WWTP)
when other communities have larger populations and are growing in size? (Comment 56)
• Why was the Pahala community chosen to have the cesspool conversion done by 2021
when the rest of the state has until 2050? (Comment 67)
• If this is truly a means for Hawai'i County to avoid fines from the federal government for
the LCC violations, then that is what the focus of the proposal should be about. (Comment
61)
Response
As described in the Draft EA Section 2.1.3 (Large Capacity Cesspools), the two cesspools serving
Pahala community meet the criteria of being LCCs under federal law since they each serve
multiple dwellings. These LCCs are in violation of the SDWA as long as they continue to operate.
The SDWA Underground Injection Control (UIC) Program prohibited the construction of new
LCCs as of April 2000 and required the closure of all existing LCCs by April 5, 2005 (see 40 CFR
§ 144.88). In order to close the LCCs serving the Pahala community and comply with federal law,
the County needs to develop an alternate means of wastewater treatment for those homes and
buildings that are currently connected to the LCCs.
It is not true that the rest of the state has until 2050 to close LCCs—all LCCs across the nation,
including those in the Pahala community, were required under federal law to be closed by 2005.
In referencing 2050, it appears that the commenter is referring to a Hawai'i state law that was
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passed in 2017 that requires the closure of all cesspools (LCCs and small capacity cesspools) by
2050. Unlike LCCs, which serve multiple dwellings and/or have the capacity to serve 20 persons
or more per day, small capacity cesspools typically serve individual homes and are not regulated
under federal law. This information has been clarified in the Final EA Section 2.1.3.
EPA and the County entered into an AOC in June 2017 since the County continued to operate
the Pahala LCCs after the 2005 closure deadline and after assuming ownership of the system
from C. Brewer in 2010. This Administrative Order included an enforceable schedule for the
County to close the Pahala LCCs in order to bring the County into compliance with federal law.
Because the LCCs cannot be closed until an alternate means of wastewater disposal is
constructed, the schedule for closure of the LCCs included in the Administrative Order was
developed based on the County's estimate of the amount of time required to design and build a
replacement means of wastewater disposal.
After careful review of different alternatives for wastewater treatment and disposal (see Section
2.5.4 (Treatment Alternatives) of this Appendix and the Final EA Section 2.8 (Alternatives
Considered but Not Carried Forward)), the County identified the most appropriate solution given
the community requirements as well as applicable Federal, State, and County regulations
governing wastewater disposal systems. The wastewater treatment and disposal facility would be
sized appropriately for the Pahala community, based on the number of lots that would be
connected to the new facility through the Proposed Action (anticipated to be approximately 176
to 177 lots), and wastewater flow projections for these lots, as determined by code. The size is
also determined by the use and zoning of the lots and includes a standard allowance for industrial
lots. For more information on the sizing of the proposed wastewater treatment and disposal
facility, see Section 2.4.3 (Hawai'i Department of Business, Economic Development and Tourism,
Land Use Commission (LUC)) of this Appendix.
Comment
• There is no data to prove Pahala community at status quo shows an impact in ground
water contamination. (Comment 67)
Response
The purpose of, and need for, the project is to close the LCCs serving the Pahala community in
order to bring the County into compliance with federal law, and to prevent potential impacts to
public health and the environment that may be caused by discharging untreated sewage into the
ground in a residential neighborhood. Regulations promulgated under the SDWA required the
closure of all LCCs nationwide by no later than April 2005. There is no requirement under these
regulations to show actual impacts to groundwater. This is because the SDWA is designed to
prevent endangerment of drinking water before it occurs—thus, to comply with the SDWA, the
regulations require closure of all LCCs. The Draft EA Section 3.8.2 (Ground Water - Impacts and
Mitigation Measures) stated that while use of the two LCCs has not resulted in documented
impacts to groundwater or drinking water resources, abandonment of the LCCs would remove a
potential source of such impacts and bring the facility into compliance with the SDWA.
Abandonment of the existing wastewater collection system would not affect groundwater within
the affected areas. This information is repeated in the Final EA Section 3.8.2.
2.2.2 Scope of the Proposed Action
Comment
• The failure to consider aggregated and cumulative effects of the Pahala and Na'alehu
projects is legally unacceptable. These two projects should be analyzed in a single impact
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statement because of the connected nature and possible cumulative impacts of the
projects. (Comment 4)
• The Pahala and Na'alehu projects should be considered together. (Comment 16)
• The Pahala and Na'alehu projects were separated to evade NEPA review. The Pahala
project is violating NEPA procedural requirements. (Comment 23a)
• NHPA Section 106 consultation should have been conducted for both the Pahala and
Na'alehu projects together. (Comment 65)
• Demoruelle v. Beck evidence of misconduct in following NEPA/HEPA. (Comment 75)
Response
NEPA defines actions as connected if they satisfy any of the following criteria:
i. Automatically trigger other actions which may require environmental impact statements
(EISs).
ii. Cannot or will not proceed unless other actions are taken previously or simultaneously.
iii. Are interdependent parts of a larger action and depend on the larger action for their
justification. [40 CFR § 1508.25]
The proposed Pahala LCC Replacement Project does not meet any of the above criteria. The
proposed Pahala LCC Replacement Project does not automatically trigger other actions which
may require an EIS and is a stand-alone project which does not rely or depend on any other
project. Therefore, the proposed Pahala LCC Replacement Project is not considered connected
to the Na'alehu Large Capacity Cesspools Closure Project (Na'alehu Project) for purposes of
NEPA.
As stated in the Final EA Section 2.9 (Relationship to 2007 Final Environmental Assessment), in
2007 the County elected to evaluate the two projects in a single environmental review document
under HRS 343 because at that time, both projects were expected to proceed along the same
timeline and both were expected to be funded under the EPA SAAP grant. The County decided
to not move forward with the proposed project as evaluated under that process for several reasons
which are also described in the Draft EA Section 2.9.
Since then, the grant workplan for the EPA SAAP grant has been amended to include only the
Pahala community - LCCs Replacement Project. This decision was made based on two points:
1) the federal grant funds would only cover a portion of one of the projects and 2) it was expected
that the Pahala LCC Replacement Project could be completed faster than the Na'alehu Project,
and there was therefore a lesser likelihood that funds associated with the grant would be de-
obligated before they could be spent. Consequently, the Na'alehu Project will not receive any
funding under the EPA SAAP grant.4
The funding of the Pahala LCC Replacement Project under the SAAP grant is considered a
federal action that requires environmental review under NEPA. Because funding from the EPA
SAAP grant is allocated to the Pahala LCC Replacement Project, and because the Na'alehu
Project is not a connected action, it is not appropriate to include the Na'alehu Project as part of
the Proposed Action examined in the Pahala LCC Replacement Project EA. The EPA did consider
the potential cumulative effects of other past, present, and reasonably foreseeable actions
4 In 2011, EPA reimbursed the County for approximately $113,000 for preliminary designs for the
Na'alehu Project. The Na'alehu Project will be completed with County and State funds and will not receive
any additional EPA SAAP grant funds.
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Pahala, Ka'u District, Hawai'i
(including the Na'alehu Project) as required by NEPA in the Draft EA Section 4 (Cumulative
Effects) and additional information is included in Section 2.2.3 (Cumulative Effects) of this
Appendix.
The two projects are also considered separate for purposes of the National Historic Preservation
Act (NHPA). Section 106 of the NHPA requires federal agencies to take into account the effects
of federal undertakings on historic properties (see 40 CFR § 800.1(a)). Specifically, agency
officials must assess whether historic properties occur within the "area of potential effect" for the
project, and if so, whether they would be impacted by the project. NHPA regulations provide that
agency officials should engage in consultation with the appropriate state historic preservation
officer and consulting parties in order to determine whether the proposed project is expected to
result in impacts to historic properties.
EPA and the County engaged in the NHPA Section 106 consultation process for the Pahala LCC
Replacement Project and determined the area of potential effect for the project did not extend
outside the Pahala area as described in Section 2.1.5 (Archeological and Cultural Resources) of
this Appendix. Because Na'alehu is located 11 miles from Pahala and is well outside of any area
expected to be affected by the Pahala LCC Replacement Project, the Na'alehu Project was not
considered as part of the Pahala LCC Replacement Project Section 106 consultation process.
The Final EA Section 3.15 (Archeological and Cultural Resources) has been updated with
additional information regarding the NHPA Section 106 Consultation process.
In accordance with state requirements, the Na'alehu Project would undergo a similar consultation
process to assess potential impacts on historic properties as part of the separate environmental
review for that project.
2.2.3 Cumulative Effects
Comment
• The project is evading NEPA requirements by not considering the cumulative impacts
(including economic impacts on county with decreasing tax base) of both the Pahala and
Na'alehu projects. (Comment 1)
• The project is evading NEPA and crosscutting environmental review requirements by not
considering the cumulative impact of both the Pahala and Na'alehu projects. (Comment
2)
• The failure to consider aggregated and cumulative effects of the Pahala and Na'alehu
projects is legally unacceptable. These two projects should be analyzed in a single impact
statement because of the connected nature and possible cumulative impacts of the
projects. (Comment 4)
• The Pahala and Na'alehu projects should be considered together. (Comment 16)
• The cumulative impacts of the Pahala and Na'alehu projects need to be considered
together in one EIS. (Comment 23a)
• The cumulative impacts of the Pahala and Na'alehu WWTPs need to be considered.
(Comment 27)
• The County and EPA have avoided consideration of the impacts of the Na'alehu Project
on the Pahala WWTP. (Comment 43)
February 2020
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Final EA, Pahala LCC Replacement Project - Appendix E
Pahala, Ka'u District, Hawai'i
Response
The community of Na'alehu is located approximately 11 miles from Pahala. As stated in the Draft
EA Section 4 (Cumulative Effects), "due to its distance from Pahala, the effects of [the Na'alehu
Project] are not expected to have a significant cause-and-effect relationship with the direct and
indirect effects of the Proposed Action." The Na'alehu Project is undergoing separate community
outreach and environmental review processes that have not yet been completed and therefore
very little information regarding the impacts of that project is publicly available. However,
information has been added to the Final EA Section 4 relating to the potential for cumulative
effects between this project and similar construction projects within the Ka'u district. Please refer
to Section 2.2.5 (NEPA Procedures) of this Appendix for a discussion of why an EA was prepared
rather than an EIS for the Proposed Action. The Na'alehu Project is not the subject of this EA.
2.2.4 Federal and State Consultations
Section 7, Endangered Species Act (ESA)
Comment
• EPA has failed to comply with the Endangered Species Act (subject of attached legal
documents). (Comment 4)
• The Project is in violation of the ESA and is causing concrete harm to the citizens of
Hawai'i. (Comment 14)
• The Project is in violation of environmental statutes and regulations including the
Endangered Species Act. (Comment 14)
• COHDEM and its contractors are avoiding Section 7 consultation under the ESA for the
Pahala project. (Comment 57)
Response
The EPA has fulfilled its consultation requirements under Section 7 of the Endangered Species
Act. A biological field survey was performed in August 2018 for the proposed wastewater
collection system and the preferred site (Site 7) for the wastewater treatment and disposal facility.
The field study did not identify any species of plants or wildlife that are currently listed or proposed
for listing as threatened or endangered species under Federal or State of Hawai'i laws, and
determined that Federally delineated Critical Habitat is not present in the Pahala area. EPA
initiated informal consultation with the U.S. Fish and Wildlife Service (USFWS) by letter dated
December 21, 2018. The EPA received concurrence from the USFWS on February 15, 2019 that
the project is not likely to adversely affect federally listed threatened or endangered species. A
full discussion of the Section 7 consultation efforts and actions is included in the Final EA Sections
3.12 (Flora), 3.13 (Fauna), and 5.6 (Endangered Species Act).
Section 106, National Historic Preservation Act (NHPA)
Comment
• The NHPA Section 106 consultation for the Pahala project is not valid because the
Na'alehu project was not also considered. The consultation was also done hastily and
without proper publication of notice. (Comment 65)
• The federal Section 106 and the Cultural Assessment of the Draft EA are inadequate.
(Comment 40)
• Local Hawaiian groups and individuals were not pre-consulted before the Section 106.
(Comment 65)
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Final EA, Pahala LCC Replacement Project - Appendix E
Pahala, Ka'u District, Hawai'i
• EPA failed to reach out to local Hawaiian organizations. The following should be consulted
(list of suggested affected organizations attached). (Comment 7)
Response
On March 8, 2018, the EPA notified all Native Hawaiian Organizations (NHOs) in the Pahala area
that the County had been authorized to act in EPA's behalf when initiating consultation under 54
U.S.C. § 300101 and 36 CFR §800.2(c)4 for the Pahala Large Capacity Cesspool Replacement
Project. The County conducted consultation outreach to NHOs by directly contacting the federally
recognized Native Hawaiian organizations listed in the Draft EA Section 10 (Consulted Parties).
As stated in the Draft EA Section 3.15 (Archeological and Cultural Resources), consultation letters
were delivered to invite comments from organizations that may attach religious or cultural
significance to properties affected by the Proposed Action. The selection of NHOs for this
outreach was developed using the U.S. Department of the Interior, Office of Native Hawaiian
Relations, Native Hawaiian Organization Notification List (Updated December 4, 2017). Letters
requesting comments under Section 106 Consultation (54 U.S.C. § 32706) were sent to a total of
14 NHOs on March 29, 2018. No responses were submitted to the County.
On September 26, 2018, a public notice was published in the Hawaii Tribune Herald and West
Hawaii Today newspapers. The public notice was to advertise the October 10, 2018 public
information meeting that was to be conducted by the County in Pahala at the Ka'u Gym Multi-
purpose Conference Room to discuss the Draft EA. The notice stated the second part of the
meeting would address Section 106 of the National Historic Preservation Act of 1966, as amended
(2006). It was meant to involve consultation with NHOs and the Native Hawaiian descendants
with ancestral lineal or cultural ties to, cultural knowledge or concerns for, and cultural religious
attachment to the proposed project area. A Section 106 sign-in sheet was provided to those
wishing to provide comments. No comments were made during the October 10, 2018 public
information meeting. This information is added to the Final EA Section 7 (Public Participation).
As explained in the Final EA, EPA has concluded Section 106 consultation with a determination
of "no historic properties affected" by the Preferred Alternative. This information is updated in the
Final EA Sections 3.15 and 5.14 (National Historic Preservation Act).
The area of potential effect for the Pahala LCC Replacement Project does not extend to Na'alehu,
which is approximately 11 miles from Pahala, meaning that there is no potential for the Pahala
LCC Replacement Project to impact historic properties in Na'alehu. The Na'alehu Project would
go through a separate consultation process for historic properties in accordance with state
requirements. Additional explanation for why these projects are considered separately is included
in Section 2.2.2 (Scope of the Proposed Action) of this Appendix.
Please see Section 2.1.5 (Archeological and Cultural Resources) of this Appendix for further
details on the Section 106 consultation for the Pahala LCC Replacement Project. The Final EA
Sections 3.15 and 5.14 have been updated to include additional information on the NHPA Section
106 Consultation process.
Other Agency Coordination
Comment
• The Hawai'i Department of Education (HIDOE) requests consultation and coordination
with the Facilities Development Branch, Public Works as early as possible to ensure a
timely connection to the new collection system and closure of the on-site septic system.
(Comment 72)
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Final EA, Pahala LCC Replacement Project - Appendix E
Pahala, Ka'u District, Hawai'i
• The HI DOE requests consultation and coordination with the school and the HI DOE
Transportation Services Branch Manager to minimize construction and traffic impacts to
the school such as noise, fugitive dust and HI DOE transportation of students. (Comment
72)
Response
The Ka'u High and Pahala Elementary School, including the Ka'u District Gym and Shelter,
would become accessible to the proposed County sewer system with the installation of two new
laterals at the property line on Hala Street and Kamani Street. While typically only a single
lateral is provided for a lot, the additional lateral on Hala Street is being installed to
accommodate the project and create a gravity flow connection. This information is included in the
Final EA Section 2.3.2 (Construct New Wastewater Collection System). Impacts and mitigation
measures for addressing construction-related dust, traffic, and noise are addressed in the Draft
EA Sections 3.14 (Air Quality), 3.17 (Traffic), and 3.18 (Noise). The County would provide
information about the construction schedule for the treatment and disposal facility and the
collection system to the Facilities Development Branch Public Works Administrator on request.
Further, the County would coordinate with the HIDOE Student Transportation Services Branch
Manager and the School in order to minimize construction-related impacts to student
transportation services. Please refer to the County response to Comment 72 for further
information.
Comment
• I request consulting party status under NEPA and Hawai'i Environmental Policy Act
(HEPA) and all cross-cutting statutes. (Comment 4)
• I was not allowed to be a consulting party. I could have advised EPA and COH on proper
procedures, but was never asked for my opinion or assistance. (Comment 65)
Response
A "consulting party" is a defined term specific to the NHPA that does not otherwise have meaning
under NEPA. On October 19, 2018, EPA sent a letter to the commenter (Comment 4) indicating
that, based on the information provided, the commenter did not meet the criteria for a consulting
party under the NHPA. In addition, HRS 343 and HAR 11-200 have no requirements or definitions
related to consulted party status for an EA.
All interested members of the public were invited to provide comments on the Draft EA and to
attend the public information meeting on October 10, 2018. The public information meeting was
conducted by the County in Pahala at the Ka'u Gym Multi-Purpose Conference Room to discuss
the Draft EA. This was immediately followed by a second meeting addressing Section 106 of the
NHPA. A Section 106 sign-in sheet was provided to those wishing to provide comments.
2.2.5 NEPA Procedures
Comment
• The two Ka'u WWTP projects are proceeding in violation of NEPA and HEPA. No EIS has
been prepared or submitted for publication, and statutory and regulatory procedures for
public participation have not been followed. (Subject of forwarded legal documents)
(Comment 16)
• All wastewater systems with treatment units in Hawai'i have had an EIS. The Pahala
project is intentionally evading this process. (Comments 15, 18, 53)
• A combined EIS for the Ka'u LCC Closure Project should be provided. (Comment 38)
February 2020
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Pahala, Ka'u District, Hawai'i
Response
EPA determined that an EA is the appropriate evaluation for the proposed Pahala LCC
Replacement Project because this federal action is not expected to significantly affect the quality
of the human environment within the meaning of NEPA. It is not accurate that an EIS is prepared
for all wastewater systems or wastewater treatment units in Hawai'i. As described in EPA NEPA
implementing regulations, types of actions that normally require the preparation of an EA include
"certain grants awarded for special projects authorized by Congress through the Agency's annual
Appropriations Act." See 40 CFR § 6.205(b). An EIS, on the other hand, is normally prepared for
new regional wastewater treatment facilities or water supply systems for a community with a
population greater than 100,000 (See 40 CFR § 6.207). As stated in the Draft EA Table 3.1, the
total population of Pahala is 1,341. The Pahala LCC Replacement Project does meet the definition
of a project normally requiring preparation of an EA and does not meet the definition for a project
normally requiring preparation of an EIS.
Moreover, as described in the Draft EA and the Preliminary Finding of No Significant Impact
(FONSI), the Pahala LCC Replacement Project is not expected to significantly affect the quality
of the human environment. As such, an EA is the appropriate vehicle for environmental review of
this project, and no EIS is required.
Additional information concerning applicable public outreach requirements and EPA and County
compliance with such requirements is available in Section 2.3.1 (Outreach) of this Appendix, and
in Final EA Section 7 (Public Participation). Information concerning the separation of the Na'alehu
Project and Pahala LCC Replacement Projects can be found in Section 2.2.2 (Scope of the
Proposed Action) of this Appendix.
HRS § 343-5(a)(9)(A) states that "(a) Except as otherwise provided, an environmental
assessment shall be required for actions that: (9) Propose any: (A) Wastewater treatment unit,
except an individual wastewater system or a wastewater treatment unit serving fewer than fifty
single-family dwellings or the equivalent..." For further discussion on the appropriateness of an
EA for purposes of HRS 343, please refer to the County response to Comment 15.
Comment
• The EPA and County are making an "irrevocable commitment of resources" to build the
Pahala and Na'alehu plants. (Comment 23a)
• The project has taken "irrevocable siting action" before the environmental review is
complete. (Comment 23a)
• The two WWTP projects in Ka'u are costing Hawai'i taxpayers at least $23,340,000
because the meter is now running and COHDEM has their contracts already in place.
(Comment 52)
Response
Neither EPA nor the County has made an irrevocable commitment of resources to the Pahala
LCC Replacement Project other than those required for planning and review of the project. As
explained in both the Draft and Final EA, multiple sites and treatment technologies were evaluated
for the Proposed Action, and a secondary wastewater treatment and land disposal system was
deemed to satisfy the purpose and need for the Proposed Action (i.e., to close the LCCs in
compliance with the SDWA by providing an alternate means of wastewater disposal). A
Preliminary Engineering Report was prepared in order to facilitate both a comparison of different
wastewater treatment systems and a discussion of site selection considerations. Property has not
yet been acquired for the project, however, and final design of the facility has not been completed.
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Pahala, Ka'u District, Hawai'i
As such, there has been no irrevocable siting action or commitment of resources associated with
the project.
Additional information on the County's commitment of resources to this project is included in the
County response to Comment 23a.
2.3 Public Involvement and Outreach
Responses to comments regarding public involvement and outreach have been arranged into the
following categories:
• Outreach
• Accessing the Draft EA
• Public Information Meeting Comments
• Na'alehu - Pahala Large Capacity Cesspool (LCC) Conversion Project - 2007 Final EA
Comments
• Public Agencies
2.3.1 Outreach
Comment
• The community is concerned about the condemnation of property. (Comment 67)
Response
The Preferred Alternative wastewater treatment and disposal facility site (Site 7) is currently
owned by B. P. Bishop Estate Trustees (commonly known as Kamehameha Schools).
Kamehameha Schools has agreed to transfer a portion of the property for the purpose of building
the wastewater treatment and disposal facility, and legally it can transfer the property to the
County through a condemnation proceeding. Thus, while the Preferred Alternative would involve
condemnation of property, it would only be used to acquire Site 7. The County intends to purchase
easements necessary to close the LCCs and construct the collection system. Apart from this
specific property, the Preferred Alternative is not anticipated to result in the condemnation of
additional private property.
Comment
• The COHDEM refuses to provide Pahala meeting records (attendees, agenda, outcomes)
or Pahala environmental review records (except the PER and Draft EA) to the local
libraries or online. (Comment 23a)
Response
EPA has fulfilled NEPA requirements for outreach and document availability/review by making
the Draft EA available to the public for review and comment. The Draft EA Section 7 (Public
Participation) included summaries of the talk story sessions and outcomes of these meetings. In
addition, though not required to do so, EPA has made key documents related to the project
continuously available through its website (https://www.epa.aov/uic/proposed~pahala~communitv~
larae-capacitv-cesspool-replacement-proiect-draft-environmental). Furthermore, there is no
requirement to publish notices of public meetings in the Office of Environmental Quality Control
(OEQC) The Environmental Notice. OEQC may publish such notices on a space available basis.
Finally, all project-related documents that have been released to any person under the Freedom
of Information Act (FOIA) are available through the centralized FOIA Online system.
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Final EA, Pahala LCC Replacement Project - Appendix E
Pahala, Ka'u District, Hawai'i
Comment
• Resident Edward Andrade should have been consulted as he was the manager of the C.
Brewer Sewage system for years. (Comment 41)
Response
All members of the Pahala community were welcome to attend the five talk story sessions held in
December 2017 prior to the release of the Draft EA; to provide comments on the Draft EA; and to
attend the October 10, 2018 public information meeting after the release of the Draft EA
concerning the project. As a member of the public, Mr. Andrade has provided comments on the
Draft EA which are addressed in this Appendix.
Comment
• The entire town was not notified about the three information meetings. (Comment 33)
• There was no disclosure of the proposed project to the residents of Pahala. (Comment
40)
• There was no disclosure or consultation with the residents of Pahala. Poor communication
resulted in low turnout for all the meetings. (Comment 41)
• I own property in Pahala, but do not reside there, and would like to be kept informed about
the Project. (Comment 59)
• The county is fast tracking the project without input from the community. (Comment 41)
• Communication with residents was not done properly and with respect, so not everyone
was informed about meetings. A lot of older people do not understand what is going on.
(Comment 42)
• The County failed to thoroughly inform all Pahala residents who will be affected by this
system. (Comment 55)
• The community needs more information about the project. Information was presented
poorly in the community meetings. (Comment 63)
• More input by the county on how this project is going to be handled fairly to benefit the
community. (Comment 63)
• The Pahala DEA notice failed to include the true purpose of project, which is to place a
secondary sewage treatment plant with four open sewage lagoons in remote Ka'u.
(Comment 53)
• Residents were not given sufficient time to address concerns about the EA. (Comment
40)
Response
NEPA requires agencies to use "appropriate communication procedures to ensure meaningful
public participation throughout the NEPA process," and to "make reasonable efforts to involve
potentially affected communities where the proposed action is expected to have environmental
impacts." See 40 CFR § 6.203(a)(5). For an EA, EPA's NEPA regulations require that the EA and
Preliminary FONSI be made available for review and comment at least thirty calendar days before
making a decision on whether, and how, to proceed with a proposed action.
As described below, EPA has complied with these public participation requirements and
guidelines throughout the scoping process and development of the Draft EA and Final EA. The
February 2020 25
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Pahala, Ka'u District, Hawai'i
Draft EA Section 7 (Public Participation) identifies the community public outreach efforts the
County conducted to solicit input while preparing the Draft EA. Prior to the issuance of the Draft
EA, the County held five talk story sessions in December 2017 to solicit community input on
reactions and perceived effects of the proposed project. Notice about the talk stories was provided
to the Pahala community through several means: direct mailing to properties currently connected
to the LCCs, fliers were left at properties which are not currently connected to the LCCs but would
have access to the proposed sewer ('newly accessible properties'), fliers were provided to
organizational leaders and posted in public venues in Pahala, and several online announcements
were made.
After collecting information on the anticipated scope and impacts of the proposed project, a Draft
EA was prepared and published in The Environmental Notice issued by OEQC on September 23,
2018. The Draft EA was made available through the OEQC website, as well as through EPA's
website, for public review and comment. EPA and the County initially solicited written comments
on the Draft EA during the 30-day period from September 23 - October 23, 2018. In response to
a request for extension, EPA and the County extended the public comment period for the Draft
EA to December 10, 2018.
The Draft EA was made available through the following public notices and methods of outreach:
• The EPA provided notice of the Draft EA on their website
(https://www.epa.aov/uic/proposed~pahala~communitv~larae~capacitv~cesspool~
replacement-proiect-draft-environmental):
• Notice of the publication of the Draft EA was published in West Hawaii Today and the
Hawaii Tribune Herald on September 26, 2018.
• A public notice was published in the October 1, 2018 print and online editions of the Ka'u
Calendar and made available on the Ka'u News Briefs web site
http://kau newsbriefs. bloqspot. com:
• The Ka'u Calendar News Brief included an article on October 9, 10, and 11, 2018 with
mention of an upcoming meeting (October 10, 2018 public information meeting); and
• Two notices for the Draft EA were published in The Environmental Notice:
o September 23, 2018 - notice for the statutory 30-day public review and comment
period for the Draft EA; and
o November 8, 2018 - notice for republishing the Draft EA and extension of the
public comment period for 30 days.
• Fliers were posted in public venues such as the community shopping center, realtor office,
grocery store, library, and the Pahala Community Center.
• Letters were mailed on September 10, 2018 containing information on the availability of
the Draft EA, the comment period, and the October 10, 2018 public information meeting
to all property owners on record adjacent to the proposed collection system.
After the publication and distribution of the Draft EA, a public information meeting was held on
Wednesday, October 10, 2018 at the Ka'u Gym Multi-Purpose Conference Room. The County
provided a presentation and display boards in an open-house format prior to the meeting to
facilitate public understanding of the proposed project, and meeting facilitators were available to
answer technical questions concerning the project and offer clarification where necessary.
On September 10, 2018, letters containing information on the availability of the Draft EA, the
comment period, and the October 10, 2018 public information meeting were mailed to all property
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Final EA, Pahala LCC Replacement Project - Appendix E
Pahala, Ka'u District, Hawai'i
owners on record adjacent to the proposed collection system. This direct mailout included an
invitation from DEM to workshops conducted prior to the October 10 public information meeting.
The workshop for owners served by C. Brewer lines was held on October 8, and the mailout for
this meeting also included any non-owners currently receiving a wastewater bill. The workshop
for owners of newly accessible properties was convened on October 9. In addition to the direct
mailout, online announcements for the October 8 and 9 workshops were available on the Ka'u
News Briefs website.
A summary of this public involvement and outreach following the issuance of the Draft EA is
included in the Final EA Section 7 (Public Participation). These efforts for public outreach and
involvement exceeded NEPA outreach requirements.
For responses to comments on outreach related specifically to the HEPA HRS 343 process,
please refer to the County's individual responses to the above comments.
As explained at various points in the Draft EA, including in Draft EA Section 1 (Summary), and in
the coversheet accompanying the Draft EA published in The Environmental Notice, the Proposed
Action is to construct "four lined aerated lagoons, a subsurface flow constructed wetland to
remove nitrogen and an adjacent disinfection system to remove pathogens and four slow-rate
land treatment basins for disposal of the treated effluent."
Comment
• Why were residents who are not on the LCC system excluded from the decision-making
process prior to December 2017? (Comment 55)
Response
On April 25, 2010, a community meeting sponsored by Councilman Guy Enriques was held at the
Pahala Community Center to discuss the Na'alehu and Pahala Large Capacity Cesspool
Replacement project. As part of the meeting, an informational handout prepared by the County's
Wastewater Division provided a brief history of the project documenting that, in 2004, Mayor Kim's
office used a ballot system to get input from property owners regarding different wastewater
treatment/disposal alternatives for those properties connected to the LCCs who would no longer
be served by the C. Brewer system after LCC closure. As reported in the Draft EA Section 2.1.4
(History of Wastewater Management in Pahala), 87 percent of the returned ballots were in favor
of the installation of a new sewer collection system and a treatment and disposal system to be
operated and maintained by the County. The handout indicated Mayor Kim's office advised the
property owners the County would move forward with a new system for Na'alehu and Pahala on
November 5, 2004. Additionally, the handout stated public meetings were held in both Na'alehu
and Pahala in November 2006 to discuss the wastewater system alternatives. The handout
included that adequate land for the treatment and disposal system had not been identified in
Pahala. The Final EA Section 2.1.4 (History of Wastewater Management in Pahala) has been
updated with this information.
Subsequent to that, community outreach activities in the form of five talk story sessions took place
in 2017 for the current Pahala LCC Replacement Project and contributed to the development of
the Draft EA. The community outreach program for the Pahala LCC Replacement Project, as
stated in the Draft EA Section 7 (Public Participation), began when the County held these five talk
story sessions which were open to all residents and members of the public. This information is
repeated in the Final EA.
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Pahala, Ka'u District, Hawai'i
2.3.2 Accessing the Draft EA
Comment
• I had difficulties downloading the Draft EA. (Comments 1, 2)
• I was not provided a copy of the EA despite having requested consulting party status.
(Comment 1)
• The Notice for the Pahala DEA was sent to the wrong address. (Comment 3)
Response
The commenter responsible for comments 1, 2, and 3 received a copy of the Draft EA via U.S.
Postal Service certified mail on or about September 27, 2018. The comment period ended
December 10, 2018, giving the commenter ample time to provide comments on the Draft EA.
Efforts to distribute the Draft EA for public review and comment exceeded NEPA outreach
requirements that are described in the comment response on pages 25 through 27 above.
Comment
• Only one copy of the Draft EA was sent to the Pahala library, limiting access to the
document, especially for the elderly. (Comment 41)
Response
The Draft EA was prepared and published in The Environmental Notice issued by OEQC on
September 23, 2018. The Draft EA was made available through the OEQC website, as well as
through EPA's website, for public review and comment. Upon public request, 11 printed copies of
the Draft EA were made available at both the Na'alehu and Pahala libraries on November 7, 2018.
The public comment period ended on December 10, 2018.
These efforts to distribute the Draft EA for public review and comment exceed the NEPA outreach
requirements. This information is included in the Final EA Section 7 (Public Participation).
Comment
• There was no physical copy of the Draft EA available at the October 10, 2018 meeting.
(Comment 18)
Response
Federal NEPA regulations do not require a project proponent to hold a public meeting on a Draft
EA, nor do they require hard copies of a Draft EA be available at a public meeting. The October
10, 2018 public information meeting included a presentation and display boards to facilitate public
understanding of the project. The Draft EA, which is a 300-page-plus document, was made
available online and in the Pahala and Na'alehu public libraries in advance of the public
information meeting for any person to review, copy, or download. In response to a request from
a member of the community, additional copies of the document were made available at public
libraries as described in the response to the previous comment.
2.3.3 Public Information Meeting
Comment
• Oral comments should be collected at public meetings. Surely someone can take oral
comments and make a transcription as OECQ has done? (Comments 9, 16)
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Final EA, Pahala LCC Replacement Project - Appendix E
Pahala, Ka'u District, Hawai'i
• The written commenting process used during public meetings is not adequate for people
with limited English. (Comment 10)
• Increments of project, if any, should be presented. What is presented is not complete, (in
reference to the October 10, 2018 meeting). (Comment 62)
• Future subdivisions should be included in presentation (in reference to the October 10,
2018 meeting). (Comment 62)
Response
Unlike the process for preparing an EIS, there is no requirement under EPA's NEPA regulations
to hold public meetings concerning an EA or Proposed FONSI. As such, agency officials are not
required to collect and respond to oral comments on a Draft EA. Despite not being required, the
County held a public information meeting on the Pahala LCC Replacement Project during the
comment period for the Draft EA in order to maximize the public's awareness of the proposal.
The Draft EA public information meeting included a presentation and display boards that showed
the entire project being considered under the Proposed Action. Though the Pahala LCC
Replacement Project would be built in a manner consistent with good engineering practices so
that it would not preclude expansion to treat additional flow associated with residences being
added to the collection system, there are no current plans to do so. The Draft EA Section 6.2.2
(Ka'u Community Development Plan) discussed the Ka'u Community Development Plan and
included a description of Policy 120, which is stated as "Extend the primary wastewater collection
lines in Pahala and Na'alehu so that infill development projects can connect wastewater systems
built for new subdivisions to the County systems." Future subdivisions would be accommodated,
as capacity allows, on a first-come, first-served basis. This information has been added to the
Final EA.
Meeting facilitators verbally explained the Proposed Action and were available to answer technical
questions concerning the project and its increments. As these meetings were not transcribed for
the purpose of responding to oral comments, meeting facilitators made clear that persons seeking
a formal response from the agencies to their comments should submit comments in writing to the
County or EPA. The County provided staff at the October 10, 2018, public information meeting to
personally assist commenters in preparing written comments, including those with limited English
skills and those who preferred to dictate written comments instead of preparing the written
comments themselves.
Comment
• The make-up of Pahala is majority immigrants, where English is a second language.
These residents do not fully understand the details of the project and legal jargon, so have
not attended the community meetings. (Comment 56)
Response
The Draft EA Section 5.7 (Environmental Justice Executive Order 12898) indicated that Pahala
has a higher proportion of minority groups as compared to the County. The American Community
Survey Data for 2012-2016 estimate that the majority of Pahala residents (58.8 percent) speak
only English at home, and that an additional 18.2 percent speak English "very well."5 All notices
and public outreach materials prepared and distributed for the Pahala LCC Replacement Project
5 U.S. Census Bureau, 2012-2016 American Community Survey. Table S1601 (Language Spoken at
Home). U.S. Census Bureau's American Community Survey Office, 2017. Web. October 16, 2019.
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(see Section 2.3.1 (Outreach) of this Appendix for more information on outreach efforts) were
developed to be as easily readable and understandable by the general public as possible.
On October 10, 2018, a public information meeting was conducted by the County in the Pahala
at the Ka'u Gym Multi-Purpose Conference Room to discuss the Draft EA. During this meeting,
the County identified community volunteers attending the meeting who were proficient in
Hawaiian, Tagalog, and English to assist anyone who identified as needing assistance. The
OEQC rules have no provision for receiving oral comments. However, the facilitator at that
meeting offered assistance in putting any oral comments attendees may wish to offer into writing.
This information has been included in the Final EA.
2.3.4 Na'alehu and Pahala LCC Conversion Project- 2007 Final EA
Comment
• The 2007 Na'alehu and Pahala Villages Large Capacity Cesspool Conversion Project
called for the use of septic tanks for wastewater treatment. The county switched the plan
from septic tanks to a lagoon system without public review. (Comment 30)
• Ballots were only sent to those homeowners that were connected to the C. Brewer system,
not the whole community (in reference to COM 0293.004 2004-2006). (Comment 61)
Response
The Proposed Action described in the Pahala LCC Replacement Project Draft EA was developed
in response to new information and changed circumstances since the 2007 proposal that cast
doubt on the viability of the proposal included in the 2007 Final EA.
The Draft EA Section 2.9 (Relationship to 2007 Final Environmental Assessment) describes the
reasons for not implementing the project described in the 2007 Na'alehu and Pahala Large
Capacity Cesspool (LCC) Conversion project Final EA. Specifically, after the County published
the Final EA in 2007, it performed additional studies and evaluation of the proposed LCC-to-septic
conversion project and eventually concluded that the proposed system would not be feasible, and
likely would not meet regulatory requirements for a new wastewater treatment/disposal system.
As stated in the Draft EA Section 2.8.2(a), based on current design criteria and current flow
projections, an approximately 800,000-gallon community septic tank would be necessary to
provide the extended detention times needed to optimize treatment performance, to avoid the
need for frequent septage pumping, and to account for peak flow rates. A community septic tank
of this size would require pumping on a 3-year interval. Septic tanks produce hydrogen sulfide,
reduced sulfur compounds, and other odorous gases; a community septic tank would concentrate
these emissions to a single point source, requiring treatment with a dual-stage scrubber to avoid
nuisance odor conditions. Therefore, use of a community septic tank is not considered to be
feasible. In addition, Draft EA, Appendix B (Preliminary Engineering Report), Section 7.5.1 states
that the use of a community septic tank would require the Department of Health to issue a variance
to HAR § 11-62, which requires WWTPs with design capacities greater than 100,000 gallons per
day (gpd) to produce effluent containing less than 30 mg/L of both BODs [5-day biochemical
oxygen demand] and TSS [Total Suspended Solids] - septic tanks are not able to produce effluent
of this quality.
On April 25, 2010, a community meeting sponsored by Councilman Guy Enriques was held at the
Pahala Community Center to discuss the Na'alehu and Pahala LCC Conversion project. As part
of the meeting, an informational handout prepared by the County's Wastewater Division provided
a brief history of the project documenting that, in 2004, Mayor Kim's office used a ballot system
to get input from property owners regarding different wastewater treatment/disposal alternatives
for those residents who would no longer be served by the C. Brewer system after LCC closure.
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As reported in the Draft Section 2.1.4 (History of Wastewater Management in Pahala), 87 percent
of the returned ballots were in favor of the installation of a new sewer collection system and a
treatment and disposal system to be operated and maintained by the County. The handout
indicated Mayor Kim's office advised the property owners the County would move forward with
new systems for Na'alehu and Pahala on November 5, 2004. Additionally, the handout stated
public meetings were held in both Na'alehu and Pahala in November of 2006 to discuss the
wastewater system alternatives. The handout included that adequate land for the treatment and
disposal system had not been identified in Pahala. This information is included in the Final EA
Section 2.1.4.
The Pahala LCC Replacement Project Draft EA was made available online and in public libraries
in Na'alehu and Pahala beginning on September 23, 2018. The County and EPA solicited input
on the Proposed Action via the public comment period that lasted from September 23 to
December 10, 2018. Information concerning the decision to abandon the 2007 proposal has been
added to the Final EA Section 2.9.
2.3.5 State and Local Agencies
Comment
• The Department of Hawaiian Homelands acknowledges receiving the request for
comments. After reviewing materials submitted, due to the project's lack of proximity to
Hawaiian Home Lands anticipates no impacts to our lands or beneficiaries. We encourage
agencies to consult with Hawaiian Homestead community associations when preparing
EAs. Dated 9/27/2018. (Comment 35)
• The County of Hawai'i Police Department has reviewed the draft EA and does not have
any additional comments or concerns at this time. Dated 10/2/2018. (Comment 36)
• The Hawai'i Department of Land and Natural Resources (Engineering Division, Division
of Forestry and Wildlife, and Land Division) has reviewed the Draft EA for the Pahala LCC
Replacement Project and has no comments. Dated 10/22/2018. (Comment 77)
• The Hawai'i Department of Land and Natural Resources (Division of Forestry and Wldlife
and Land Division) has reviewed the Draft EA (generated in response to the extension of
public comment period) for the Pahala LCC Replacement Project and has no comments.
Dated 12/7/2018. (Comment 71)
Response
EPA acknowledges receipt of letters from the above organizations and appreciates their review
of the Proposed Action and Draft EA.
Pre-assessment consultation letters were sent to 14 Native Hawaiian Organizations, as stated in
the Draft EA Section 3.15.1 (Archeological Resources - Existing Conditions). These organizations
included the Pi'ihonua Hawaiian Homestead Community Association. No responses were
received from any Native Hawaiian Organization. This information is updated in the Final EA.
2.4 State and Local Processes
Responses to comments regarding compliance with state and local processes have been
arranged into the following categories:
• State of Hawai'i Office of Planning
• Hawai'i Environmental Policy Act (HEPA), HRS Chapter 343
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• Hawai'i Department of Business, Economic Development and Tourism, Land Use
Commission (LUC)
• Ka'u Community Development Plan (CDP)
2.4.1 State of Hawai'i Office of Planning
Comment
• The State of Hawai'i Office of Planning indicates that the Final EA should include a
discussion of the project's ability to meet all parts of the Hawai'i State Planning Act (HRS
Chapter 226), and examine the project's consistency with these statutes, or clarify where
it is in conflict. A discussion of Priority Guidelines, or a determination that these guidelines
are not applicable to the proposed action, should be included in an examination of Part III
statutes. (Comment 32)
• The State of Hawai'i Office of Planning requests that the Final EA should include a
discussion of the project's compatibility with statewide sustainability goals and principles
of sustainability (HRS § 226-108). (Comment 32)
• The State of Hawai'i Office of Planning indicates that the option of a District Boundary
Amendment could be considered as a land use approval option (could be used instead of
a Special Permit) and discussed in the EA. (Comment 32)
Response
The State of Hawai'i Office of Planning received a pre-assessment consultation letter on March
15, 2018 and provided a formal response on April 8, 2018 which included comments on the
Proposed Action. These initial comments were incorporated into the project planning and the
development of the Draft EA as appropriate. In addition to the pre-consultation response, the
State of Hawai'i Office of Planning provided comments on the Draft EA (those described above)
that requested an expansion of the discussion in the Draft EA Section 6 (Plans, Policies, and
Controls) to include the Proposed Action's ability to meet all parts of the Hawai'i State Planning
Act. Information and a brief discussion of sustainability principles from HRS § 226-108 have been
added to the Final EA Table 6.1 in addition to information on other applicable sections of Part III
of HRS § 226 as requested by the Office of Planning.
The State of Hawai'i Office of Planning's comment concerning the option of a District Boundary
Amendment is noted.
2.4.2 Hawai'i Environmental Policy Act (HEPA)
Comment
• The project is in violation of HEPA and UIPA for disclosure of the August 15, 2018
environmental assessment records, and denial of requested records. (Comment 1)
• The COH/EPA/Contractors should fully explain why two new-build secondary sewage
plants 11 miles apart in remote, rural Ka'u would not require an EISPN Act 172-12 notice.
(Comment 2)
• The Pahala and Na'alehu projects are in violation of EIS requirements as established by
HRS 343/ HAR 11-200 and 11-201. (Comment 13)
• The Pahala and Na'alehu projects should be considered together under HEPA 343.
(Comment 16)
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• The project is not in compliance with HRS 343 because of the failure to prepare a HEPA
EIS, the methods of public outreach and participation, lack of availability of documents,
and lack of TEN public notice for the two "talkstory" sessions. (Comment 23a)
• The Pahala Draft EA notice failed to include the 9A trigger; the project should trigger HEPA
343 Sec5(a)(9). (Comments 16, 53, 58)
• Demoruelle v. Beck evidence of misconduct in following NEPA/HEPA. (Comment 75)
Response
The above-listed comments relate to compliance with the Hawai'i Environmental Policy Act,
otherwise known as Chapter 343 of Hawai'i Revised Statutes or HRS 343. The Final EA Section
6 (Plans, Policies and Controls) includes discussion of state and local requirements applicable to
this project. Comments related specifically to compliance with state requirements including HRS
343 are addressed by the County in its separate responses to the above comments.
For discussion of compliance with NEPA procedures, please see Section 2.2 (NEPA Processes)
of this Appendix. Discussion of public outreach and notice efforts is included in Section 2.3 (Public
Involvement and Outreach) of this Appendix and in the Final EA Section 7 (Public Participation).
Comments regarding the Na'alehu Large Capacity Cesspools Closure Project are outside the
scope of the Proposed Action. The Na'alehu Large Capacity Cesspools Closure Project is
currently undergoing a separate environmental review, coordinated by the County of Hawai'i
Department of Environmental Management, in accordance with HRS 343 requirements.
2.4.3 Hawai'i Department of Business, Economic Development and Tourism, Land Use
Commission (LUC)
Comment
• Describing the project as 14.9 acres is an attempt to evade LUC scrutiny, as LUC review
is required for projects of 15 acres or more. (Comments 1, 6, 23a, 40 and 41)
• The project covered a minimum 667,500 sq. ft. [15.3 acres] plus utility access must be
considered as part of the project impacts no matter who will own it, so that is another
37,500 sq. ft., bring total acreage at Site 7 as 16.1 acres. (Comment 23a)
• The LUC should be given a chance to review the project even if the property was not within
their range. (Comment 42)
Response
Because the Proposed Action is located within an Agricultural District, under Hawai'i law a Special
Permit is needed. As described in the Draft EA Sections 3.10.2 (Agricultural Lands - Impacts and
Mitigation Measures) and 6.1.3 (State Land Use District), "under Chapter 205, HRS, use of
agricultural lands for non-agricultural purposes greater than 15.0 acres requires approval of a
Special Permit by the Land Use Commission." The Final EA clarifies that, for the Preferred
Alternative at Site 7, the County would apply for a Special Permit which requires approval by the
County Planning Commission. For projects that would use agricultural lands for non-agricultural
purposes greater than 15.0 acres, the County Planning Commission would then submit their
decision to the State of Hawai'i Land Use Commission for their approval.
As stated in the Draft EA Section 3.10.2(a), "construction of the wastewater treatment and
disposal facility at Site 7 would require removal of approximately 14.9 acres of macadamia nut
trees." The 14.9-acre site has been selected to provide the necessary land area for the facilities
needed to treat the incoming flows and to dispose the treated effluent from the treatment process.
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The proposed project site minimizes the use of the adjacent lands which contain a commercial
macadamia orchard. A larger project site is not required. Please refer to the County response to
Comment 23a for more information.
As stated in the Draft EA Section 2.10.3 (Hawai'i Revised Statutes (HRS) Chapter 205
Considerations), within the agricultural district, public, private, and quasi-public utility lines are a
permitted use. The area of the Proposed Action located within the ROWs and other easements
within the residential areas of Pahala is considered a permitted use within agricultural land and
therefore does not add to the acreage of agricultural lands for purposes of the Special Permit for
the LUC review. The County would therefore seek a Special Permit from the County Planning
Commission. This information is repeated in the Final EA Section 2.10.3.
No attempt has been made to avoid review by the LUC. The County sent the LUC a pre-
consultation letter for this project dated March 15, 2018 providing notice of the preparation of a
Draft EA and inviting comments on the Proposed Action as part of the pre-assessment
consultation process. No response was received. Also, the Department of Business, Economic
Development and Tourism was directly notified (by mail) of the availability of the Draft EA.
2.4.4 Ka'u Community Development Plan (CDP)
Comment
• The Pahala Draft EA shows no respect for the Ka'u CDP, specifically Policy 90, and does
not follow its statutes. (Comments 46, 50, 65)
Response
Comments related to compliance with state and local requirements are addressed by the County
in a separate response to the above comments. The Draft EA included a detailed discussion of
the Ka'u Community Development Plan in Section 6.2.2 (Ka'u Community Development Plan).
That section has been updated in the Final EA.
2.5 Project Location and Design
Responses to comments regarding the location and design of the proposed project have been
arranged into the following categories:
• Proximity to Schools
• Location of preferred Alternative
• Extent of Collection System
• T reatment Alternatives
• Technical Design
2.5.1 Proximity to Schools
Comment
• How far away will the Plant be from the Pahala schools? (Comment 23a)
• I am very concerned about the short distance between the proposed site and the school.
(Comment 26)
Response
As stated in the Draft EA Section 4 (Cumulative Effects), the Ka'u High School and Pahala
Elementary School are approximately one-half mile north of the wastewater treatment and
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disposal facility at Site 7 under the Preferred Alternative. The facility would be separated from the
schools by a macadamia nut orchard, the old Pahala Sugar Mill maintenance yard, five streets
and numerous private residences. The wastewater treatment and disposal facility would be
enclosed with a 6-foot-high chain-link fence and posted to prevent public access. EPA does not
anticipate that construction and operation of the proposed wastewater treatment and disposal
facility would have any direct or indirect impact on the schools (e.g., due to visual, smell, or noise
impacts), due to the distance between the proposed facility and the schools. This information has
been added to the Final EA Sections 3.14 (Air Quality), 3.18 (Noise), and 3.19 (Visual
Characteristics).
The schools currently discharge wastewater to eight (8) DOH-approved septic systems. At the
time the septic systems were installed, two new laterals were also installed at the property line on
Hala Street and Kamani Street to allow for eventual connection to the new collection system (see
Draft EA Section 4.1.1 (Past, Present, and Reasonably Foreseeable Actions)). Upgrading the
collection system in front of the school so that these laterals may be connected to the new
collection system may result in temporary traffic impacts during construction but these impacts
would be mitigated through the establishment of a traffic control plan which would be coordinated
with HIDOE transportation services (see the Draft EA Section 3.17.2 (Traffic - Impacts and
Mitigation Measures)).
Construction of the project would also result in temporary noise impacts for all areas with
construction equipment and trenching as described in Draft EA Section 3.18.2. All construction
activities would comply with the Community Noise Control provisions of HAR 11-46. Lastly, the
Proposed Action could result in short-term impacts to air quality due to construction activities as
a result of fugitive dust or exhaust emissions from mobile construction equipment as described in
Draft EA Section 3.14.2. A dust control plan would be implemented to include mitigation measures
such as watering of active work areas. EPA does not anticipate any long-term impacts to the Ka'u
High School and Pahala Elementary School as a result of construction activities.
2.5.2 Location of Preferred Alternative
Comment
• The plant should be sited below/south of the highway. (Comments 23a, 27, 55, 56, 62, 63,
67, 68, 69, 70, 73) - Commenters provided the following rationales for this comment:
concern over flooding risk, concern that caves and burial sites may be present at the
proposed location, concern about visual and odor impacts, and concern about safety and
health.
• I am very upset with this whole idea of where you are intending to put the new plant.
(Comment 34)
• The plant should be sited south of the highway and make use of the existing culvert that
was installed by the sugar industry. (Comments 31, 33)
• Please move the proposed Pahala sewage treatment plant to the makai (seaward side) of
the highway. The proposed site is too close for comfort and life quality. (Comment 37)
• The site should be relocated below the highway to be further away from the town due to
safety, environmental, historical, and aesthetic concerns. (Comment 41)
Response
The Draft EA Section 2.7 (Development of Site Alternatives and Selection of Preferred Alternative)
discussed the alternative sites for construction of a new wastewater treatment and disposal
facility. One of the alternatives discussed, Site 9, is located below the highway. This alternative
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Pahala, Ka'u District, Hawai'i
scored lower than the Preferred Alternative location (Site 7) because it would require construction
of additional access roads, a longer distance to available power and potable water, and a longer
transmission line due to the further distance from the existing LCCs and collection system
infrastructure. Site 9 would require approval by the State of Hawai'i Department of Transportation.
It also scored lower than Site 7 because of presence of and/or proximity to archeological/cultural
sites. In addition, it was determined that, depending on the configuration of the wastewater
treatment facility and the land application groves, this alternative could require trenching and
construction of piping across south flowing branches of the Hi'onamoa Gulch, classified as a
riverine wetland (per the National Wetland Inventory), which occurs within the site. To avoid this
potential impact for Site 9 and to minimize costs, the headworks, lagoons, and the subsurface
constructed wetlands could be sited in the upper portion of the site (i.e., the area closest to the
highway) which would result in other impacts. Further discussion has been added to the Final EA
Sections 2.5 (Proposed Action - Site 9 Alternative) and 3.7 (Surface Water).
Two additional parcels located below the highway were identified in the Draft EA as Sites 4 and
5. Site 4 was eliminated from consideration because, among other reasons, it contained an
unnamed gulch that would need to be crossed by influent and fire protection lines and, because
of the soil type, it was estimated that 200 acres would be needed to accommodate the slow-rate
land treatment basins (See Draft EA Section 2.8.1(d) (Other Site Alternatives)). Site 5 was
eliminated from consideration for similar reasons, as described in Section 2.8.1(e) of the Draft
EA. No other parcels below the highway were identified as potentially suitable for the project.
The location and configuration of the Preferred Alternative (Site 7) were designed to minimize
aesthetic impacts of the project. As described in the Draft EA Section 3.19.2 (Visual
Considerations and Light Pollution - Impacts and Mitigation Measures), the existing pine trees
along Maile Street would continue to obstruct the view of the facility from Maile Street. The facility
would be visible from Mamalahoa Highway (State Route 11); however, impacts to the view plane
would be mitigated by the planted trees in the disposal groves and by the rise in elevation between
the highway and the facility. In addition, as described in the Draft EA Table 6.1, the project "does
not include facilities or improvements that would adversely affect public safety of this area of
Hawai'i." Potential impacts of the project on historic properties are addressed in Section 2.1.5
(Archeological and Cultural Resources) of this Appendix.
2.5.3 Extent of Collection System
Comment
• It was my understanding that the reason the sewage system was being expanded beyond
what was required by the Feds was because it was part of the CDP. Can you please direct
me to the section in the CDP that states this? (Comment 29)
• I really feel that the County of Hawai'i should concentrate on only people involved with
LCC's first and foremost because of the Federal mandated regulations. We non-LCC are
not in violation of any standards of the Federal Regulation's requestings. (Comment 55)
• The County has decided to expand the new sewage system beyond those homes currently
on LCCs, and beyond what is required by the federal government. (Comments 31 and 73)
• There are some homes which will have the sewer line running near their homes but are
not part of the original C. Brewer LCC line. The homes across the street and connecting
are not part of the LCC line either, so it is perplexing as to why this initial phase of the
project is including lines in areas that are not necessary. (Comment 61)
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Response
The Draft EA Section 2.3.2 (Construct New Wastewater Collection System) discusses the
construction a new sewer collection system in the Pahala community to replace and expand upon
the existing system of substandard gravity lines that currently conveys sewage to the two LCCs.
As described in the Draft EA Section 6.2.1 (Hawai'i County General Plan), the current LCC
collection system includes lines located the backyard of many parcels. Where easements for the
existing collection system aren't accessible, the County must obtain permission from each
landowner to enter them, through private property, to inspect, maintain, repair, or replace existing
sewer facilities: all activities essential to an efficient, functioning system. As a result, the proposed
new collection system would be located primarily within the public street rights-of-way and to close
the LCCs, there would be parcels that become "newly accessible" to the collection system. The
collection system is not being expanded under the Proposed Action beyond the area needed to
close the LCCs. This information is repeated in the Final EA.
The collection system constructed as part of the Proposed Action would be designed to extend to
all properties currently served by the LCC system. While the areal extent of the new collection
system would mirror the old collection system, certain properties that are not currently served by
the LCC system and that are adjacent to, or across the street from, the LCC properties, would
become accessible to a sewer when the new collection system is installed. Under County code,
properties that become accessible to a sewer are required to connect to sewer unless certain
exceptions are met. While the Proposed Action does not include installation of laterals to connect
these newly accessible properties to the new collection system, it is nonetheless foreseeable that
these properties would be required to connect to the new system. These properties have therefore
been included in the scope of the environmental review for this project.
The requirement for accessible properties to connect to sewer is discussed in detail in the Draft
EA Section 2.3.2 and the Final EA Section 2.3.2. Comments related to state and local
requirements, including the CDP, are addressed in the County's response to Comment 29.
2.5.4 Treatment Alternatives
Comment
• If all the County had wanted was compliance with clean-water requirements, and with the
least distress to the taxpayer and payer of sewage-system user fees, it probably would
have explored alternative means of sewage treatment. Methods such as constructed
wetlands generally are less capital and labor intensive than traditional treatment plants.
(Comment 5)
• The DEA gives no consideration to any decentralized, more cost-effective project for rural
areas such as in Ka'u. There should be remedial community meetings to consider
alternatives, including the original conversion to septic, to close the LCCs. (Comment 23a)
• Mobile sewage treatment systems should be considered to address Hawai'i's problem
with cesspools. Mobile units could be used when cesspools are at capacity, and they do
not require pipelines, which are subject to damage. (Comment 44)
• No alternatives, including micro-sewage projects, have been offered to taxpayers.
(Comment 52)
• The sewage flow could easily be handled by one or two small packaged plants, affordably
modular to accommodate growth, on a very small footprint of land with no noxious odors.
(Comment 66)
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• The type of plant to be used should be reconsidered due to the history of flooding from
rain, storms, and hurricanes from the slopes of Mauna Loa which would overflow the open
sewer reservoir. (Comment 76)
Response
The proposed treatment method for the Pahala LCC Replacement Project consists of an aerated
lagoon treatment system with a constructed wetland and disinfection, followed by land application
for effluent management. The system is described in detail in the Draft EA Section 2.3.1 (Acquire
Site 7 and Construct New Secondary Wastewater Treatment and Disposal Facility). In addition to
the proposed treatment method, the County and EPA considered numerous treatment
alternatives, including septic tank alternatives (see Draft EA Section 2.8.2(a)), alternatives for
onsite wastewater systems (see Draft EA Section 2.8.2(b)) and other "effluent management
options" (see Draft EA Section 2.8.3). As described in the Draft EA, all these alternatives were
removed from consideration due to their lack of feasibility and other concerns as outlined in the
Draft EA Section 2.8 (Alternatives Considered but Not Carried Forward).
Specifically, septic tank alternatives were rejected because it was determined that a community
septic system large enough to receive the projected flow from the community would not be
capable of achieving the effluent quality standards required by HAR § 11-62-23.1 (see Draft EA
Section 2.8.2). In addition, individual septic systems for the lots currently served by the LCCs
were deemed infeasible because many of the lots in Pahala are too small to construct individual
septic systems (see Draft EA Section 2.8.2).
The commenter referring to micro-sewage may have been referring to individual wastewater
systems such as composting toilets which would be too small to meet the purpose and need of
the Proposed Action. A discussion of alternative individual systems is available in the Preliminary
Engineering Report in Appendix B of the Final EA.
Flood risks associated with the proposed wastewater treatment and disposal system are
discussed in Section 2.1.1 (Flood Risk) of this Appendix, and in the Final EA Sections 2.3.1
(Acquire Site 7 and Construct New Secondary Wastewater Treatment and Disposal Facility) and
3.23 (Infrastructure - Drainage System).
2.5.5 Technical Design
Comment
• The Brown and Caldwell engineer classified Pahala wastewater flows (80,000 gallons a
day) as municipal. EPA cites small wastewater flows (non-municipal) as under 1 million
gallons a day. All consideration of packaged treatment plants were dismissed based on
the engineer characterizing the Pahala wastewater flow as municipal. Since a package
plant that would be adequate to close the Pahala LCCs would cost around $4 million... this
option would be given real consideration as a cost effective alternative. It would also
require far less land and fit closer to the exiting LCCs. Since packaged plants are modular,
capacity could be expanded for future flows by just adding new units. The added cost of
electricity and sludge removal would be offset by saving of $10 million in borrowed SRF
funds. (Comment 64)
• The proposed facility is too large. The Pahala WWTP will be built to handle 380,000
gal/day when the actual flow for a larger population base in the 2007 FEA was 80,000 g/d.
Underutilized plants can become a "negative removal efficiency" - meaning what the plant
pumped out was more contaminated that what went in. (Comment 5)
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• The engineers fail to justify the extremely high Pahala wastewater flow rates which should
have been based on City and County of Honolulu Sewer Standards with an average
wastewater flow rate of 320 gal/day per lot. The LCC closure only required disconnecting
from around one hundred households, so the flow rate is around 32,00 gal/day. (Comment
66)
Response
Per HAR 11-62, wastewater treatment works must be designed in accordance with County
standards, or City and County of Honolulu standards if a county does not have design standards.
The County of Hawai'i does not have design standards; therefore, the City and County of Honolulu
standards are applicable to the Pahala LCC Replacement Project. The City and County of
Honolulu updated their design standards in July 2017 and the 320-gpd standard is no longer
applicable.
Based on these standards, the Pahala LCC Replacement Project is designed to treat an average
dry weather flow of 190,000 gpd including lots which are not in single family residential use or
zoning, which is sufficient capacity to allow closure of the LCCs. Additional detail is provided in
the Draft EA Appendix B (Preliminary Engineering Report). It should be noted that wastewater
flows from a community are highly variable, and peak flow rates from small community wastewater
collection systems are typically three to five times higher than the average flow rates. State and
County design standards take this variability into account, and application of the standards results
in conservatively designed facilities that are protective of human health and the environment
under anticipated conditions. Information relating to applicable design standards has been added
to the Final EA Section 2.3 (Proposed Action - Site 7 Alternative (Preferred Alternative)).
The wastewater treatment and disposal facility and the collection system would be designed to
meet the purpose and need of the Proposed Action. The facility would be built to handle 190,000
gpd (average dry weather), not the full-buildout flow projections of 360,000 gpd associated with
expansion to entire community. However, as a matter of good engineering practice, and to the
extent practical, the wastewater treatment and disposal facility and collection system would be
designed not to preclude expansion to treat future average dry weather flows up to 360,000 gpd
should the County or community decide in the future that expansion is necessary in accordance
with the requirements established in the Ka'u Community Development Plan Policy 120.
The proposed treatment system for the Pahala LCC Replacement Project includes aerated
lagoons that are more energy efficient than conventional activated sludge wastewater treatment
processes. The aerated lagoon process is less sensitive to underloading conditions than
conventional activated sludge wastewater treatment processes and would provide excellent
treatment performance during low flow conditions. The "negative removal efficiency" effect is not
applicable to the aerated lagoon technology. The Pahala LCC Replacement Project does include
a constructed wetland treatment system and the proposed land treatment tree groves provide an
energy efficient "natural" technology that would use sunlight, vegetation, and soil properties to
achieve the desired results.
Comment
• The consideration of the use of alternative energy sources (wind, solar, methane) would
decrease emissions. Hooking up to HELCO is not looking to the future. Please look
beyond the grid for energy. (Comments 31, 73)
Response
The 14.9-acre area for the wastewater treatment and disposal facility under the Preferred
Alternative (Site 7) minimizes use of the adjacent macadamia nut farm. The Draft EA Figure 2.3
February 2020
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Final EA, Pahala LCC Replacement Project - Appendix E
Pahala, Ka'u District, Hawai'i
shows the project site as fully utilized by the four lagoons, the four planted groves used for slow-
rate land application system, the subsurface flow constructed wetland, and the headworks and
operation building. The remaining land area would not be sufficient to accommodate construction
of facilities for an alternative energy source.
The Preferred Alternative does not include utilizing alternative energy systems such as
photovoltaic solar or wind as a total replacement for connecting to the HELCO grid due to:
• The need for consistent power supply;
• Emergency backup power requirements;
• Up-front capital cost;
• Full utilization of the 14.9-acre proposed site for the treatment and disposal facility;
• Objective to minimize the amount of land area removed from agricultural production; and
• EPA-enforced project implementation schedule deadlines.
Partial augmentation of traditional power utilizing photovoltaic solar panel arrays on the
headworks and operations building rooftops, however, is feasible and would be further analyzed
during the detailed design phase after loads and demand patterns are better understood.
Additional alternative energy systems can be added in the future if prioritized and funded by
County Council, and the electrical systems would be designed to accept additional alternative
energy input.
Methane gas is generated at wastewater treatment plants using a process called anaerobic
digestion. The proposed wastewater treatment and disposal facility would be too small for
anaerobic digestion to be economical; the design flow to the Pahala wastewater treatment and
disposal facility would be 190,000 gpd, and anaerobic digestion is only economically attractive for
wastewater treatment and disposal facilities that treat at least 5 to 10 million gpd. In addition, the
anaerobic digestion process requires primary clarifiers as part of the liquid treatment process, but
primary clarifiers tend to be odorous in tropical climates, due to the relatively high wastewater
temperatures. The proposed facility would rely on natural treatment systems that require relatively
low energy input. Additional detail regarding the preliminary analysis of alternative energy options
can be found in the Final EA, Appendix B (Preliminary Engineering Report).
Comment
• I am concerned with the placement of the sewer lines near the water lines of Pahala. Is
there some kind of spec sheet that shows how far away the sewer line will be to the water
line? (Comment 61)
Response
As stated in Draft EA Section 3.22.1(a) (Infrastructure - Water System - Existing Conditions),
"the water lines are primarily located along or under the roadways in the area." The Draft EA
Appendix A included a letter from the County of Hawai'i DWS that stated the following:
"The Department requests that the construction plans show, and the proposed sewer lines be
installed with, the proper horizontal and vertical clearances from our existing water system
facilities and concrete jacketing atwaterline crossings, where necessary, as recommended by the
Department's Water System Standards. In addition, backflow prevention devices must be
installed where there are connections to our water system at wastewater processing and
treatment facilities."
February 2020
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Final EA, Pahala LCC Replacement Project - Appendix E
Pahala, Ka'u District, Hawai'i
The Pahala LCC Replacement Project would not impact existing water lines in the community.
This information was added to the Final EA Section 2.3.2 (Construct New Wastewater Collection
System).
2.6 Other Comments
Responses to other comments have been arranged into the following categories:
• Miscellaneous and Other Comments
• Na'alehu Large Capacity Cesspools Closure Project
2.6.1 Miscellaneous and Other Comments
Comment
• A councilmember's name was listed incorrectly in the Draft EA. (Comment 8)
Response
Refer to the Final EA Section 10.1 (Pre-Assessment Consultation) for corrected spelling of the
councilmembers name.
Comment
• The Draft EA incorrectly states that Pahala is the largest town in Ka'u District. (Comment
61)
Response
Refer to the Final EA Section 2.1.1 (Pahala Community) for a correction to the text which has
been revised to state "The Ka'u district consists of several communities, including the Pahala
community, which has a population of approximately 1,341 persons."
Comment
• The Draft EA list of preparers did not include the outreach subcontractors. (Comments
23a, 27)
Response
The public outreach subcontractor did not prepare the EA and therefore no correction the List of
Preparers in the Final EA is required.
Comment
• What were the agreements made between C. Brewer and the County during the transition
of turnover? (Comment 67)
Response
The Draft EA Section 2.1.4 (History of Wastewater Management in Pahala), which described the
history of wastewater management in Pahala, includes the following information: "Around 2006,
C. Brewer requested that the County construct and maintain a new and improved community
sewer system. A County Council Resolution approved the C. Brewer request. In anticipation of C.
Brewer's dissolution, C. Brewer proposed, and the County agreed, to enter into a formal
agreement to not only construct and maintain a new and improved community sewer system but
to assume ownership of the existing system including the LCC's by April 30, 2010." As part of this
agreement, for the majority of Pahala properties connected to the LCCs, C. Brewer committed to
complete the line (called a lateral) between the residences and the property line at the edge of
February 2020
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Final EA, Pahala LCC Replacement Project - Appendix E
Pahala, Ka'u District, Hawai'i
the public right-of-way adjacent to the new collection system. It was agreed, if the County did not
complete its portion of the work by April 30, 2010, the County would assume pending and
unfinished obligations to connect the new laterals installed by C. Brewer to the residences and
new collection system when complete. Thus, because that date has passed and the County has
not completed installation of the new collection system, this project includes connecting these C.
Brewer laterals, which may now need to be replaced, or installing private laterals for currently
connected properties if authorized by the property owner and approved by County Council. This
information has been added to the Final EA Section 2.1.4.
Comment
• Since the Kealakehe WWTP is running so much over budget, why won't the Pahala
project? (Comment 27)
Response
The Kealakehe Aeration Upgrade and Sludge Removal Project is a repair and upgrade project
that is outside of the original project scope for construction of that facility; comments regarding
the cost of that repair and upgrade are not pertinent to the scope, cost, or impacts of the Proposed
Action.
Comment
• A handout was distributed by then County Rep. Guy Enriques to everyone in the
community. Why did the county waste money doing an EA regarding the same site?
(Comment 41)
• The citizens of Ka'u have been significantly harmed by COHDEM and EPA failure to
incorporate environmental review from the initial proposal of the WWTP projects in 2012
DEM's CIP 2012-13 Budget. (Comment 23a)
• The Na'alehu/Pahala 2007 Final EA/FONSI should have been supplemented or withdrawn
prior to the publication of the Pahala Draft EA/AFNSI notice in September 2018.
(Comment 4)
• Why hasn't the 2007 Ka'u LCC project Final EA/FONSI been withdrawn under HRS?
(Comment 27)
Response
In 2007, the County prepared a Final EA for a project to install septic tanks to replace the existing
cesspools in order to comply with HRS 343. Before EPA performed its environmental review of
the project as required under NEPA, the project was abandoned because it was determined to be
infeasible based on further engineering review. Additionally, the parcel considered in the 2007 EA
for construction of a septic tank treatment system (TMK 9-06-002:016) is not the same parcel as
the Preferred Alternative (Site 7) of the current Pahala LCC Replacement Project (TMK 9-6-
002:018). A discussion of the history of the projects is included in the Final EA Section 2.9
(Relationship to 2007 Final Environmental Assessment).
Comments relating to HRS 343 publication procedures for the project proposed in 2007 are not
germane to the Pahala LCC Replacement Project that is currently the subject of EPA's review
under NEPA. As explained in the Draft EA Section 2.9 and in Section 2.3.4 (Na'alehu and Pahala
LCC Conversion Project - 2007 Final EA) of this Appendix, the EPA did not prepare or approve
the 2007 County-led environmental review referenced in the comment. Comments related to
compliance with publication requirements under HRS 343 are addressed by the County in their
responses to the above comments.
February 2020
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Final EA, Pahala LCC Replacement Project - Appendix E
Pahala, Ka'u District, Hawai'i
2.6.2 Na'alehu Large Capacity Cesspools Closure Project
Comment
• EPA and CODEM are avoiding NEPA/HEPA, ESA, NHPA, Section 106 and the
environmental review for the Na'alehu project. (Comments 1, 34, 43, 57, 65)
• EPA has separated the Ka'u LCC closure grant into two separate projects and refused to
follow NEPA/ESA procedures that EPA followed for the Pahala project DEA as for the
Na'alehu WWTP work plan. (Comment 4)
• I have concerns about the Na'alehu plant, including its location. (Comment 5)
• Na'alehu plant is sited too close to the school. The Na'alehu DEA has been withheld since
April 2017, and no EA has been published, preventing the opportunity for public review
and comments. (Comment 23a)
• There was no public participation in the decision to site the Na'alehu WWTP near the
elementary school. (Comment 38)
• How can comments be made about the Na'alehu WWTP? We will share this information
at the weekly Ka'u community meeting about the WWTPs. (Comment 47)
• The Na'alehu project is sited too close to the well, school and in PONC Land. (Comments
43, 47, 48, 52, 75)
• Is the Na'alehu Preliminary Engineering Report available at the libraries? I did not know it
had been published because two scheduled meetings about the Na'alehu project have not
been held. (Comment 48)
• Did the libraries receive copies of the Preliminary Engineering Report for the Na'alehu
sewage treatment plant? (Comment 54)
• EPA and COHDEM transferred funding away from the Na'alehu project to evade NEPA,
NHPA-/ESA requirements. (Comment 65)
• The estimated costs for the Na'alehu project are suspicious. The large value of the
administrative and legal expenses budget for suggests it may be a slush fund. (Comment
66)
• HI Department of Education requests to be included in the pre-draft assessment
consultation and Draft EA for the Na'alehu LCC Replacement Project. (Comment 72)
• COHDEM and its contractors are avoiding Section 7 consultation under the ESA for the
Na'alehu project. (Comment 57)
Response
Comments regarding the Na'alehu Large Capacity Cesspools Closure Project are outside the
scope of the Proposed Action. As explained in the Draft EA Section 4.1.2 (Actions Considered
but Excluded from Analysis), the Na'alehu Large Capacity Cesspools Closure Project is a
separate project from the Pahala LCC Replacement Project and the two are not expected to result
in any cumulative impacts given the considerable distance between the two towns. This is further
clarified and supported in the Final EA Section 4 (Cumulative Effects). In addition, neither project
is dependent on the other for completion, nor does approval or completion of one project make it
more likely the other would be similarly approved or completed. The Na'alehu Large Capacity
Cesspools Closure Project is currently undergoing a separate environmental review, coordinated
February 2020
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Final EA, Pahala LCC Replacement Project - Appendix E
Pahala, Ka'u District, Hawai'i
by the County of Hawai'i Department of Environmental Management, in accordance with HRS
343 requirements.
2.7 Comments Not Related to NEPA
Comment
• EPA should consider a settlement because the third circuit will be considering the
preliminary injunction. I am planning to file a personal injury claim. (Comment 17)
• The County should grandfather in the "newly accessible lots" with functional cesspools
and septic tanks. (Comment 31)
• The plaintiff responds to the defendant's Opposition to the Motion for Preliminary
Injunction. The Na'alehu wastewater system Draft EA should be immediately released,
and the County of Hawai'i should cease any and all expenditures on consultant and
subconsultant contractors and halt all planning and development activities on the Na'alehu
and Pahala WWTP projects. (Subject of forwarded legal documents) (Comment 21)
• The community plans to file multiple lawsuits. (Comment 23a)
• Is there any impact on rapport when there will be endless lawsuits based on violation of
NEPA/HEPA for the twin Ka'u WWTP projects? (Comment 27)
• Since the Kealakehe WWTP is the "most important" project in Kona, why isn't the Ka'u
twin WWTP projects treated as "important"? (Comment 27)
• I did not receive any confirmation that comments were mailed. (Comment 39)
• I am having trouble finding an attorney and no one has attempted to talk to me about the
case. (Comment 21)
• We will be suing on this forever! (Comment 22)
• Residents of Pahala have experienced negative psychological impacts since 2005 or
2007. (Comments 40, 41)
• The judge dismissed the Preliminary Injunction, and the COH Motion to Dismiss. The court
case will move forward. (Comment 49)
• You have not addressed the problem of an [APA Hawai'i Chapter] award for a Ka'u CDP
that has been totally ignored. The judges who awarded it were misled. (Comment 50)
• I am available as a consultant to produce a Cultural Impact Assessment if the project
proceeds to the EIS phase. (Comment 60)
• Wll police be present at the public meeting? (Comments 11 and 16)
• The LCC households of Ka'u deserve reparations and should not pay for sewer service
until the project is completed. (Comment 23a)
• Employee strikes (disputes). (Comment 67)
Response
These comments are not relevant to the environmental review.
February 2020
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Final EA, Pahala LCC Replacement Project - Appendix E
Pahala, Ka'u District, Hawai'i
Comment
• A Brown & Caldwell sub-contractor has approached community members seeking
personal information about me, which is criminal invasion. I will be contacting the Pele
Defense Fund and the FBI. (Comment 19)
• I will not be consulting the Pele Defense Fund. I have been traumatized by the Brown and
Caldwell sub-contractor inquiring about me. The County Council will request an audit of
this 13 year fiasco or I will take evidence of malfeasance to the FBI. (Comment 20)
Response
These comments are not relevant to the environmental review. EPA has found no indication that
illegal conduct has occurred.
February 2020
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Final EA, Pahala LCC Replacement Project - Appendix E
Pahala, Ka'u District, Hawai'i
3 County of Hawai'i Response to Comments
The following is a compilation of all comment letters from agencies, organizations, and others
who formally replied with comments to the Draft EA. Note that some of the comments were
submitted as a letter and some via e-mail as shown by the date and time. As required by HAR §
11-200-9.1(c), all written comments and County of Hawai'i responses are reproduced in this
appendix.
(*) denotes comment number shown in Table 1
State Agencies
(32) Office of Planning
(72) Department of Education
(35) Department of Hawaiian Home Lands
(77) Department of Land and Natural Resources, Engineering Division
(71; 77) Department of Land and Natural Resources, Land Division
(71; 77) Department of Land and Natural Resources, Division of Forestry and Wildlife
County of Hawaii Agencies
(36) County of Hawai'i Police Department
Interested Parties
(37) Ruby Javar
(26) TinaTuttle
(27) Sandra Demoruelle
(28) Dr. Noelani Hong 10/10/2018; 11:38 am
(44) Dale A. Loper 9/29/2018; 7:46 am
(29) Ngaire Gilmour 10/17/2018; 10:30 am
(30) Jerome Warren
(31) Ngaire Gilmour 10/20/2018; 12:40 pm
(33) Edward Andrade, Jr.
(41) Sophia M. Hanoa 10/23/2018; 4:47 pm
(42) Jadelyn Kaapana-Moses 10/24/2018; 1:39 pm
(38) Lila Lopes
(34) Charles Tuttle and Tina Tuttle
(43) Amanda McDowell and Anthony McDowell
(40) Pele Defense Fund
(55) Alfred Ibarra and Mary Ibarra
(56) Walter T.L. and Debra A. Wong Yuen
(63) Gwendolyn Sorensen 11/2/2018; 2:43 pm
February 2020
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Final EA, Pahala LCC Replacement Project - Appendix E
Pahala, Ka'u District, Hawai'i
62) Prodincio Fuerte
59) Larry O. Navarro 11/19/2018; 11:27 am
60) Lisa Gollin 11/19/2018; 11:46 am
61) Tanya Ibarra 12/3/2018; 8:19 am
68) Dorothy Kalua
67; 69; 70) Pele Defense Fund (2 duplicates) 12/10/2018; 6:15 am; 6:26 am; 6:26 am
73) Ngaire Gilmour 12/10/2018; 5:01 pm
74) Keoni Fox 12/10/2018; 5:43 pm
76) Noelani Hong
1)
Sandra
Demorue
le
9/24/2018;
8:57 am
2)
Sandra
Demorue
le
9/24/2018;
10:26 am
3)
Sandra
Demorue
le
9/24/2018;
11:15 am
4)
Sandra
Demorue
le
9/24/2018;
1:21 pm
5)
Sandra
Demorue
le
9/25/2018;
8:32 am
6)
Sandra
Demorue
le
9/25/2018;
9:39 am
7)
Sandra
Demorue
le
9/25/2018;
12:28 pm
8)
Sandra
Demorue
le
9/25/2018;
12:39 pm
9)
Sandra
Demorue
le
9/28/2018;
9:54 am
10)
Sandra
Demorue
le
9/28/2018;
11:52 am
11)
Sandra
Demorue
le
9/28/2018;
1:21 pm
12)
Sandra
Demorue
le
9/28/2018;
1:43 pm
13)
Sandra
Demorue
le
9/29/2018;
5:50 pm
14)
Sandra
Demorue
le
10/1/2018;
10:29 am
15)
Sandra
Demorue
le
10/1/2018;
10:41 am
16)
Sandra
Demorue
le
10/3/2018;
8:17 am
17)
Sandra
Demorue
le
10/6/2018;
9:00 am
18)
Sandra
Demorue
le
10/10/2018
; 10:50 pm
19)
Sandra
Demorue
le
10/12/2018
; 10:20 am
20)
Sandra
Demorue
le
10/13/2018
; 8:51 am
21)
Sandra
Demorue
le
10/21/2018
; 4:12 pm
22)
Sandra
Demorue
le
10/24/2018
; 4:03 pm
39)
Sandra
Demorue
le
10/23/2018
; 2:48 pm
46)
Sandra
Demorue
le
10/31/2018
; 8:03 am
45)
Sandra
Demorue
le
10/31/2018
; 8:13 am
48)
Sandra
Demorue
le
10/31/2018
; 11:39 am
47)
Sandra
Demorue
le
10/31/2018
; 12:41 pm
49)
Sandra
Demorue
le
10/26/2018
; 11:12 am
February
2020
47
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Final EA, Pahala LCC Replacement Project - Appendix E
Pahala, Ka'u District, Hawai'i
(50) Sandra
Demoruel
le
11/2/2018; 12:22 pm
(51) Sandra
Demoruel
le
11/5/2018; 9:26 am
(52) Sandra
Demoruel
le
11/6/2018; 11:51 am
(53) Sandra
Demoruel
le
11/8/2018; 11:52 am
(54) Sandra
Demoruel
le
11/13/2018; 12:40 pm
(57) Sandra
Demoruel
le
11/16/2018; 10:03 am
(58) Sandra
Demoruel
le
11/2/2018; 12:14 pm
(64) Sandra
Demoruel
le
12/10/2018; 2:36 pm
(65) Sandra
Demoruel
le
12/10/2018; 3:01 pm
(66) Sandra
Demoruel
le
12/10/2018; 3:29 pm
(75) Sandra
Demoruel
le
12/10/2018; 4:38 pm
(23a) Sandra
Demoruel
le
10/22/2018; USPS
February 2020
48
-------
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RPORATIOK
'»i'OS5 .*i «
10349-01 ref (32)
March 6, 2020
Ms. Mary Alice Evans, Director,
Office of State Planning
235 South Beretania Street, 6th Floor
Honolulu, Hawaii 96813
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment - October 17, 2018
Dear Ms. Evans:
Thank you for your October 17, 2018 comment letter (DTS201810160922NA) regarding the
County of Havvai'i Department of Environmental Management Draft Environmental Assessment
(EA) for the Pahala Large Capacity Cesspool Replacement project. Our responses follow:
1. No response required.
2. i. State Land Use Unpermitted Use Consideration
A District Boundary Amendment is an option to the County Special Permit.
However, a District Boundary Amendment to Urban would result in a spot
designation where the surrounding area is currently designated as Agricultural by the
State Land Use Commission and by the County in both the General Plan and Ka'u
Community Development Plan. Also, this same surrounding area zoning designation
is Agriculture (A-20a or A-la) or MG-la in the case of the adjacent macadamia nut
facility. Overall, this spot zoning designation is not preferable in lieu of the Special
Permit. This information will be included in the Final EA Section 2.10.3.
ii. The Hawaii State Planning Act
The Final EA will include the following discussion of Part III Priority Guidelines.
iii. Principles of Sustainabilitv
The Final EA will include the following discussion on this project's compatibility
with the principles on sustainabilitv, HRS §226-108.
The Final EA will include the following in Table 6.1:
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
-------
10349-01
Letter to Ms. Mary Alice Evans, Director,
Page 2
March 6, 2020
PART II. PLANNING COORDINATION and IMPLEMENTATION
Part II does not apply to the Pahala Community Large Capacity Cesspool Replacement project.
PART III. PRIORITY GUIDELINES
Objectives and Policies of the Hawai'i State Plan
Discussion
§226-101 Purpose. The purpose of this part is to
establish overall priority guidelines to address
areas of statewide concern.
The Pahala project will support applicable
overall priority guidelines, as follows:
§226-102 Overall direction. The State shall
strive to improve the quality of life for Hawaii's
present and future population through the pursuit
of desirable courses of action in seven major
areas of statewide concern which merit priority
attention: economic development, population
growth and land resource management,
affordable housing, crime and criminal justice,
quality education, principles of sustainabilitv,
and climate change adaptation.
The Pahala project will affect short-term
economic development and jobs during the
construction period. The Pahala project
will not affect economic development,
population growth and land resource
management, affordable housing, crime
and criminal justice, quality education and
climate change adaption. Removal of
cesspools is consistent with the principles
of sustainabilitv.
§226-103 Economic priority guidelines, (a)
Priority guidelines to stimulate economic growth
and encourage business expansion and
development to provide needed jobs for Hawaii's
people and achieve a stable and diversified
economy.
(e) Priority guidelines for water use and
development:
(1) Maintain and improve water conservation
programs to reduce the overall water
consumption rate.
(2) Encourage the improvement of irrigation
technology and promote the use of
nonpotable water for agricultural and
landscaping purposes.
The Pahala project will stimulate economic
development and jobs during the
construction period.
§226-104 Population growth and land
resources priority guidelines, (a) Priority
guidelines to effect desired statewide growth and
distribution:
The Pahala project will d not affect
population growth but may help protect the
environment and improve water quality in
nearby surface water resources.
10349-01
Letter to Ms. Mary Alice Evans, Director,
Page 3
March 6, 2020
§226-105 Crime and criminal justice. Priority
guidelines in the area of crime and criminal
justice:
The Pahala project will not affect crime or
criminal justice in the Pahala area.
§226-106 Affordable housing. Priority
guidelines for the provision of affordable
housing:
The Pahala project will not affect
affordable housing in the Pahala area.
226-107 Quality education. Priority guidelines
to promote quality education:
The Pahala project will not affect
education in the Pahala area.
[§226-108] Sustainabilitv. Priority guidelines
and principles to promote sustainabilitv include:
(5) Promoting decisions based on meeting the
needs of the present without compromising
the needs of future generations.
The Pahala project will close 2 large
capacity cesspools, replacing them with
secondary treatment and disposal systems,
thereby protecting ground water resources
for future generations, potentially
benefitting the health and vitality of the
area coastal and marine ecosystem.
[§226-109] Climate change adaptation
priority guidelines. Priority guidelines to
prepare the State to address the impacts of
climate change, including impacts to the areas of
agriculture; conservation lands; coastal and
nearshore marine areas; natural and cultural
resources; education; energy; higher education;
health; historic preservation; water resources; the
built environment, such as housing, recreation,
transportation; and the economy.
The wastewater treatment and disposal
facility will be designed to contain the 100-
vear, 24-hour storm event while
maintaining sufficient freeboard to account
for the uncertainty of climate model
projections..
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA; C. Lekven, BC; P. Goodwin, ERG
-------
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-------
WILSON OKAMOTO
COUP T t § II
10349-01
March 6, 2020
ref (72)
Mr. Kenneth G. Mads en II, Public Works Manager
Planning Section
Department of Education
State of Havvai'i
P.O. Box 2360
Honolulu, HI 96804
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment - December 7, 2018
Dear Mr. Mads en:
Thank you for your December 7, 2018 comment letter regarding the County of Havvai'i
Department of Environmental Management (DEM) Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our responses follow:
The Final EA Section 2.3.2 will include the following:
As stated in Section 4.7.2 of the County ofHawai'/. Department of Public Works, Final
Environmental Assessment and Finding of No Significant Impact, Ka 'u Gym and Shelter,
Pahala, Ka 'u District. April 2012: "In accordance with Section 21-5, Havvai'i County
Code (HCC), Ka'u High and Pahala Elementary School, including the Ka'u District Gym
and Shelter, will be required to connect to the County sewer system when access
becomes available. The State Department of Education will be responsible for
coordinating and constructing the connection to the sewer system via a branch main on
Hala Street and properly closing their onsite system. "
Further, the Ka'u Gym and Shelter Final EA states: 'The Ka'u High and Pahala Elementary
School, including the Ka'u District Gym and Shelter, will become accessible to the proposed
County sewer system with the installation of two new laterals at the property line on Hala
Street and Kamani Street. While typically only a single lateral is provided for a lot, the
additional lateral on Hala Street is being installed to accommodate the project and create a
gravity flow connection."
Information regarding project schedules, including US Environmental Protection Agency
(USEPA) compliance dates, project updates and milestones can be found on the USEPA website
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
10349-01
Letter to Mr. Kenneth G. Mads en II
Page 2
March 6, 2020
at: https://www.epa,gov/uic/coutity-hawaii-administrative-order-consent-closure-cesspools-
pahala-atid-naalehu.
The County will also provide information about the construction schedule for the treatment and
disposal facility and the collection system to the Facilities Development Branch Public Works
Administrator on request. Impacts and mitigation measures for addressing construction-related
dust, traffic and noise are addressed in the Draft EA Sections 3.14.2, 3.17.2 and 3.18.2.
Further, the County will coordinate with the HIDOE Student Transportation Services Branch
Manager and the School in order to minimize construction-related impacts to student
transportation services. This information will be included in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
•SSUF
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STATE OF HAW An
rOPllA«II»;IIIIO»lt,l*NK ' *
Septwnber 27,
wtliioa otiuiKsE® corporation
1»©7 S. tera-tania St., «»
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gI§I»*K*
I cti t»i m
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(D£A) on chit ptopotmA community I,mm
Capacity Cuapsal IliCiCI ftaplacaMott fcroject
Su&;|*6C:
fl>«;5 Jitpkiirtiiitiwlt erf Hawaii*!! tftsiie acknowledge* receiving
Eh* r«quo«t. for coommmt* on tihft atoowt-cited project. Alter
reviewing the imatetrialii submitted, due to its lark trf proximity
tit KmmII I*, u* lie nor anticipate any iapacta to our
or beneficiaries ~rata the project.
fcwwt, we highly
•II
t» CMURil* With
sther (HInative
Hawaiian ©r«a»ii;i»tic«.y wim preparing enviromimmtai
to better aaaea* potential iiigiitcts to «ileiir«l and natural
mmmnmn, *«e«* »«l other tight* ol Native Hawaiian*.
HaJwrto for si» opportunity to previa® comment*. If you
any plsase call few Ann Hyatt at ett-MliO or mm
have
Sincerely
m(\ '-vf
II, Xaleo Manuel
ActtRf MtimiOf inrof-s«a
LSOM OKAMOTO
RP0RAT4QN
„• a. t o s ;s . * i « t *, <. , h ! I *
10349-01 ref (35)
March 6, 2020
M. Kaleo Manuel, Acting Planning Program Manager
State of Hawai'i
Department of Hawaiian Home Lands
91-5420 Kaplolei Parkway
Kapolei, HI 96707
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - September 27, 2018
Dear Mr. Manuel:
Thank you for your September 27, 2018 comment letter regarding the County of Hawai'i
Department of Environmental Management Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement project. The Final Environmental Assessment
(EA) will note that due to the lack of proximity to Hawaiian Home Lands properties, the
Department of Hawaiian Home Lands does not anticipate any impacts to the lands or
beneficiaries from the project.
The Draft EA Section 10.1 lists the Native Hawaiian Organizations consulted in preparation of
the Draft EA. This information will be repeated in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
-------
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-------
WILSON OKAMOTO
COUP T t § II
10349-01
March 6, 2020
ref (77)
Mr. Russell Y. Tsuji, Land Administrator
Land Division
Department of Land and Natural Resources
State of Havvai'i
Post Office Box 621
Honolulu, HI 96809
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of, Ka'u, Havvai'i
Response to Comment, e-mail December 10, 2018
Dear Mr. Tsuji:
Thank you for your December 12, 2018 comment letter regarding the County of Havvai'i
Department of Environmental Management Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement project. Our responses follow:
The Draft EA Section 3.9.1 (a) states:
"The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM),
Community Panel No. 155166 1800F, effective date September 29, 2017 shows that most of
the Pahala area is located in Zone A', which designates areas determined to be outside the 0.2-
percent annual chance (500-vear) floodplain. A small portion of the community of Pahala,
including some land within the collection system project site, is located within Zone X—
Other Flood Areas, indicating areas within the 0.2-percent annual chance (500-year)
floodplain, or areas with a 1-percent annual chance of flooding with average flood depths
less than 1 foot.
According to the FIRM, both existing LCCs are also located within ZoneX. However, LCC-1
is very close to the edge of the 500-year floodplain.
On April 16, 2018, in response to the pre-assessment notification, the State of Havvai'i
Department of Land and Natural Resources Engineering Division stated the responsibility for
conducting research as to the flood hazard designation for the project site lies with the project
proponent. Also on April 16, 2018 and in response to the pre-assessment notification, the
County of Havvai'i Department of Public Works confirmed that the proposed treatment and
disposal project site at Site 7 is designated as Zone X on the FIRM and is outside the 500-
year floodplain."
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
10349-01
Letter to Mr. Russell Y. Tsuji
Page 2
March 6, 2020
This information will be repeated in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
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10349-01 ref (71; 77)
March 6, 2020
Mr. Russell Y. Tsuji, Land Administrator
Land Division
Department of Land and Natural Resources
State of Hawai'i
Post Office Box 621
Honolulu, HI 96809
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - December 7, 2018
Dear Mr. Tsuji:
Thank you for your December 7, 2018 comment letter regarding the County of Hawai'i
Department of Environmental Management Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement project. Our response follows:
The Final EA will note the Land Division - Hawai'i District and the Division of Forestry and
Wildlife had no comments.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
-------
STATE OF HAWAII
DEPARTMENT OF LAND AND NATURAL RESOURCES
LAND DIVISION
POST OFFICfc BOX 621
HONOLULU. HAWAII 96809
suzanne n c\se:
LHAWPUtSON
LAND AND NATURAL KESOUKCES
)N WATER KESOUKCfe
CC'.EC CS/-I
0A £*6
October 22, 2018
Wilson Okamolo Corporation
1907 South Beretania Street, Suite 400 via email: PahaiaEA@wigsonokamoto.com
Honolulu, Hawaii 96826
Gentlemen:
SUBJECT: Draft Environmental Assessment for the Pahaia Large Capacity
Cesspool Replacement Project located at Pahaia, District of Ka'u,
Island of Hawaii; TMK: (3) 9-6-002:018
Thank you for the opportunity to review and comment on the subject matter. The Land
Division of the Department of Land and Natural Resources (DLNR) distributed or made
available a copy of your request pertaining to the subject matter to DLNR's Divisions for their
review and comments.
At this time, enclosed are comments from the (a) Engineering Division, (b) Division of
Forestry & Wildlife, and (c) Land Division - Hawaii District on the subject matter. Should you
have any questions, please feel free to call Darfene Nakamura at (808) 587-0417. Thank you,
Sincerely,
Land Administrator
Enclosures
cc: Central Files
ill
it
IS®
527f«(J2i49E®iHEERHG ,
COMMISSION ON Vi ATFR RFSOl
St.4f» IGhMtN'l
STATE OF HAWAII
DEPARTMLNT OF LAM) AND NA'i URAL RESOURCES
LAN'D DIVISION
post omen box 621
HONOI.t'l -.HAWAII 96809
JdT'
LOCATION:
APPLICANT:
September 27, 2018
MEMORANDUM
DLNR Agencies;
Div. of Aquatic Resources
Div. of Boating & Ocean Recreation
X Engineering Division
_X_Div. of Forestry & Wildlife
Div. of State Parks
X Commission on Water Resource Management
Office of Conservation & Coastal Lands
X Land Division - Hawaii District
X Historic Preservation
Russell Y. Tsuji, Land Administrate
Draft Environmental Assessment for the Pahaia Large Capacity Cesspool
Replacement Project
Pahaia, District of Ka'u, Island of Hawaii; TMK: (3) 9-6-002:018
Wilson Okamoto Corporation
Transmitted for your review and comment is information on the above-referenced
subject matter. We would appreciate your comments by October 19, 2018.
The DEA can be found on-line at: httu './/health.hawaii,gov/oeac/ (Cfick on The
Environmental Notice in the middle of the page.)
If no response is received by this date, we will assume your agency has no comments.
If you have any questions about this request, please contact Darlene Nakamura at 587-0417.
Thank you.
Attachments
(~}
C }
We have no/objections.
We have nojcomments.
Comments a/e^attachpd/
Signed:
Print Name:
Date:
¦j-r-p
V^-Carty ft. P.hang P.hir>f Pngtpoar
Central Files
-------
I
STATE OF HAWAII
DEPARTMENT OF LAND AND NATURAL RESOURCES
LAND DIVISION
POST OFFICE BOX 621
HONOLULU, HAWAII 96809
September 27, 2018
FfjdM: ^ '
SUBJECT:
LOCATION:
APPLICANT:
DLNR Agencies:
Div. of Aquatic Resources
Div. of Boating & Ocean Recreation
X Engineering Division
X Div. of Forestry & Wildlife
Div. of State Parks
X Commission on Water Resource Management
Office of Conservation & Coastal lands
X Land Division - Hawaii District
X Historic Preservation
Russell Y. Tsuji, Land Administrated
Draft Environmental Assessment for the Pabafa Large Capacity Cesspool
Replacement Project
Pahafa, District of Ka'u, island of Hawaii; TMK: (3) 9-6-002:018
Wilson Okamoto Corporation
Transmitted for your review and comment is information on the above-referenced
subject matter. We would appreciate your comments by October 19, 2018.
The DEA can be found on-line at: htto://health, hawaii. aov/oeoc/ (Click on The
Environmental Notice in the middle of the page.)
If no response is received by this date, we wiil assume your agency has no comments.
If you have any questions about this request, please contact Darlene Nakamura at 587-0417.
Thank you.
Attachments
( y We have no objections.
(v) We have op comments.
( ) Comme
Signed:
Print Name: DAVID G. SMITH, Administrator
Date:
cc: Central Files
m 01NR
son mn
06:38:31 a.m.
10—13—2018
SUMNHSfl.CASe
STATE OF HAWAII
DEPARTMENT OP LAND AND NATURAL -RESOURCES
LAND DIVISION
POST OFFICE BOX 621
HONOLULU, HAWAII 96809
2018 0CI-I P 12* 3^
RECEIVED
LAND DIVISION
HILQ. HAWAII
P:
FROM:
SUBJECT:
LOCATION:
APPLICANT:
September 27, 2018
MiMSMMiMa f
DLNR Agencies:
Div. of Aquatic Resources
Div. of Boating & Ocean Recreation
X Engineering Division
JKJDIv. of Foreslry & Wildlife
Ply. of Slate Parks
X Commission on Water Resource Management
Office of Conservation & Coastal Lands
X Land Division - Hawaii District
X Historic Preservation
Russell Y. Tsuji, Land Administ
Draft Environmental Assessment for the Pahata Large Capacity Ctsspool
Replacement Project
Pahala, District of Ka'u, island of Hawaii; TMK: (3) 9-6-002:018
Wilson Okamoto Corporation
Transmitted for your review and comment is information on the above-referenced
subject matter. We would appreciate your comments by October 19,2018.
The DEA -can be found on-line at: httmffhealtti.hawalaov/oeac/ (Cilek on The
Environmental Notice In the middle of the page.)
If no response is received by this date, we will assume your agency has no comments.
If you have any quesfions about this request, please contact Darlene Nakamura at 587-0417.
Thank you.
Attachments
cc: Central Files
( O We have no objections.
{ ) We have no comments.
( ) Comments are i
Signed:
Print Name:
Date:
i'hthtr.:
-------
WILSON OKAMOTO
COUP T t § II
10349-01
March 6, 2020
ref (71;77)
Mr. Russell Y. Tsuji, Land Administrator
Land Division
Department of Land and Natural Resources
State of Havvai'i
Post Office Box 621
Honolulu, HI 96809
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment - October 22, 2018
Dear Mr. Tsuji:
Thank you for your October 22, 2018 comment letter regarding the County of Havvai'i
Department of Environmental Management Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement project. Our responses follow:
The Final EA will include the Department of Land and Natural Resources Engineering Division
had no additional comments, the Division of Forestry and Wildlife had no comments, and the
Land Division - Havvai'i District had no objections.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
-------
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County of Hawaii
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tJirft CapKXy C«l##9f fciplisewttll Project,
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comments or tonti
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LSOM OKAMOTO
RPORATIQN
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10349-01 ref (36)
March 6, 2020
Chief Paul Ferreira, Police Chief
County of Havvai'i
Police Department
349 Kapiolani Street
Hilo, HI 96720
Attention: Captain Miles Chong, Commander Ka'u District
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment - October 2, 2018
Dear Chief Ferreira:
Thank you for your October 2, 2018 comment letter regarding the County of Havvai'i
Department of Environmental Management Draft Environmental Assessment for the Pahala
Large Capacity Cesspool Replacement project. The Final Environmental Assessment (EA) will
note that the County of Havvai'i Police Department has reviewed the Draft EA and does not have
any comments or concerns at this time.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
-------
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10349-01 ref (37)
March 6, 2020
Mr. Ruby Javar
P.O. Box 847
Pahala, HI 96777
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - October 10, 2018
Dear Mr. Javar:
Thank you for your October 10, 2018 comment letter regarding the County of Hawai'i
Department of Environmental Management Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool (LCC) Replacement project. Our responses follow:
The Draft EA Section 2.7 describes the site selection process, including the factors and their
relative weights used to evaluate the various sites. Further, Section 2.7 describes the twenty-one
criteria within four general categories (environmental, social and cultural; location and site; land
use and availability; and collection system and service area) that were established and defined for
the analysis. The Draft EA Appendix B, Section 8, provides additional information regarding the
site selection process. As a result of this process, the County identified three sites (Sites 7, 8, and
9) as reasonable alternatives for construction of the wastewater treatment and disposal facility
under the Proposed Action. The final scores for Sites 7, 8, and 9 were 4.33, 4.06, and 4.10
respectively, out of a total possible score of 5. Based on this analysis, Site 7 was selected as the
Preferred Alternative. The site is easily accessible, has good soils for a land application system,
and is close to the existing LCCs.
The Draft EA Section 2.5 describes Site 9, which is south (makai) of the Preferred Alternative
Site 7. As outlined in Appendix B Section 8, Site 9 earned a lower ranking than Site 7 for the
following criteria: presence of and or proximity to archaeological/cultural sites, existing vehicle
access, power and potable water availability, and distance from the area of the wastewater
collection system. Site 7 had a lower ranking than Site 9 in one category: topography. With the
distance between the two sites less than 300 feet, they were ranked equally for the criteria of
proximity of treatment units to existing occupied buildings.
The Draft EA Sections 2.5 and 2.7 provide information as to the issues related to the use of Site
9. An unnamed stream near the upper portion of the parcel could affect the selected
configuration of the wastewater treatment facility and the land application groves. Potentially, to
maximize energy efficiency by taking advantage of gravity flow, the headworks, lagoons and the
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii ~ 96826 • (808) 946-2277
-------
10349-01
Letter to Mr. Ruby Javar
Page 2
March 6, 2020
subsurface constructed wetlands could be sited in the upper portion of the site, or the area closest
to the highway. In addition, since the site is located across Mamalahoa Highway from the Pahala
community, it would require construction of piping and other utilities within the highway ROW
and approval by the State of Hawai'i Department of Transportation. Site 9 would require
additional access roads to facilitate both construction and operation of the treatment and disposal
facility and a slightly longer transmission line given its increased distance from the existing
LCCs.
This information will be included in the Final EA.
The comment referencing fines is not specifically a comment to the content of Draft EA, and the
potential for penalties to be levied against the County by the EPA for failure to close the LCCs is
unrelated to the site selection process.
The Draft EA Section 2.3.2 states the new collection system would be subject to the County of
Hawai'i Code (HCC) Chapter 21, Sewers. Specifically, HCC Chapter 21, Article 2 (Public
Sewers), Section 21-5, which states the following:
"(a)Owners of all dwellings, buildings, or properties used for human occupancy, employment,
recreation, or other purposes, which are accessible to a sewer are required at their expense to
connect directly with the public sewer within 180 days after date of official notice.''''
The financial impact of the project on individual newly accessible property owners was raised by
the community during the December 2017 public meetings. Although not required by Hawaii
Administrative Rules (HAR) Title 11, Chapter 200, Department of Environmental Management
voluntarily convened two additional public meetings in Pahala, one on October 9, 2018 and the
second on March 21, 2019 to gain further input from newly accessible property owners and
present funding options for them to pursue.
The Draft EA Section 7 will be revised to add that the County held additional meetings in Pahala
including one to provide information on financing sources available to owners of parcels which
would become accessible to the County collection system. The purpose of the March 21, 2019
meeting was to fulfill a County commitment made in October, 2018 to research financing
options available to the newly accessible residents of the Pahala Community. At the meeting.
Department of Environmental Management provided the preliminary results of the County
investigation into funding sources and options available for newly accessible property owners
once the new treatment and disposal facility and wastewater collection system have been
designed, permitted and constructed.
10349-01
Letter to Mr. Ruby Javar
Page 3
March 6, 2020
Programs discussed included:
• US Department of Housing and Urban Development (HUD) with County of Hawaii
Office of Housing and Community Development Residential Repair Program -
Community Block Grant Program, and
• US Department of Agriculture - Rural Development (USDA-RDA) Program.
As noted during the presentation, these programs may change in the coming years, and additional
options may be added to this preliminary list. Hawaii Legislature, Senate Bill 221 SD1, which
could amend Hawaii Revised Statutes (HRS) Chapter §342D to establish a low interest loan
program to offer financial assistance to cesspool owners to connect to wastewater treatment
systems approved by the Department of Health was also discussed; however, this bill was
subsequently not passed during the 2019 legislative session.
This information will be included in the Final EA.
The Draft EA Section 3.16 discusses the socioeconomic characteristics of and impacts on the
Pahala community.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
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10349-01 ref (27)
March 6, 2020
Ms. Tina Tuttle
P.O. Box 727177
Naalehu, HI 96722
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - October 10, 2018
Dear Ms. Tuttle:
Thank you for your October 10, 2018 comment letter regarding the County of Hawai'i
Department of Environmental Management Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement project. Our response follows:
The Elementary School Complex, the portion of campus closest to the treatment and disposal
facility within the Ka'u High and Pahala Elementary School campus, lies more than Vi mile
directly or about 1 mile away from the treatment and disposal facility by road. From the school,
one must travel on a portion of the school parcel and on 5 streets to reach the fenced wastewater
treatment and disposal facility. The intervening streets access or abut residential parcels and
other land uses. The distance and intervening land uses show the treatment and disposal facility
is not located in close proximity to a school facility. This information will be included in the
Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
-------
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WILSON OKAMOTO
COUP T t § II
10349-01
March 6, 2020
ref(27)
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment - October 10, 2018
Dear Ms. Demoruelle:
Thank you for your October 10, 2018 comment letter regarding the County of Havvai'i
Department of Environmental Management Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement project. Our responses follow:
M-l
Hawaii Revised Statutes (HRS) Section 343-5 Applicability and requirements (a) states
"Except as otherwise provided, an environmental assessment shall be required for actions that:
(1) Propose the use of state or county lands or the use of state or county funds..." as well as, "(9)
Propose any: (A) Wastewater treatment unit..."
However, Hawaii Administrative Rules (HAR) Title 11, Chapter 200, which implements HRS
Chapter 343, differentiates between "agency actions" - those proposed by an agency to utilize
state or county lands or funds; and, "applicant" actions" - those for which an applicant requires
approval from an agency.
The Pahala Large Capacity Cesspool Replacement project is a proposal by an agency
(Department of Environmental Management) to use County funds, thereby "triggering" the need
for an EA.
The September 23, 2108 Environmental Notice provided the following project description:
"The County of Hawai'i Department of Environmental Management proposes to construct
wastewater system improvements replacing the large capacity cesspools (LCCs) currently
serving Pahala, in order to comply with U.S. Environmental Protection Agency (EPA)
regulations. The project improvements would include a new wastewater collection system
located primarily within public streets in the Pahala community, and a treatment and disposal
system on land to be acquired by the County (TMK: 9-6-002: 018). The project would be
partially funded by an EPA grant and by the Clean Water State Revolving Fund loan program.
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
10349-01
Letter to Ms. Sandra Demoruelle
Page 2
March 6, 2020
The collection system would consist of approximately 12,150 linear feet of 8 to 12-inch diameter
underground gravity flow piping in Maile, Tlima, Huapala, Hlnano, Hala, Puahala and Plkake
Streets. The treatment and disposal facility would occupy about 14.9 acres and consist of a
headworks and an odor control unit, an operations building, four lined aerated lagoons, a
subsurface flow constructed wetland to remove nitrogen with an adjacent disinfection system to
remove pathogens, and four slow rate land treatment basins for further treatment and disposal of
the treated effluent. A perimeter security fence would enclose the entire facility. The existing
LCCs and associated wastewater collection system would be abandoned."
M-2- N/A
M-3
Hawaii Administrative Rules Title 11 Department of Health Chapter 200 §11.1(d) does not
include a requirement to withdraw a determination. Nor, is there a time stated for such a
withdrawal.
M-4
The public outreach subcontractor did not prepare the Draft EA.
M-5
This is not a comment on the content of the Draft EA for the Pahala Large Capacity Cesspool
Replacement project.
M-6
The quoted statement was from the Councilmember for the Kona district, in relation to the
Kealakehe Aeration Upgrade and Sludge Removal project. The Kealakehe Aeration Upgrade
and Sludge Removal project is not the subject of this Draft EA. The County of Hawai'i
Department of Environmental Management considers the Pahala Large Capacity Cesspool
Replacement project important.
M-7
As stated in the article, additional funding for the Kealakehe Aeration Upgrade and Sludge
Removal project was requested to replace the "badly eroded liners in several of the lagoons".
The liner replacement was outside of the original project scope. Expanding the scope of any
project generally necessitates additional cost in order to complete the work associated with that
expanded scope.
M-8
Hawai'i Administrative Rules (HAR) Title 11 Chapter 200-10 Contents of an environmental
assessment does not include a requirement for evaluating the fiscal impacts of a project on a
County's budget or ability to obtain funding.
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10349-01
Letter to Ms. Sandra Demoruelle
Page 3
March 6, 2020
M-9
The Draft EA Section 2.7 describes the site selection process, including the factors and their
relative weights used to evaluate the various sites. Further, Section 2.7 describes the twenty-one
criteria within four general categories (environmental, social and cultural; location and site; land
use and availability; and collection system and service area) that were established and defined for
the analysis. The Draft EA, Appendix B, Section 8, provides additional information regarding
the site selection process. As a result of this process, the County identified three sites (Sites 7, 8,
and 9) as reasonable alternatives for construction of the wastewater treatment and disposal
facility under the Proposed Action. The final scores for Sites 7, 8, and 9 were 4.33, 4.06, and
4.10 respectively, out of a total possible score of 5. Based on this analysis. Site 7 was selected as
the Preferred Alternative. The site is easily accessible, has good soils for a land application
system, and is close to the existing LCCs.
The Draft EA Section 2.5 describes Site 9, which is south (makai) of the Preferred Alternative
Site 7. As outlined in Appendix B Section 8, Site 9 earned a lower ranking than Site 7 for the
following criteria: presence of and or proximity to archaeological cultural sites, existing vehicle
access, power and potable water availability, and distance from the area of the wastewater
collection system. Site 7 had a lower ranking than Site 9 in one category: topography. With the
distance between the two sites less than 300 feet, they were ranked equally for the criteria of
proximity of treatment units to existing occupied buildings.
The Draft EA Sections 2.5 and 2.7 provide information as to the issues related to the use of Site
9. An unnamed stream near the upper portion of the parcel could affect the selected
configuration of the wastewater treatment facility and the land application groves. Potentially, to
maximize energy efficiency by taking advantage of gravity flow, the headworks, lagoons and the
subsurface constructed wetlands could be sited in the upper portion of the site, or the area closest
to the highway. In addition, since the site is located across Mamalahoa Highway from the Pahala
community, it would require construction of piping and other utilities within the highway ROW
and approval by the State of Hawai'i Department of Transportation. Site 9 would require
additional access roads to facilitate both construction and operation of the treatment and disposal
facility and a slightly longer transmission line given its increased distance from the existing
LCCs.
This information will be repeated in the Final EA.
M-10
The Draft EA Section 2.2 sets forth the purpose of the Pahala Large Capacity Cesspool
Replacement project: 'The purpose of the actions considered in this Environmental Assessment
(EA) is to provide the infrastructure necessary to enable the County to comply with the SDWA
and fulfill the compliance provisions of the AOC between EPA and the County with respect to
closure of the Pahala LCCs". The remaining portions of the Pahala community are not serviced
by the LCCs and hence not included in the Pahala Large Capacity Cesspool Replacement
10349-01
Letter to Ms. Sandra Demoruelle
Page 4
March 6, 2020
project. The Draft EA Figure 2.6 shows the area of the community serviced by the current and
proposed collection system.
The Draft EA Section 2.3.1 states the treatment and disposal facility will be designed to provide
an average dry weather flow capacity of 190,000 gallons per day, which will be sufficient
capacity to allow the closure of the two LCCs. In addition, the Draft EA Appendix B states the
wastewater treatment plant (WWTP) designed not to preclude treating future average dry
weather flows up to 360,000 gpd to meet the future needs of the community, in accordance with
the requirements established in the Ka'u Community Development Plan Policy 120.
M-ll
The Draft EA Section 4 discusses Cumulative Effects including the scope of analysis and also
actions considered but excluded from analysis.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
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fills mcjiitp it® Ixc® swwucd foe vitwi wmi ilanpiwii cement using w«riivfrer Mutt Swrcriiv. ml is
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LSOM OKAMOTO
RP0RAT4QN
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10349-01 ref (28)
March 6, 2020
Dr. B Noelani Hong
Via email: noealoha@gmail.com
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of, Ka'u, Hawai'i
Response to Comment - October 28, 2018 11:38 a.m.
Dear Dr. Hong:
Thank you for your October 28, 2018 11:38 a.m. comment message regarding the County of
Hawai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our response follow:
The County is aware of two existing culverts that allow stormwater to flow across the
Mamalahoa Highway in the vicinity of the project. The first is a box culvert located at the
intersection with Maile Street that conveys stormwater under the highway. The second culvert is
located approximately 600 feet east of the Maile Street intersection and was used to convey
sugar mill flume water across the highway for disposal.
The Draft EA Figure 2.3 shows the intersection of Maile Street and Mamalahoa Highway lies at
about 580 feet above mean sea level (MSL). The Draft EA Figure 2.2 shows the Pa'au'au Gulch
crosses under Mamalahoa Highway near the hospital about 0.88 miles north of that intersection
and lies at approximately 780 feet MSL or about 200 feet higher in elevation than the culvert at
the Maile Street and Mamalahoa Highway intersection._Due to this distance and the elevation
difference, surface flows at Site 7 would not affect the gulch. Similarly, the Kaimani Street and
Mamalahoa Highway intersection lies about 0.84 miles north of the proposed facility site and at
about 780 feet MSL. Surface flows at the facility would also not affect that intersection. Figures
2.2 and 2.3 will be repeated in the Final EA.
The Draft EA Section 3.9.1 (a) states:
'The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map
(FIRM), Community Panel No. 155166 1800F, effective date September 29, 2017 shows
that most of the Pahala area is located in ZoneX, which designates areas determined to be
outside the 0.2- percent annual chance (500-vear) floodplain. A small portion of the
community ofPahala, including some land within the collection system project site, is
located within Zone X — Other Flood Areas, indicating areas within the 0.2-percent
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
-------
10349-01
Letter to Dr. B Noelani Hong
Page 2
March 6, 2020
annual chance (500-vear) floodplain, or areas with a 1-percent annual chance of flooding
with average flood depths less than 1 foot.
According to the FIRM, both existing LCCs are also located within ZoneX. However,
LCC-1 is very close to the edge of the 500-year floodplain.
On April 16, 2018, in response to the pre-assessment notification, the State of Hawai'i
Department of Land and Natural Resources Engineering Division stated the responsibility
for conducting research as to the flood hazard designation for the project site lies with the
project proponent. Also on April 16, 2018 and in response to the pre-assessment
notification, the County of Hawai'i Department of Public Works confirmed that the
proposed treatment and disposal project site at Site 7 is designated as ZoneX on the
FIRM and is outside the 500-year floodplain."
The relevant FIRM panel is reproduced in Appendix B as Figure 4-13.
This information will be repeated in the Final EA.
Draft EA Section 3.23.2 (a) states:
'The proposed wastewater treatment and disposal facility would include an on-site
drainage system to address stormwater surface runoff created by new impervious surfaces
within the facility. The site would include a system to collect runoff via grated inlets or
swales, and flows would be conveyed to on-site drainage detention systems, such as
subsurface linear infiltration or depressed detention basins."
This information will be repeated in the Final EA.
The preferred alternative (Site 7) slopes from approximately north to south (mauka to makai)
such that, during rain events, surface flows pass through the existing orchard to the southern
(makai) end where the flows eventually drain through the culvert located at the Maile Street-
Mamalahoa Highway intersection to the areas below (makai) the highway. Most of the land
surface area below the existing macadamia nut orchard contains little to no vegetation to absorb
or slow these flows. The gradient of Site 7 and surrounding area results in this natural pattern of
surface flows which also existed when the area was planted in sugar cane and is not considered
flooding.
Based on the roadway flooding concerns expressed by the community during the Paha la public
meetings held in December 2017 and October 2018, the State of Hawai'i Department of
Transportation (DOT) Hawai'i District office was contacted to discuss drainage at the treatment
and disposal facility project site and the culvert at the Maile Street and Mamalahoa Highway
intersection. On February 20, 2019, the District office confirmed via telephone that the DOT
10349-01
Letter to Dr. B Noelani Hong
Page 3
March 6, 2020
owns and maintains the culvert at the Maile Street intersection, and that they have no record of
the roadway being inundated by stormwater drainage during precipitation events at that location.
Stormwater runoff generated mauka of the treatment and disposal facility project site will be
directed around the perimeter of the site via diversion swales that will convey flow back to the
existing drainage pattern that flows to the existing culvert at Maile Street. During heavy rain
events, stormwater may temporarily back up behind the culvert. There will be no changes to this
culvert and the proposed treatment and disposal facility will not be located within the area of the
culvert.
As stated in the Draft EA, the on-site stormwater management system would meet the
requirements of Hawai'i County Code (HCC), Chapter 27 Floodplain Management, Section 20,
Standards for subdivisions and other developments (e) which mandates a site drainage plan to
"comply with sections 27-20(a) and (b) and section 27-24, and shall include a storm water
disposal system to contain run-off caused by the proposed development, within the site
boundaries, up to the expected [design] storm event, as shown in the department of public works
"Storm Drainage Standards".
To meet the requirements of HCC, Chapter 27, Section 20 (f), the project "shall not alter the
general drainage pattern above or below the development". Thus, for the HCC design storm
event, no increase in flow amount will be directed to either of the culverts at the highway as a
result of the site development. A drainage report will be prepared during the design process to
evaluate the improvements necessary to comply with HCC Chapter 27 requirements.
The wastewater treatment processes will be designed to accommodate the associated peak flows,
including precipitation that falls on the area occupied by the aerated lagoon treatment system.
The Draft EA Appendix B, Section 2.2 outlines the anticipated peak wastewater flows from the
community, based on the applicable flow standard. The Draft EA Section 2.3.1 states the aerated
lagoons will be lined to prevent water seepage through the bottom and sides of the lagoons. The
Draft EA Appendix B, Section 5.3 shows the operational freeboard that will be available to
contain and to equalize lagoon flows during. In addition, the slow-rate land application groves
will be designed to completely contain both peak effluent flows and precipitation from a 100-
year, 24-hour storm event. A geotechnical engineering assessment of berm stability will be
conducted during the design process. The tree groves will be designed in accordance with the
EPA's "Process Design Manual, Land Treatment of Municipal Wastewater Effluents". Effluent
will be applied at a hydraulic loading rate that is a small percentage of the percolation rate of the
soil, ensuring sufficient capacity for assimilation of peak effluent flow rates and precipitation
from the design storm event.
This information will be included in the Final EA.
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10349-01
Letter to Dr. B Noelani Hong
Page 4
March 6, 2020
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
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10349-01 ref (44)
March 6, 2020
Mr. Dale A. Loper
z75dloter_sv9@dallop.us
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - September 29, 2018 7:46 a.m.
Dear Mr. Loper:
Thank you for your September 29, 2018 7:46 a.m. comment message regarding the County of
Hawai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our response follows.
As stated in the Draft EA Section 2.1.4, in 2003, C. Brewer requested assistance from the County
to close the large capacity cesspools (LCCs) in Pahala. Further, "Voting took place via mail for
the Pahala community to choose the preferred sewer improvement alternative resulting in 87
percent of the returned ballots in favor of installation of a new sewer collection system and a
treatment and disposal system to be operated and maintained by the County."
The Draft EA Section 2.3.1 states the treatment and disposal facility will be designed to provide
an average dry weather flow capacity of 190,000 gallons per day. In addition, the Draft EA
Appendix B states the wastewater treatment plant (WWTP) will be designed not to preclude
expansion to treat future average dry weather flows up to 360,000 gpd to meet the future needs
of the community, in accordance with the requirements established in the Ka'u Community
Development Plan Policy 120. The information provided in your message shows units with a
treatment capacity of 250 to 2,000 gallons per day. Thus, these systems do not have sufficient
capacity to accommodate the flows for the Pahala Large Capacity Cesspool Replacement project.
Use of a system of 250 to 2,000 gallons per day to treat the wastewater generated by each
privatelv-owned parcel in the community currently served by the LCCs would likely necessitate
siting multiple units within private property. As outlined in the Draft EA, Appendix B Section
7.5.4, issues associated with individual wastewater systems include:
• locating the treatment units within developed private parcels, many of which are small
(less than 10,000 square feet) and significantly improved,
• insufficient land area within developed private parcels to effectively use dispose of
treated effluent without impacting adjacent parcels, and
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii • 96826 • (808) 946-2277
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10349-01
Letter to Mr. Dale A. Loper
Page 2
March 6, 2020
• soil conditions and subsurface geology unsuitable for effluent disposal compliant with
Havvai'i Administrative Rules (HAR) Title 11 Chapter 62-34 requirements, potentially
necessitating the import of suitable fill soils or elevated mound systems.
This information will be repeated in the Final EA.
Additional issues include: access for construction equipment, ownership of the units, and
operation and maintenance of the units either by the County of Hawai'i on private property or by
individual property owners in this remote location.
This information will be added to the Final EA, section 2.8.2.
Based on the above, use of small capacity treatment units for this project does not appear to be a
practical and feasible option for the County.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
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LSOM OKAMOTO
RP0RAT4QN
10349-01 ref (29)
March 6, 2020
Ms. Ngaire Gilmour
ngaire. i oy (a), gmaii. com
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - October 17, 2018 10:30 a.m.
Dear Ms. Gilmour:
Thank you for your October 17, 2018 10:30 a.m. comment message regarding the County of
Hawai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Community Large Capacity Cesspool (LCC) Replacement project.
The Draft EA Section 6.2.2 discusses the Ka'u Community Development Plan (CDP): "Section
5 of the CDP prioritizes improvements in infrastructure, facilities, and services, including
Section 5.8 which applicable to .. .Environmental management facilities, including expanded
sewer lines, ...As you noted, Policy 120 is to "Extend the primary wastewater collection lines
in Pahala and Na'alehu so that infill development projects can connect wastewater systems built
for new subdivisions to the County systems."
The collection system will be consistent with Policy 120 as the improvements for the Pahala
(LCC) Replacement project have been designed not to preclude accommodating the Pahala
community. Similarly, the treatment and disposal facility has been designed not to preclude
accommodating the wastewater flows from the collection system from the Pahala community.
The Draft EA Section 2.2 describes the purpose of the Pahala Large Capacity Cesspool
Replacement project is to close the Pahala large capacity cesspools (LCC). The Draft EA Section
2.3.2 discusses the construction of a new sewer collection system in the Pahala community to
replace the existing system of substandard gravity lines that currently conveys sewage to the two
LCCs. As described in Section 6.2.1, the current collection system includes facilities located in
the backyards of many parcels. Where easements for the existing collection system aren't
accessible, the County must obtain permission from individual landowners to enter them,
through private property, to inspect, maintain, repair or replace existing sewer facilities: all
activities essential to an efficient, functioning system. As a result, the proposed new collection
system would consist of a total of approximately 12,150 linear feet (LF) (2.3 miles) of corrosion-
resistant polyvinyl chloride (PVC) piping located almost entirely within the right of way (ROW)
of eight public streets.
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
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10349-01
Letter to Ms. Ngaire Gilmour
Page 2
March 6, 2020
Also as outlined in the Draft EA, Section 2.3.2, the new collection system would be subject to
the Hawai'i County Code (HCC) Chapter 21, Sewers, specifically. Article 2 (Public Sewers),
Section 21-5, which states the following:
"(a) Owners of all dwellings, buildings, or properties used for human occupancy, employment,
recreation, or other purposes, which are accessible to a sewer are required at their expense to
connect directly with the public sewer within 180 days after date of official notice. "
Each adjacent lot will be provided with a lateral connection to the sewer main as required by
HCC and standards. Under the Preferred Alternative, the design of the new collection system
would extend between street intersections and include sewer service stub-outs (the lateral
connection to the sewer main) to the lot lines of adjacent properties, including the newly
accessible, to accommodate their eventual connection. Accordingly, to close the existing LCCs,
there will be additional properties in Pahala that would be required to connect to the new
wastewater collection system, at their expense, after it becomes operational. Such properties are
near the existing service area but are presently connected to individual wastewater systems. To
conform to the stated section of HCC, the respective, newly accessible property owners would be
responsible for the design, permitting and completion of sewer service connections between the
County stub-outs and improvements for stated uses on their property, as well as for the proper
closure of their individual wastewater systems. The Draft EA Figure 2.6 shows the area of the
community serviced by the current and proposed collection systems.
The above information will be repeated in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
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Honolulu, Hawaii S>6®26t
>V H.., CTi Di*f tfc MHMA COMMUNITY 1AHGf CAPACCTY CESSPOOL
(UU KtPLAClMtHl PROJECT
INFORMATIONAL MEETING, OGTOtf i 10, 3018
COMMENTS {C«tl»W*i|
, „.rr„ ^ .,-X^
Ka'jt homeowners who aw on the old plantation gaBg-osssp©fl>l$,
In 2007,. Cou iroisriiffftal Assessment for
NmMw ift4 ftftsla Villages large Capacity Cesspool Conversion Prefect, The
plan implements septic units for wastewater ireaiwtrij, Tfteti tfw Cmtntf
switched the plan without mmv the- iiiihnc. 1 he* staniiofwi the septic tank
system tnd started planning for a lagoon system and MMt planning isr a lagoon
system without public review.
Earl Matsukawa
Wilson Oka mono Corporation
ISO? South Baretama Street, Suite 400
WILSON OKAMQlYe
n»f south BMWttM Smrn, Sun* *oo
mm
T (l&tJIMMS? f ffltilli»».a-2i3
* imiBMsasiassMisfcae
Allimlion; Mr, &M Mrtiutow
SUBJECT: DRAFT EA: Pj&MALA COMMUNITY
LAMSE CAPACITY CESSPOOL. ftCC|
REPLACEMENT PROJECT
INFORMATION MEETING. OCTOBER 10,:®«
H >t . !•' «INT:
R- ?-0 ' I 5 '
-------
Graft EnvifWIffteitM Anstwwili W iitv
PlOfKtMtrt C4n,rrH,ailK Urj|<. C,ip,n ily U^^|K»l:(tCC|Rtpli«««*iitPirtll««t
PuMte 1»rt®t»18
PERSONAL NOTES
LSOM OKAMOTO
BPORATIQK
'»i'OS5 .*i «
10349-01 ref (30)
March 6, 2020
Mr. Jerome Warren
P.O. Box 951
Naalehu, Hawaii 96722
Subject: Draft Environmental Assessment (EA)
Pahala Large Capacity Cesspool Replacement Project
District of, Ka'u, Havvai'i
Response to Comment - October 19, 2018
Dear Mr. Warren:
Thank you for your October 19, 2018 comment letter regarding the County of Havvai'i
Department of Environmental Management Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement project. Our response follows:
The Draft EA, Section 2.8.2(a), discusses use of a community septic tank as follows:
"Community Septic Tank. Based on current design criteria and current flow projections, an
approximately 800,000-gallon community septic tank would be necessary to provide the
extended detention times needed to optimize treatment performance, to avoid the need for
frequent septage pumping, and to account for peak flow rates. A community septic tank of this
size would require pumping on a 3-vear interval. Septic tanks produce hydrogen sulfide, reduced
sulfur compounds, and other odorous gases; a community septic tank would concentrate these
emissions to a single point source, requiring treatment with a dual-stage scrubber to avoid
nuisance odor conditions. More significantly, a community septic tank would not be capable of
achieving the effluent quality standards (less than 30 mg/L of both BOD5 and TSS) specified in
HAR 11-62-23.1. Therefore, use of a community septic tank is not considered to be feasible."
Further details for the use of community septic tanks are also provided in the Draft EA,
Appendix B, Section 7.5.1 and 7.5.2 including the need for a DOH variance from HAR 11-62-
23.1 requirements (which must be renewed every five years), and the need to provide for
wastewater treatment and disposal capacity to meet the rest of the community's current and
future needs.
The Draft EA Section 2.9 discusses the relationship between the current project and the 2007
Final EA for the Naalehu-Pahala Large Capacity Cesspool (LCC) Conversion project. As stated
in Section 2.9:
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
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10349-01
Letter to Mr. Jerome Warren
Page 2
March 6, 2020
"After the issuance of the Final EA and Negative Declaration FONSI in 2007, the County
conducted additional study and evaluation of the proposed LCC conversion project. The
County eventually concluded that the LCC conversion project described in the 2007 Final
EA would not meet the need to provide a collection system and a treatment and disposal
facility, close the LCCs, and provide for the future needs of the Pahala community. This
determination was based on several factors..."
The Draft EA Section 2.8.2 (a) discusses the conversion of LCC 1 to a seepage pit for septic tank
effluent disposal, as documented below:
• "Converting LCC to Seepage Pit. Converting LCC 1 to a seepage pit regulated as an
injection well (LCC 2 could not be converted as it is on private land) would lead to numerous
potential compliance issues with HAR 11-23-07, which regulates injection wells. The
condition and structure of LCC 1 is unknown, and HAR 11-62-25 requires all new and
proposed effluent disposal systems are required to have a backup system. No such system
could be feasibly constructed as new injection wells are not allowed."
Pahala is located mauka of the UIC line, as such conversion of one or more LCC to a seepage pit
for disposal of septic tank effluent would be subject to HRS 340E and Hawai'i Administrative
Rules Title 11, Department of Health, Chapter 23, Underground Injection Control (HAR Chapter
23). In 2018, H.B. No, 1934, H.D. 1, S.D. 2 was enacted as Act 131 which amended Section
340E-2 to add:
"The director shall promulgate regulations establishing an underground injection control
program. Such program shall prohibit any underground injection which is not authorized by
a permit issued by the director; provided that the director shall not issue permits for the
construction of sewage wastewater injection wells unless alternative wastewater disposal
options are not available. feasible. or practical;"
The Draft EA Section 2.8.2 (a) also discusses the leachfield option considered for septic tank
effluent disposal as outlined below: "Leachfield Disposal. To meet DOH's leachfield design
criteria, a minimum of 30 acres of land would be required to meet loading rate and redundancy
requirements. Achieving even distribution of effluent over a leachfield of this size would be
challenging. Therefore, leachfield disposal is not considered to be feasible."
The above information will be repeated in the Final EA.
The Draft EA Section 7.0 provides information regarding the community outreach program for
the current proposed action, including meetings starting in December 2017.
The Draft EA Section 2.1.4, History of Wastewater Management in Pahala, will be expanded in
the Final EA to provide the following additional information:
10349-01
Letter to Mr. Jerome Warren
Page 3
March 6, 2020
Field investigation conducted on February 4, 2009 on the property conveyed by C. Brewer for a
treatment disposal site in Na'alehu showed unacceptable percolation rates, making converted
seepage pit or leach field options less desirable in this area.
On December 13, 2008 a community meeting sponsored by Councilman Guy Enriques was held
at the Na'alehu Community Center to discuss the Na'alehu and Pahala Large Capacity Cesspool
Replacement project. As part of the meeting, an informational handout prepared by the County's
Wastewater Division stated that adequate land for the treatment and disposal system had not
been identified in Pahala. A preliminary location for a treatment and disposal site below the Old
Pahala Mill site was not acceptable due to reports of archaeological sites in the area, and outlined
the benefits of a lagoon type treatment and disposal system. At an April 25, 2010 community
meeting at the Pahala Community Center, which was also sponsored by Councilmember
Enriques, the meeting informational handout stated the County was investigati
ng available properties for siting wastewater treatment disposal facility in Pahala. The handout
also stated that all properties accessible to the new sewer system would be required to connect in
accordance with Hawaii County Code Chapter 21.
Also, although not specific to the Pahala project, it was stated at a July 22, 2016 2:00 p.m.
presentation at the Na'alehu Community Center that the County had purchased the parcel
containing the makahiki grounds in Na'alehu for a lagoon type wastewater treatment leach field
disposal system.
The Draft EA Section 7 provides information regarding the five "talk story" sessions held in
December 2017. Section 7 identifies the various issues, concerns, environmental impacts and
mitigations measures which were addressed in the Draft EA.
On September 26, 2018, a public notice was published in both the Hawaii Tribune Herald and
West Hawaii Today to advertise the October 10, 2018 public information meeting conducted by
the County in Pahala at the Ka'u Gym Multi-Purpose Conference Room to discuss the
availability of the Draft EA and process for submitting comments. A public notice was also
published in the October 1, 2018 online and print editions of the Ka'u Calendar and made
available on the Ka'u News Briefs web site http://kaunewsbriefs.blogspot.com.
All materials circulated, posted and published for the October 2018 meetings included the
electronic link to the Draft EA at http://health.hawaii.gov/oeqc/.
The Draft EA was made available online on the County of Hawai'i and EPA websites and in
public libraries in Na'alehu and Pahala beginning on September 23, 2018. Upon public request,
11 printed copies of the Draft EA were made available at both the Na'alehu and Pahala libraries
on November 7, 2018. The County's transmittal requested the library make the copies available
for checkout. The Draft EA was also posted on the County of Hawaii and EPA websites at:
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10349-01
Letter to Mr. Jerome Warren
Page 4
March 6, 2020
http://recorcte.co.hawau.hi.us/webliiik/l/edoc/96064/Pahala%20FINAL%20PRAFT%20EA
%20and%20Appendices 508 9-ll-18.pdf
https://www.epa.gov/uic/proposed-pahala-community4arge-capacity-cesspool--replacemetit-
project-draft-enviromnental
At the October 10, 2018, public information meeting, the County provided staff to personally
assist commenters in preparing written comments on the Draft EA. In addition, during this
meeting, the County identified community volunteers attending the meeting who were proficient
in Hawaiian, Tagalog, and English to assist anyone who identified as needing assistance in
providing written comments on the Draft EA.
The public notice also stated that a second part of the meeting on October 10, 2018 would
address Section 106 of the National Historic Preservation Act (NHPA) involving consultation
with Native Hawaiian Organizations and Native Hawaiian descendants with ancestral lineal or
cultural ties to, cultural knowledge or concerns for, or cultural religious attachment to the
proposed project area. Eight persons placed their names on a sign-in sheet to contribute during
the Section 106 part of the meeting; however, no comments or information from the public were
forthcoming during this meeting.
Appropriate portions of this historical information related to public outreach regarding closure of
the Pahala LCCs will be included in the Section 7 of the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
I _ ,
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-------
['/'."[• Ill,
^rasrwml)? lire srogfe- CpfRiiy, ilciwn tfiRwygfi lis? ycncraiHM*, wk: el'k'ii iwwi'iig
multiple .pnetams. Far if* Coiiii}- la mmki pewtixinf these owners (weave they
were I* iriii#f*!*fca! system* fcit %vs« inslniie.il iegntly wili only teiaf c»ri(iwib«i«*ii
i«*t epjwsilwn to a flmi tJmt, in the Imp wi, will k beneficial. Iti» vwM wws ihe
County to locnic ajjlpitl tor ihe p«i#i3t in tie communii>¦. unltier IIisiii »l teiti>$ pemximd
,r;,, I.
c) 1 he Cwmiy s#»ti« mmmt m »ll «Mi«f ten' wnli
2, It not Alagptiling: i# fcc informed that there mil It no indcjxnfeM e*tiy mmixt for As xwiitt
HmSfcy. Solst, «W m*l methane me nil powibililies, l»'t j»w "HicwkSog vp to (tl'liprr is net
looking » in? fiiftint. Hwjc look fccp»u4 the "gilif for .energy.
3 !%*» nmmikt the suggestion mute m tie meeting co HMCrtt to kxA at Ite posstltiity of
He lilfliwsy thai
LSOM OKAMOTO
BPORATIQK
'»i'OS5 .*i «
10349-01 ref (31)
March 6, 2020
Ms. Ngaire Gilmour
ngaire. i oy (a), gmaii. com
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - October 20, 2018 12:40 p.m.
Dear Ms. Gilmour:
Thank you for your October 20, 2018 12:40 p.m. comment message regarding the County of
Hawai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our responses follow:
1.
a) The Draft EA Section 2.2 describes the purpose of the Pahala Large Capacity Cesspool
Replacement project is to close the Pahala large capacity cesspools (LCC). The Draft EA
Section 2.3.2 discusses the construction a new sewer collection system in the Pahala
community to replace the existing system of substandard gravity lines that currently
conveys sewage to the two LCCs. As described in Section 6.2.1, the current LCC
collection system includes lines located the backyard of many parcels. Where easements
for the existing collection system aren't accessible, the County must obtain permission
from each landowner to enter them, through private property, to inspect, maintain, repair,
or replace existing sewer facilities: all activities essential to an efficient, functioning
system. As a result, the proposed new collection system will be located within the public
street rights-of-way and to close the LCCs, there will be parcels that become "newly
accessible" to the collection system. The collection system is not being expanded under
the proposed action beyond the area needed to close the LCCs. This information will be
repeated or included in the Final EA.
b) The Draft EA Section 2.3.2 discusses Hawai'i County Code, Chapter 21, specifically,
Article 2 (Public Sewers), Section 21-5, which states the following:
"(a)Owners of all dwellings, buildings, or properties used for human occupancy,
employment, recreation, or other purposes, which are accessible to a sewer are required
at their expense to connect directly with the public sewer within 180 days after date of
official notice.
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
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10349-01
Letter to Ms. Ngaire Gilmour
Page 2
March 6, 2020
The financial impact of the project on individual newly accessible property owners was
raised by the community during the December 2017 public meetings as summarized in
Section 7 of the Draft EA. Although not required by Hawaii Administrative Rules
(HAR) Title 11, Chapter 200, DEM voluntarily convened two additional public meetings
on October 9, 2018 and March 21, 2019 to gain further input from newly accessible
property owners and present funding options for them to pursue.
This information will be added to the final EA Section 7.
c) County Council approval would be required to grandfather or fund connections of newly
accessible properties to the new collection system.
2.
Although the project does not currently include alternative energy systems such as photovoltaic,
solar or wind power as a total replacement to the HELCO grid, feasible alternatives utilizing
energy systems can be added in the future if prioritized and funded by County Council. A source
of methane is not currently available in the Pahala area, natural gas distribution infrastructure is
not in place in this remote location, and the Proposed Alternative, utilizing natural, low energy,
treatment systems does not provide for wastewater-related methane production and capture.
3.
The Draft EA Section 2.7 describes the site selection process, including the factors and their
relative weights used to evaluate the various sites. Further, Section 2.7 describes the twenty-one
criteria within four general categories (environmental, social and cultural; location and site; land
use and availability; and collection system and service area) that were established and defined for
the analysis. The Draft EA Appendix B, Section 8, provides additional information regarding
the site selection process. As a result of this process, the County identified three sites (Sites 7, 8,
and 9) as reasonable alternatives for construction of the wastewater treatment and disposal
facility under the Proposed Action. The final scores for Sites 7, 8, and 9 were 4.33, 4.06, and
4.10 respectively, out of a total possible score of 5. Based on this analysis. Site 7 was selected as
the Preferred Alternative. The site is easily accessible, has good soils for a land application
system, and is close to the existing LCCs.
The Draft EA Section 2.5 describes Site 9, which is south (makai) of the Preferred Alternative
Site 7. As outlined in Appendix B Section 8, Site 9 earned a lower ranking than Site 7 for the
following criteria: presence of and or proximity to archaeological cultural sites, existing vehicle
access, power and potable water availability, and distance from the area of the wastewater
collection system. Site 7 had a lower ranking than Site 9 in one category: topography. With the
distance between the two sites less than 300 feet, they were ranked equally for the criteria of
proximity of treatment units to existing occupied buildings.
The Draft EA Sections 2.5 and 2.7 provide information as to the issues related to the use of Site
9. An unnamed stream near the upper portion of the parcel could affect the selected
10349-01
Letter to Ms. Ngaire Gilmour
Page 3
March 6, 2020
configuration of the wastewater treatment facility and the land application groves. Potentially, to
maximize energy efficiency by taking advantage of gravity flow, the headworks, lagoons and the
subsurface constructed wetlands could be sited in the upper portion of the site, or the area closest
to the highway. In addition, since the site is located across Mamalahoa Highway from the Pahala
community, it would require construction of piping and other utilities within the highway ROW
and approval by the State of Hawai'i Department of Transportation. Site 9 would require
additional access roads to facilitate both construction and operation of the treatment and disposal
facility and a slightly longer transmission line given its increased distance from the existing
LCCs.
The above information will be repeated in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
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-------
WILSON OKAMOTO
COUP T t § II
10349-01
March 6, 2020
ref (33)
Mr. Edward Andrade, Jr.
P.O. Box 514
Pahala, Hawaii 96777
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - October 19, 2018
Dear Mr. Andrade:
Thank you for your October 19, 2018 comment letter regarding the County of Hawai'i
Department of Environmental Management Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement project. Our responses follow:
A.
The County is aware of two existing culverts that allow stormwater to flow across the
Mamalahoa Highway in the vicinity of the project. The first is a box culvert located at the
intersection with Maile Street that conveys stormwater under the highway. The second culvert is
located approximately 600 feet east of the Maile Street intersection and was used to convey
sugar mill flume water across the highway for disposal.
The Draft EA Section 3.9.1 (a) states:
"The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM),
Community Panel No. 155166 1800F, effective date September 29, 2017 shows that most of
the Pahala area is located in Zone A', which designates areas determined to be outside the 0.2-
percent annual chance (500-vear) floodplain. A small portion of the community of Pahala,
including some land within the collection system project site, is located within Zone X—
Other Flood Areas, indicating areas within the 0.2-percent annual chance (500-year)
floodplain, or areas with a 1-percent annual chance of flooding with average flood depths
less than 1 foot.
According to the FIRM, both existing LCCs are also located within ZoneX. However, LCC-1
is very close to the edge of the 500-year floodplain.
On April 16, 2018, in response to the pre-assessment notification, the State of Hawai'i
Department of Land and Natural Resources Engineering Division stated the responsibility for
conducting research as to the flood hazard designation for the project site lies with the project
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
10349-01
Letter to Mr. Edward Andrade, Jr.
Page 2
March 6, 2020
proponent. Also on April 16, 2018 and in response to the pre-assessment notification, the
County of Hawai'i Department of Public Works confirmed that the proposed treatment and
disposal project site at Site 7 is designated as Zone X on the FIRM and is outside the 500-
year floodplain."
The relevant FIRM panel is reproduced in Appendix B as Figure 4-13.
This information will be repeated in the Final EA.
The Draft EA Section 3.23.2 (a) states:
"The proposed wastewater treatment and disposal facility would include an on-site drainage
system to address stormwater surface runoff created by new impervious surfaces within the
facility. The site would include a system to collect runoff via grated inlets or swales, and
flows would be conveyed to on-site drainage detention systems, such as subsurface linear
infiltration or depressed detention basins."
This information will be repeated in the Final EA.
The preferred alternative (Site 7) slopes from approximately north to south (mauka to makai)
such that, during rain events, surface flows pass through the existing orchard to the southern
(makai) end where the flows eventually drain through the culvert located at the Maile Street-
Mamalahoa Highway intersection to the areas below (makai) the highway. Most of the land
surface area below the existing macadamia nut orchard contains little to no vegetation to absorb
or slow these flows. The gradient of Site 7 and surrounding area results in this natural pattern of
surface flows which also existed when the area was planted in sugar cane and is not considered
flooding.
Based on the roadway flooding concerns expressed by the community during the Pahala public
meetings held in December 2017 and October 2018, the State of Hawai'i Department of
Transportation (DOT) Hawai'i District office was contacted to discuss drainage at the treatment
and disposal facility project site and the culvert at the Maile Street and Mamalahoa Highway
intersection. On February 20, 2019, the District office confirmed via telephone that the DOT
owns and maintains the culvert at the Maile Street intersection, and that they have no record of
the roadway being inundated by stormwater drainage during precipitation events at that location.
Stormwater runoff generated mauka of the treatment and disposal facility project site will be
directed around the perimeter of the site via diversion swales that will convey flow back to the
existing drainage pattern that flows to the existing culvert at Maile Street. During heavy rain
events, stormwater may temporarily back up behind the culvert. There will be no changes to this
culvert and the proposed treatment and disposal facility will not be located within the area of the
culvert.
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10349-01
Letter to Mr. Edward Andrade, Jr.
Page 3
March 6, 2020
As stated in the Draft EA, the on-site stormvvater management system will meet the requirements
of Hawai'i County Code (HCC), Chapter 27 Floodplain Management. Section 20, Standards for
subdivisions and other developments (e) which mandates a site drainage plan to "comply with
sections 27-20(a) and (b) and section 27-24, and shall include a storm water disposal system to
contain run-off caused by the proposed development, within the site boundaries, up to the
expected [design] storm event, as shown in the Department of Public Works Storm Drainage
Standards.
To meet the requirements of HCC, Chapter 27, Section 20 (f), the project "shall not alter the
general drainage pattern above or below the development". Thus, for the HCC design storm
event, no increase in flow amount will be directed to either of the culverts at the highway as a
result of the site development. A drainage report will be prepared during the design process to
evaluate the improvements necessary to comply with HCC Chapter 27 requirements.
The wastewater treatment processes will be designed to accommodate the associated peak flows,
including precipitation that falls on the area occupied by the aerated lagoon treatment system.
The Draft EA Appendix B, Section 2.2 outlines the anticipated peak wastewater flows from the
community, based on the applicable flow standard. The Draft EA Section 2.3.1 states the aerated
lagoons will be lined with liners to prevent water seepage through the bottom and sides of the
lagoons. The Draft EA Appendix B, Section 5.3 shows the operational freeboard that will be
available to contain and to equalize lagoon flows. In addition, the slow-rate land application
groves will be designed to completely contain both peak effluent flows and precipitation from a
100-vear, 24-hour storm event. A geotechnical engineering assessment of berm stability will be
conducted during the design process. The tree groves will be designed in accordance with the
EPA's "Process Design Manual, Land Treatment of Municipal Wastewater Effluents". Effluent
will be applied at a hydraulic loading rate that is a small percentage of the percolation rate of the
soil, ensuring sufficient capacity for assimilation of peak effluent flow rates and precipitation
from the design storm event.
This information will be included in the Final EA.
B.
The Draft EA Section 3.15 references a November 2016 archaeological field inspection report
that states, while the historical ground modifications have likely limited the archaeological
potential of the site, the discovery of both pre- and post-contact surface artifacts within the 42.5-
acre parcel (which includes Site 7), as well as evidence from plantation-era documents that the
opening of a lava tube containing human remains once existed in the southeastern corner of the
parcel, indicate that further archaeological studies may be necessary. The Final EA will clarify
that the report also stated it would be advisable to limit the development footprint to exclude the
southeastern corner of the 42.5-acre parcel. This area, which is presently not used as a
macadamia nut orchard, but forms part of the macadamia nut processing plant complex, is the
location of a known (but sealed) lava tube opening that local informants have indicated is linked
10349-01
Letter to Mr. Edward Andrade, Jr.
Page 4
March 6, 2020
to tubes that possess traditional human burials. Further, by excluding this section of the parcel, it
will be possible to avoid at least one known historic property. The Draft EA Figure 2.3 provides
the Preliminary Site Plan for the new treatment and disposal facility, shows the 14.9-acre project
site has been developed to exclude the area in the southeastern corner as the location of the
sealed lava tube opening.
Between September 18, 2018 and January 10, 2019, a team of qualified archaeologists conducted
a pedestrian survey of the proposed project site and completed subsurface trenching to determine
the presence of archaeological resources. The work was undertaken in accordance with the State
of Hawaii Department of Land and Natural Resources State Historic Preservation Division
(SHPD) requirements, with the archaeological inventory survey (AIS) approach accepted by
SHPD in their August 20, 2018 letter. The results of the survey and subsurface trenching
showed no burials or lava tube openings were identified on site. The AIS submitted to SHPD in
March 2019 documents that a sealed lava tube opening is located east of the proposed
wastewater treatment and disposal facility project site, outside the proposed property boundary
and outside of the area of potential effect considered in consultation with SHPD as required by
the National Historic Preservation Act.
The complete document is available for download from the County's website
at: http://records,co.hawan.hi.us/weblink/l/edoc/100962/Dfaft%20ArcheQlogieal%20Inventory~
%20Survcy%20-%20Pahala%20WWTPH.20and%20Sewer%20Systcm.Ddf
A geophysical survey of the proposed area will be performed during detailed design with the
specific intent to locate subsurface voids (such as lava tubes) present beneath the site that may
impact design and construction of the new wastewater treatment, disposal and collection
systems.
This information will be included in the Final EA.
C.
The Draft EA Section 3.14.2 states:
"Wastewater treatment plants can be a source of nuisance odors to the surrounding
community if not properly designed or operated. Typically, nuisance odors are most
commonly associated with anaerobic (without oxygen) conditions and with processing of
residual solids. Incoming raw sewage flows to the proposed wastewater treatment and
disposal facility would first be routed to the headworks, which is the facility where the
solids are removed from the flows.
To mitigate potential nuisance odors, the headworks would be equipped with an odor
control system with a granulated activated carbon (GAC) scrubber to remove odors. A
package GAC scrubber passes the odorous air through a bed of activated carbon, which
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10349-01
Letter to Mr. Edward Andrade, Jr.
Page 5
March 6, 2020
adsorbs the odorous constituents within the pore spaces of the carbon. The County
currently operates GAG scrubbers at other facilities, and it has been proven to be an
effective means of odor control both locally and nationwide. The treatment lagoons
would be equipped with mechanical aerators capable of maintaining sufficiently aerobic
(with oxygen) conditions within the water column, which would prevent nuisance odor
conditions from occurring. The disposal groves would be irrigated with fully-treated and
aerobic secondary effluent from the treatment process; irrigation with secondary effluent
is not associated with development of nuisance odor conditions."
This information will be included in the Final EA Section 3.14.2.
D.
The Draft EA Section 2.7 describes the site selection process, including the factors and their
relative weights used to evaluate the various sites. Further, Section 2.7 describes the twenty-one
criteria within four general categories (environmental, social and cultural; location and site; land
use and availability; and collection system and service area) that were established and defined for
the analysis. The Draft EA Appendix B, Section 8, provides additional information regarding the
site selection process. As a result of this process, the County identified three sites (Sites 7, 8, and
9) as reasonable alternatives for construction of the wastewater treatment and disposal facility
under the Proposed Action. The final scores for Sites 7, 8, and 9 were 4.33, 4.06, and 4.10
respectively, out of a total possible score of 5. Based on this analysis. Site 7 was selected as the
Preferred Alternative. The site is easily accessible, has good soils for a land application system,
and is close to the existing LCCs.
The Draft EA Section 2.5 describes Site 9, which is south (makai) of the Preferred Alternative
Site 7. As outlined in Appendix B Section 8, Site 9 earned a lower ranking than Site 7 for the
following criteria: presence of and or proximity to archaeological cultural sites, existing vehicle
access, power and potable water availability, and distance from the area of the wastewater
collection system. Site 7 had a lower ranking than Site 9 in one category: topography. With the
distance between the two sites less than 300 feet, they were ranked equally for the criteria of
proximity of treatment units to existing occupied buildings.
The Draft EA Sections 2.5 and 2.7 provide information as to the issues related to the use of Site 9.
An unnamed stream near the upper portion of the parcel could affect the selected configuration of
the wastewater treatment facility and the land application groves. Potentially, to maximize energy
efficiency by taking advantage of gravity flow, the headworks, lagoons and the subsurface
constructed wetlands could be sited in the upper portion of the site, or the area closest to the
highway. In addition, since the site is located across Mamalahoa Highway from the Pahala
community, it would require construction of piping and other utilities within the highway ROW
and approval by the State of Hawai'i Department of Transportation. Site 9 would require
additional access roads to facilitate both construction and operation of the treatment and disposal
10349-01
Letter to Mr. Edward Andrade, Jr.
Page 6
March 6, 2020
facility and a slightly longer transmission line given its increased distance from the existing
LCCs.
This information will be included in the Final EA.
On September 26, 2018, a public notice was published in both the Hawaii Tribune Herald and
West Hawaii Today which stated a public meeting was to be held on October 10, 2018 for the
Pahala Community Large Capacity Cesspool Replacement Project Draft EA. A public notice
was also published in the October 1, 2018 print and online editions of the Ka 'u Calendar and
made available on the Ka'u News Briefs web site http://kaunewsbriefs.blogspot.com. Fliers
were also posted in public venues such as the community shopping center, realtor office, grocery
store, library, and the Pahala Community Center.
On September 10, 2018, letters containing information on the availability of the Draft EA, the
comment period, and the October 10, 2018 meeting were mailed to all property owners on record
adjacent to the proposed collection system. This direct mailout included an invitation from DEM
to workshops conducted prior to the October 10 public meeting. The workshop for owners
served by C. Brewer lines was held on October 8, and the mailout for this meeting also included
anyone with a current sewer account. The workshop for owners of newly accessible properties
was convened on October 9. In addition to the direct mailout, online announcements for the
October 8 and 9 workshops were available on the Ka'u News Briefs website.
This information will be included in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
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-------
WILSON OKAMOTO
COUP T t § II
10349-01
March 6, 2020
ref (41)
Ms. Sophia Hanoa
sohia.hatioa@aol.com
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment - October 23, 2018 4:47 p.m.
Dear Ms. Hanoa:
Thank you for your October 23, 2018 4:47 p.m. comment message regarding the County of
Havvai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Community Large Capacity Cesspool Replacement project. Our responses follow:
1. a. b. c. d. The Draft EA Section 7 documents the 5 public meetings held in Pahala December
12, 13 and 14, 2017 to discuss the Pahala Large Capacity Cesspool Replacement project. As
documented in the Draft EA, the community outreach program for the current project was
designed as "talk story" sessions to optimize community conversations in informal sessions.
Further, as documented in the Draft EA, invitations and announcements for the talk story
sessions were intended to reach all audiences, as follows:
• Property owners with C. Brewer lines on their property were mailed letters from DEM
inviting them to these sessions. The letters included stamped, mail-in postcards to
facilitate the RSVP process.
• Fliers were hand-delivered to "newly-accessible" properties.
• Organizational leaders were provided copies of fliers announcing meetings and asked to
circulate among their members.
• Fliers were posted in public venues, such as the post office, the Pahala Community
Center and the Ka'u Hospital.
• Several online announcements were included in Ka'u News Briefs available at
http://kaunewsbriefs.blogspot.com.
This information will be repeated in the Final EA.
On September 10, 2018, letters containing information on the availability of the Draft EA, the
comment period, and the October 10, 2018 meeting were mailed to all property owners on record
adjacent to the proposed collection system. On October 26, 2018 letters were mailed to property
owners on record adjacent to the proposed collection system informing them of the extension of
the public comment period to December 10, 2018.
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
10349-01
Letter to Ms. Sophia Hanoa
Page 2
March 6, 2020
On September 26, 2018, a public notice was published in both the Hawaii Tribune Herald and
West Hawaii Today which stated a public meeting was to be held on October 10, 2018 for the
Pahala Community Large Capacity Cesspool Replacement Project Draft EA. A public notice
was also published in the October 1, 2018 online and print editions of the Ka 'u Calendar and
made available on the Ka'u News Briefs web site http://kaunewsbriefs.blogspot.com.
This information will be included in the Final EA.
The Draft EA Section 7 will be revised to add that, on March 21, 2019, the County held another
meeting in Pahala which included a presentation to provide information on financing options
available to owners of parcels which would become accessible to the County collection system.
The purpose of the meeting was to fulfill a County commitment made in October, 2018 to
research financing options available to the newly accessible residents of the Pahala Community
by March, 2019.
1. e. On, November 7, 2018, the County of Havvai'i hand delivered eleven copies of the Draft
EA to the Pahala Public Library and eleven copies to the Na'alehu Public Library. The County's
transmittal requested the library make the copies available for checkout. This information will
be included in the Final EA Section 7.
All materials circulated, posted and published for the October 2018 meetings included the
electronic link to the Draft EA at http://health.hawaii.gov/oeqc/. The Draft EA was also posted
on the County of Hawaii and EPA websites at:
• http://records.co.hawaii.hi.us/weblink/ l/edoc/96064/Pahala%20FINAL%20DRAFT%20
EA%20and%20Appendices 508 9-ll-18.pdf
• https://www.epa.gov/mc/proposed-paliala-commumtv-large-capacity-cesspool-lcc-
replacement-project-draft-environmental
This information will be included in the Final EA.
2. a. The Draft EA Section 3.15 references a November 2016 archaeological field inspection
report that states, while the historical ground modifications have likely limited the archaeological
potential of the site, the discovery of both pre- and post-contact surface artifacts within the 42.5-
acre parcel (which includes Site 7), as well as evidence from plantation-era documents that the
opening of a lava tube containing human remains once existed in the southeastern corner of the
parcel, indicate that further archaeological studies may be necessary. The Final EA will clarify
that the report also stated it would be advisable to limit the development footprint to exclude the
southeastern corner of the 42.5-acre parcel. This area, which is presently not used as a
macadamia nut orchard, but forms part of the macadamia nut processing plant complex, is the
location of a known (but sealed) lava tube opening that local informants have indicated is linked
to tubes that possess traditional human burials. Further, by excluding this section of the parcel, it
-------
10349-01
Letter to Ms. Sophia Hanoa
Page 3
March 6, 2020
will be possible to avoid at least one known historic property. The Draft EA Figure 2.3, which
provides the Preliminary Site Plan for the new treatment and disposal facility, shows the 14.9-
acre project site has been developed to exclude the area in the southeastern corner identified as
the location of the sealed lava tube opening.
Between September 18, 2018 and January 10, 2019 a team of qualified archaeologists conducted
a pedestrian survey of the proposed project site and completed subsurface trenching to determine
the presence of archaeological resources. The work was undertaken in accordance with the State
of Hawaii Department of Land and Natural Resources State Historic Preservation Division
(SHPD) requirements, with the archaeological inventory survey (AIS) approach accepted by
SHPD in their August 20, 2018 letter. The results of the survey and subsurface trenching
showed no burials or lava tube openings were identified on-site. The AIS submitted to SHPD in
March 2019 documents that a sealed lava tube opening is located east of the proposed
wastewater treatment and disposal facility project site, outside the proposed property boundary,
and outside of the area of potential effect considered in consultation with SHPD as required by
the National Historic Preservation Act.
The complete document is available for download from the County's website
at: http://records,co.hawan.hi.us/weblink/l/edoc/100962/Dfaft%20Archeologieal%20Inventory
%20Siirvev%20-%20Pahaia%20WWlP%20and%20Sewer%20Svstem.pdf
A geophysical survey of the proposed project area will be performed during detailed design with
the specific intent to locate subsurface voids (such as lava tubes) present beneath the site that
may impact design and construction of the new wastewater treatment, disposal and collection
systems.
This information will be included in the final EA.
On April 25, 2010, a community meeting sponsored by Councilman Guy Enriques was held at
the Pahala Community Center to discuss the Na'alehu and Paha la Large Capacity Cesspool
Replacement project. As part of the meeting, an informational handout prepared by the County's
Wastewater Division provided a brief history of the project documenting that, in 2004, Mayor
Kim's office used a ballot system to get input from property owners regarding different
wastewater treatment disposal alternatives for those property owners connected to the LCCs who
would no longer be served by the C. Brewer system after LCC closure. As reported in the Draft
EA Section 2.1.4, 87 percent of the returned ballots were in favor of the installation of a new
sewer collection system and a treatment and disposal system to be operated and maintained by
the County. The handout indicated that Mayor Kim's office advised the property owners the
County would move forward with new systems for Na'alehu and Pahala on November 5, 2004.
Additionally, the handout stated public meetings were held in both Na'alehu and Pahala in
November 2006, to discuss the wastewater system alternatives. The handout included that
adequate land for the treatment and disposal system had not been identified in Pahala. The
10349-01
Letter to Ms. Sophia Hanoa
Page 4
March 6, 2020
handout also stated that all properties accessible to the new sewer system would be required to
connect in accordance with Hawaii County Code Chapter 21.
2. b. As shown in Figure 2.3 the 14.9-acre treatment and disposal facility project site does not
extend into Maile Street. Similarly, Figure 2.3 shows the 14.9-acre treatment and disposal
facility does not extend into Mamalahoa Highway. The site fencing will not extend into the
Maile Street or Mamalahoa Highway rights-of-way. The Draft EA Figure 2.3 shows the
intersection of Maile Street and Mamalahoa Highway lies at about 580 feet above mean sea level
(MSL). Figure 2.3 will be repeated in Final EA.
The Draft EA Figure 2.3 shows the intersection of Maile Street and Mamalahoa Highway lies at
about 580 feet above mean sea level (MSL). The Draft EA Figure 2.2 shows the Pa'au'au Gulch
crosses under Mamalahoa Highway near the hospital about 0.88 miles north of that intersection
and lies at approximately 780 feet MSL or about 200 feet higher in elevation than the culvert at
the Maile Street and Mamalahoa Highway intersection.JDue to this distance and the elevation
difference, surface flows at Site 7 would not affect the gulch. Similarly, the Kaimani Street and
Mamalahoa Highway intersection lies about 0.84 miles north of the proposed facility site and at
about 780 feet MSL. Surface flows at the facility would also not affect that intersection. Figures
2.2 and 2.3 will be repeated in the Final EA.
3. The Draft EA Section 2.7 describes the site selection process, including the factors and their
relative weights used to evaluate the various sites. Further, Section 2.7 describes the twenty-one
criteria within four general categories (environmental, social and cultural; location and site; land
use and availability; and collection system and service area) that were established and defined for
the analysis. The Draft EA Appendix B, Section 8, provides additional information regarding
the site selection process. As a result of this process, the County identified three sites (Sites 7, 8,
and 9) as reasonable alternatives for construction of the wastewater treatment and disposal
facility under the Proposed Action. The final scores for Sites 7, 8, and 9 were 4.33, 4.06, and
4.10 respectively, out of a total possible score of 5. Based on this analysis, Site 7 was selected as
the Preferred Alternative. The site is easily accessible, has good soils for a land application
system, and is close to the existing LCCs.
The Draft EA Section 2.5 describes Site 9, which is south (makai) of the Preferred Alternative
Site 7. As outlined in Appendix B Section 8, Site 9 earned a lower ranking than Site 7 for the
following criteria: presence of and or proximity to archaeological cultural sites, existing vehicle
access, power and potable water availability, and distance from the area of the wastewater
collection system. Site 7 had a lower ranking than Site 9 in one category: topography. With the
distance between the two sites less than 300 feet, they were ranked equally for the criteria of
proximity of treatment units to existing occupied buildings.
The Draft EA Sections 2.5 and 2.7 provide information as to the issues related to the use of Site 9.
An unnamed stream near the upper portion of the parcel could affect the selected configuration of
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Letter to Ms. Sophia Hanoa
Page 5
March 6, 2020
the wastewater treatment facility and the land application groves. Potentially, to maximize energy
efficiency by taking advantage of gravity flow, the headworks, lagoons and the subsurface
constructed wetlands could be sited in the upper portion of the site, or the area closest to the
highway. In addition, since the site is located across Mamalahoa Highway from the Pahala
community, it would require construction of piping and other utilities within the highway ROW
and approval by the State of Hawai'i Department of Transportation. Site 9 would require
additional access roads to facilitate both construction and operation of the treatment and disposal
facility and a slightly longer transmission line given its increased distance from the existing
LCCs.
This information will be included in the Final EA.
3. a. Mr. Andrade has provided comments to the Draft EA.
The County is aware of two existing culverts that allow stormwater to flow across the
Mamalahoa Highway in the vicinity of the project. The first is a box culvert located at the
intersection with Maile Street that conveys stormwater across the highway. The second culvert
is located approximately 600 feet east of the Maile Street intersection and was used to convey
sugar mill flume water across the highway for disposal.
The Draft EA Section 3.9.1 (a) states:
"The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM),
Community Panel No. 155166 1800F, effective date September 29, 2017 shows that most of
the Pahala area is located in Zone A', which designates areas determined to be outside the 0.2-
percent annual chance (500-vear) floodplain. A small portion of the community of Pahala,
including some land within the collection system project site, is located within Zone X—
Other Flood Areas, indicating areas within the 0.2-percent annual chance (500-year)
floodplain, or areas with a 1-percent annual chance of flooding with average flood depths
less than 1 foot.
According to the FIRM, both existing LCCs are also located within ZoneX. However, LCC-1
is very close to the edge of the 500-year floodplain.
On April 16, 2018, in response to the pre-assessment notification, the State of Hawai'i
Department of Land and Natural Resources Engineering Division stated the responsibility for
conducting research as to the flood hazard designation for the project site lies with the project
proponent. Also on April 16, 2018 and in response to the pre-assessment notification, the
County of Hawai'i Department of Public Works confirmed that the proposed treatment and
disposal project site at Site 7 is designated as Zone X on the FIRM and is outside the 500-
year floodplain."
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Letter to Ms. Sophia Hanoa
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March 6, 2020
The relevant FIRM panel is reproduced in Appendix B as Figure 4-13.
This information will be repeated in the Final EA.
The Draft EA Section 3.23.2 (a) states:
"The proposed wastewater treatment and disposal facility would include an on-site drainage
system to address stormwater surface runoff created by new impervious surfaces within the
facility. The site would include a system to collect runoff via grated inlets or swales, and
flows would be conveyed to on-site drainage detention systems, such as subsurface linear
infiltration or depressed detention basins."
This information will be repeated in the Final EA.
The preferred alternative (Site 7) slopes from approximately north to south (mauka to makai)
such that, during rain events, surface flows pass through the existing orchard to the southern
(makai) end where the flows eventually drain through the culvert located at the Maile Street-
Mamalahoa Highway intersection to the areas below (makai) the highway. Most of the land
surface area below the existing macadamia nut orchard contains little to no vegetation to absorb
or slow these flows. The gradient of Site 7 and surrounding area results in this natural pattern of
surface flows which also existed when the area was planted in sugar cane and is not considered
flooding.
Based on the roadway flooding concerns expressed by the community during the Pahala public
meetings held in December 2017 and October 2018, the State of Hawai'i Department of
Transportation (DOT) Hawai'i District office was contacted to discuss drainage at the treatment
and disposal facility project site and the culvert at the Maile Street and Mamalahoa Highway
intersection. On February 20, 2019, the District office confirmed via telephone that the DOT
owns and maintains the culvert at the Maile Street intersection, and that they have no record of
the roadway being inundated by stormwater drainage during precipitation events at that location.
Stormwater runoff generated mauka of the treatment and disposal facility project site will be
directed around the perimeter of the site via diversion swales that will convey flow back to the
existing drainage pattern that flows to the existing culvert at Maile Street. During heavy rain
events, stormwater may temporarily back up behind the culvert. There will be no changes to this
culvert and the proposed treatment and disposal facility will not be located within the area of the
culvert.
As stated in the Draft EA, the on-site stormwater management system would meet the
requirements of Hawai'i County Code (HCC), Chapter 27 Floodplain Management, Section 20,
Standards for subdivisions and other developments (e) which mandates a site drainage plan to
"comply with sections 27-20(a) and (b) and section 27-24, and shall include a storm water
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10349-01
Letter to Ms. Sophia Hanoa
Page 7
March 6, 2020
disposal system to contain run-off caused by the proposed development, within the site
boundaries, up to the expected [design] storm event as shown in the department of public works
"Storm Drainage Standards".
To meet the requirements of HCC, Chapter 27, Section 20 (f), the project "shall not alter the
general drainage pattern above or below the development". Thus, for the HCC design storm
event, no increase in flow amount will be directed to either of the culverts at the highway as a
result of the site development. A drainage report will be prepared during the design process to
evaluate the improvements necessary to comply with HCC requirements.
The wastewater treatment processes will be designed to accommodate the associated peak flows,
including precipitation that falls on the area occupied by the aerated lagoon treatment system.
The Draft EA Appendix B, Section 2.2 outlines the anticipated peak wastewater flows from the
community, based on the applicable flow standard. The Draft EA Section 2.3.1, states the
aerated lagoons will be lined to prevent water seepage through the bottom and sides of the
lagoons. The Draft EA Appendix B, Section 5.3 shows the operational freeboard that will be
available to contain and to equalize lagoon flows. In addition, the slow-rate land application
groves will be designed to completely contain both peak effluent flows and precipitation from a
100-vear, 24-hour storm event. A geotechnical engineering assessment of berm stability will be
conducted during the design process. The tree groves will be designed in accordance with the
EPA's "Process Design Manual, Land Treatment of Municipal Wastewater Effluents". Effluent
will be applied at a hydraulic loading rate that is a small percentage of the percolation rate of the
soil, ensuring sufficient capacity for assimilation of peak effluent flow rates and precipitation
from the design storm event.
This information will be included in the Final EA.
3 b. Without specific citations it is not possible to confirm the issue related to negative impacts
to residents near wastewater treatment plants.
3 c. The proposed site plan is included in the Draft EA as Figure 2.3. As noted in Section 2.3.1,
"disposal of the treated and disinfected effluent would be accomplished through land treatment
in four groves of native, water-tolerant trees occupying a total area of approximately 8.0 acres."
This 8.0 acre planted area, combined with the sloping site topography and existing Cook pine
trees {Araucaria columnar is) on Maile Street, will provide a visual buffer from both the
Mamalahoa Highway and Maile Street. As outlined in Section 3.19.2 of the Draft EA, the
Proposed Action is not expected to adversely affect the views or viewsheds identified in the
County General Plan. The wastewater collection system would be installed below the streets and
therefore would not impact views. Above-ground structures may include the operations
building, headworks and UV cover structures, and berms around the basins. The existing pine
trees along Maile Street, most of which would remain with no changes, would continue to
obstruct the viewplanes from Maile Street. The facility site would be adjacent (mauka) to, and
10349-01
Letter to Ms. Sophia Hanoa
Page 8
March 6, 2020
visible from, Mamalahoa Highway (State Route 11); however, impacts to the viewplane would
be mitigated by the planted trees in the basins and by the rise in elevation between the highway
and the facility.
3. d. The Draft EA Section 2.3.1 states Site 7 is owned by Kamehameha Schools and Section
2.5 states Site 9 is owned by Kamehameha Schools. The Final EA will clarify that the current
landowner is BP Bishop Estate Trustees (Kamehameha Schools).
4. a. As outlined above and in the Draft EA Section 2.1.3, the County has been discussing the
need for a new collection system, treatment and disposal facility to replace the existing collection
system and LCCs, which have been prohibited by the U.S. Environmental Protection Agency,
with the community since 2004. The County has not fast-tracked this project. Although not a
comment specific to the content of the Draft EA, for clarification, fees currently paid by Paha la
residents serviced by the existing County-owned collection and LCC disposal system are
collected for operation and maintenance of that system. All properties connected to County of
Hawai'i wastewater collection systems pay fees as outlined in County of Hawaii Code (HCC)
Chapter 21 Section 21-36.1. Currently, users connected to gang cesspools (LCCs) pay a reduced
charge per unit as compared to rates charged to other user categories.
4. b. and c. The Draft EA Section 2.2 describes the purpose of the Paha la Large Capacity
Cesspool Replacement project is to close the Pahala large capacity cesspools (LCC). The Draft
EA Section 2.3.2 discusses the construction of a new sewer collection system in the Pahala
community to replace the existing system of substandard gravity lines that currently conveys
sewage to the two LCCs. As described in Section 6.2.1, the current collection system includes
facilities located in the backyards of many parcels. Where easements for the existing collection
system aren't accessible, the County must obtain permission from individual landowners to enter
them, through private property, to inspect, maintain, repair or replace existing sewer facilities:
all activities essential to an efficient, functioning system.
As a result, the proposed new collection system would consist of a total of approximately 12,150
linear feet (LF) (2.3 miles) of corrosion-resistant polyvinyl chloride (PVC) piping located almost
entirely within the right of way (ROW) of eight public streets.
Also as outlined in the Draft EA, Section 2.3.2, the new collection system would be subject to
the Hawai'i County Code (HCC) Chapter 21, Sewers, specifically, Article 2 (Public Sewers),
Section 21-5, which states the following:
"(a) Owners of all dwellings, buildings, or properties used for human occupancy, employment,
recreation, or other purposes, which are accessible to a sewer are required at their expense to
connect directly with the public sewer within 180 days after date of official notice.''''
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10349-01
Letter to Ms. Sophia Hanoa
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March 6, 2020
Each adjacent lot will be provided with a lateral connection to the sewer main as required by
HCC and standards. Under the Preferred Alternative, the design of the new collection system
would extend between street intersections and include sewer service stub-outs (the lateral
connection to the sewer main) to the lot lines of adjacent properties, including the newly
accessible, to accommodate their eventual connection. Accordingly, to close the existing LCCs,
there will be additional properties in Pahala that would be required to connect to the new
wastewater collection system, at their expense, after it becomes operational. Such properties are
near the existing service area but are presently connected to individual wastewater systems. To
conform to the stated section of HCC, the respective, newly accessible property owners would be
responsible for the design, permitting and completion of sewer service connections between the
County stub-outs and improvements for stated uses on their property, as well as for the proper
closure of their individual wastewater systems. The Draft EA Figure 2.6 shows the area of the
community serviced by the current and proposed collection systems.
The Draft EA Figure 2.6 shows the area of the community serviced by the current and proposed
collection systems.
The financial impact of the project on individual newly accessible property owners was raised by
the community during the December 2017 public meetings as summarized in Section 7 of the
Draft EA. Although not required by Hawaii Administrative Rules (HAR) Title 11, Chapter 200,
DEM voluntarily convened two additional public meetings on October 9, 2018 and March 26,
2019 to gain further input from newly accessible property owners and present funding options
for them to pursue. This information will be added to the final EA.
The County's intent, as stated in the June 22, 2017 US Environmental Protection Agency Region
9 Administrative Order on Consent is to provide an industry standard wastewater collection
system and a secondary treatment and disposal facility, a basic service to the Pahala community
to eliminate underground injection from LCCs it operates to help protect underground drinking
water sources. Closure of individual cesspools is mandated by legislation at the State level. In
2017, Act 125 was enacted requiring all cesspools, not exempted by the Department of Health,
be upgraded or converted to septic systems, or aerobic treatment unit systems, or connected to
sewage systems by January 1, 2050. Though closure of individual wastewater systems by the
County is not part of the Proposed Action, this legislation will affect all parcels in Pahala
currently using cesspools for sewage disposal.
4. d. The Draft EA Section 2.9 provides information regarding the 2007 Final EA for the
Na'alehu- Pahala Large Capacity Cesspool Conversion project. There is no statement in the 2007
Final EA that the project was a joint venture.
4. e. The Pahala wastewater treatment plant (WWTP) 14.9-acre project site has been developed
to provide the necessary land area for the facilities needed to treat the incoming flows and to
dispose the treated effluent from the treatment processes. The project site minimizes the use of
10349-01
Letter to Ms. Sophia Hanoa
Page 10
March 6, 2020
the adjacent lands which contain a commercial macadamia orchard. A larger project site is not
required. The special permit requirement applies to the proposed WWTP parcel only, not to the
proposed utility easement. The County will apply for the required special permit through the
Planning Commission. This information will be repeated in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
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WILSON OKAMOTO
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10349-01
March 6, 2020
ref (42)
Jadelyn Kaapana Moses
mamai apab7.l Coj gmail, com
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment October 24, 2018 1:39 a.m.
Dear Ms. Moses:
Thank you for your October 24, 2018 1:39 a.m. comment message regarding the Draft
Environmental Assessment (EA) for the County of Havvai'i Department of Environmental
Management Pahala Large Capacity Cesspool Replacement project. Our responses follow:
We appreciate you taking the time to attend meetings and encourage you to continue your
engagement. The purpose of this letter is to address your emailed comments as they relate to the
content requirements of the Draft EA.
Section 2.1.4 of the Draft EA provides a history of wastewater management for Pahala. As
stated, in 2003 C. Brewer requested assistance from the County to close their large capacity
cesspools as required by the Environmental Protection Agency. Section 2.14 discussed that,
around 2006, C. Brewer requested that the County construct and maintain a new and improved
sewer system for the Pahala community. A County Council Resolution approved the C. Brewer
request. In anticipation of C. Brewer's dissolution, the company proposed, and the County
agreed in April 2007, to enter into a formal agreement to construct and maintain a new and
improved community sewer system or assume maintenance and required service of the existing
systems by April 30, 2010. The Final EA will clarify that C. Brewer committed to complete the
line (called a lateral) between the residences and the property line at the edge of the public right-
of-way adjacent to the new collection system for specific private properties in Pahala and
Na'alehu. It was agreed, if the County did not complete its* portion of the work by April 30,
2010, it would assume pending and unfinished obligations to connect the new laterals installed
by C. Brewer to the residences and new collection system when complete. Thus, the project
includes connecting these C. Brewer laterals, which may now need to be replaced.
As outlined in the Draft EA Section 2.1.3, the County has been discussing the need for a new
collection system, treatment and disposal facility to replace the existing collection system and
LCCs, with the community since 2004.
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
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10349-01
Letter to Jadelyn Kaapana Moses
Page 2
March 6, 2020
On April 25, 2010, a community meeting sponsored by Councilman Guy Enriques was held at
the Pahala Community Center to discuss the Na'alehu and Paha la Large Capacity Cesspool
Replacement project. As part of the meeting, an informational handout prepared by the County
Wastewater Division, provided a history of the project documenting that, in 2004, Mayor Kim's
office used a ballot system to get input from property owners regarding different wastewater
treatment disposal alternatives for those property owners connected to the LCCs who would no
longer be served by the C. Brewer system after LCC closure. As reported in the Draft EA
Section 2.1.4, 87 percent of the returned ballots were in favor of the installation of a new sewer
collection system and a treatment and disposal system to be operated and maintained by the
County. The handout indicated that Mayor Kim's office advised the property owners the County
would move forward with a new system for Na'alehu and Pahala on November 5, 2004.
Additionally, the handout stated that public meetings were held in both Na'alehu and Pahala in
November 2006 to discuss the wastewater system alternatives.
This historical information related to public outreach regarding closure of the LCCs will be
included in the Final EA.
The Draft EA Section 7 documents the five public meetings held in Pahala December 12, 13 and
14, 2017 to discuss the Pahala Large Capacity Cesspool Replacement project. As documented in
the Draft EA, the community outreach program for the current project was designed as 'talk
story" sessions to optimize community conversations in informal sessions. Further, as
documented in the Draft EA, invitations and announcements for the talk story sessions were
intended to reach all audiences, as follows:
• Property owners with C. Brewer lines on their property were mailed letters from
DEM inviting them to these sessions. The letters included stamped, mail-in postcards
to facilitate the RSVP process.
• Fliers were hand-delivered to ''newlv-accessible" properties.
• Organizational leaders were provided copies of fliers announcing meetings and asked
to circulate among their members.
• Fliers were posted in public venues, such as the post office, the Pahala Community
Center and the Ka'u Hospital.
• Several online announcements were included in Ka'u News Briefs available at
http://kaunewsbriefs.blogspot.com.
This information will be repeated in the Final EA.
On September 10, 2018, letters containing information on the availability of the Draft EA, the
comment period, and the October 10, 2018 meeting were mailed to all property owners on record
adjacent to the proposed collection system. This direct mailout included an invitation from DEM
to workshops conducted prior to the October 10 public meeting. The workshop for owners
served by C. Brewer lines was held on October 8, and the mailout for this meeting also included
10349-01
Letter to Jadelyn Kaapana Moses
Page 3
March 6, 2020
anyone with a current sewer account. The workshop for owners of newly accessible properties
was convened on October 9. In addition to the direct mailout, online announcements for the
October 8 and 9 workshops were available on the Ka'u News Briefs website.
On September 26, 2018, a public notice was published in both the Hawaii Tribune Herald and
West Hawaii Today which stated a public meeting was to be held on October 10, 2018 for the
Pahala Large Capacity Cesspool Replacement Project Draft EA. A public notice was also
published in the October 1, 2018 print and online editions of the Ka 'u Calendar and made
available on the Ka'u News Briefs web site http://kaunewsbriefs.blogspot.com. Fliers were also
posted in public venues such as the community shopping center, realtor office, grocery store,
library, and the Pahala Community Center.
This information will be included in the Final EA.
All accessible properties will be required to connect to the new wastewater collection system in
accordance with Hawai'i County Code, Chapter 21, Article 2, Section 21-5. However, as you
have noted, the County entered into an agreement with C. Brewer (in April 2007) to eliminate
LCCs from the existing community sewer system and connect properties discharging to them to
new County collection, treatment and disposal systems. Once the actual costs are determined.
County Council action is still required to approve the expenditures.
The financial impact of the project on individual newly accessible property owners was raised by
the community during the December 2017 public meetings as summarized in Section 7 of the
Draft EA and again during the October 2018 meetings. Although not required by Hawai'i
Administrative Rules (HAR) Title 11, Chapter 200, DEM voluntarily convened an additional
public meeting on March 21, 2019 to gain further input from newly accessible property owners
and fulfill a County commitment made in October 2018 to research and provide financing
options available for the newly accessible residents of the Pahala Community to pursue.
Programs discussed included:
• US Department of Housing and Urban Development (HUD) with County of Hawai'i
Office of Housing and Community Development Residential Repair Program-
Community Block Grant Program, and
• US Department of Agriculture - Rural Development (USDA-RDA) Program.
As noted during the presentation, these programs may change in the coming years and additional
options may be added to this preliminary list. Hawai'i Legislature, Senate Bill 221 SD1, which
could amend Hawai'i Revised Statutes (HRS) Chapter §342D to establish a low interest loan
program offering financial assistance to cesspool owners to connect to wastewater treatment
systems approved by the Department of Health was also discussed; however, this bill was
subsequently not passed during the 2019 legislative session.
-------
10349-01
Letter to Jadelyn Kaapana Moses
Page 4
March 6, 2020
This information will be included in the Final EA.
The County has investigated reports of cultural and historical sites in the context of this project
in consultation with the State Historic Preservation Division (SHPD), as follows:
The Draft EA Section 3.15 references a November 2016 archaeological field inspection report
that states, while the historical ground modifications have likely limited the archaeological
potential of the site, the discovery of both pre- and post-contact surface artifacts within the 42.5-
acre parcel (which includes Site 7), as well as evidence from plantation-era documents, that the
opening of a lava tube containing human remains once existed in the southeastern corner of the
parcel, indicate that further archaeological studies may be necessary. The Final EA will clarify
that the report also stated it would be advisable to limit the development footprint to exclude the
southeastern corner of the 42.5-acre parcel. This area, which is presently not used as a
macadamia nut orchard, but forms part of the macadamia nut processing plant complex, is the
location of a known (but sealed) lava tube opening that local informants have indicated is linked
to tubes that possess traditional human burials. Further, by excluding this section of the parcel, it
will be possible to avoid at least one known historic property. The Draft EA Figure 2.3, which
provides the Preliminary Site Plan for the New Treatment and Disposal Facility shows the 14.9-
acre project site has been developed to exclude the area identified as the location of the sealed
lava tube opening.
Between September 18, 2018 and January 10, 2019 a team of qualified archaeologists conducted
a pedestrian survey of the proposed project site and subsurface trenching to determine the
presence of archaeological resources. The work was undertaken in accordance with the State of
Hawai'i Department of Land and Natural Resources SHPD requirements, with the archaeological
inventory survey (AIS) approach accepted by SHPD in their August 20, 2018 letter. The
archaeological inventory survey submitted to SHPD in March 2019 documents that a sealed lava
tube opening is located east of the proposed wastewater treatment and disposal facility project
site, outside the proposed property boundary, and outside of the area of potential effect
considered in consultation with the SHPD.
The complete document is available for download from the County's website
at: http://records,co.hawaii.hi.us/weblink/l/edoc/100962/Draft%20A.rcheological%20Itiventorv
%20Survev%20-%20Pahala%20WWlT>%20and%20Sewer%20Svstem.pdf
A geophysical survey and geotechnical investigation of the proposed project area will be
performed during detailed design with the specific intent to locate subsurface voids (such as lava
tubes) present beneath the site, conduct infiltrometer testing, and determine subsurface soil
characteristics that may impact design and construction of the new wastewater treatment,
disposal and collection systems.
This information will be included in the Final EA.
10349-01
Letter to Jadelyn Kaapana Moses
Page 5
March 6, 2020
The project will be designed to accommodate the future needs of the Pahala community in
accordance with the Ka'u Community Development Plan Policy 120 as discussed in the Draft
EA Sections 2.9, 6.2.2, 7 and Appendix B. Additional information will be included in the
appendices of the Final EA to clarify how accommodations will be made not to preclude future
expansion of the new collection system. Future development will be accommodated as capacity
allows on a first-come, first-served basis.
As stated in the Draft EA Section 2.10, the County of Hawai'i Department of Environmental
Management will submit a Special Use Permit application. Subdivision Application, and obtain
plan approval as required by applicable Hawai'i County Code and Hawai'i Revised Statutes.
This information will be repeated in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
tOMMtNlISEMlfllfiHmaMALA IXC R|Pt«fMfW PROJfCT if'
SUBMITTED TO;
Mfi Aft>r
Wilson Ofairittte Cofpei alien
1907 south Beretatfa Street Suite 400
Honolulu, HI M026 • ' ' ¦
Fax:808/946-22S3
SUBMITTED ®Y;
*$
Naatehu HI 96772
Comnumt;
in 2010, when lie County acquired the Illegal Ka'u LCCs from the C, Brewer
Company, the COHDEM mm simpty tasked wills closing the LCCS - beyond that Is
wastewater dreamland. And which bureaucrat In came In one day and said: "'I
haws a f rent Idea - let's put a sewage plantnextto i school - ye»h that will
work! Which school? NwWw Elementary School r
There h«s been no public participaitot In the decision to m
sewage plane tesicfe my grandson's dassroom m Naatehu Schoo) and I •#« my
voice t© m ne»rd. Do the right thing and provide s tlngfe SiS for the iCs'u ICC
Closure Project «s take the school-site off the to* immediately t
Sltpi In Naatehu, Hawaii on October 22,2018
III* lopes '
LSOM OKAMOTO
RPORATIQN
:> „• * t o 3 ;s . * i « t *, <. , H ! I *
10349-01 ref (38)
March 6, 2020
Ms. Lila Lopes
Naalehu, 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - October 22, 2018
Dear Ms. Lopes:
Thank you for your October 22, 2018 comment letter regarding the County of Hawai'i
Department of Environmental Management Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement project. Our responses follow:
The Na'alehu LCC project is not the subject of the Draft EA for the Pahala Large Capacity
Cesspool (LCC) Replacement project.
Hawaii Administrative Rules (HAR) 11-200-7 Multiple or phased applicant or agency actions
states that "A group of actions proposed by an agency or an applicant shall be treated as a single
action when (1) The component actions are phases or increments of a larger total undertaking,
(2) An individual project is a necessary precedent for a larger project; (3) An individual project
represents a commitment to a larger project; or (4) The actions in question are essentially
identical and a single statement will adequately address the impacts of each individual action and
those of the group of actions as a whole." The wastewater projects at Pahala and Na'alehu are
not phases or increments of a larger total undertaking, are not precedents or commitments for a
larger project, nor are they identical. Hence, there is no requirement to consider them in a single
environmental review document.
We appreciate your participation in the Draft E A process.
Sincerely,
Keola Cheng
Project Manager
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
-------
10349-01
Letter to Ms. Lila Lopes
Page 2
cc: W. Kucharski. COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
@Mi«immiaiEim^SAiAiitirporatk>n
ISW South BtfMani* Street, Suite 400
U«b^I..Ii. CJI CkCO"5C
flwPllslll# Hi WM-'P
fa*: lllS/§46-22S3
siJiMfrreo iv:
Charies futile "V"
9*4*13 Kmimiu Road
Naaletai HI 96772
Comment:
It seems extremely wrong • in fact "green colter crime,* thai the EPA grant was
rowed to Wnh m M*y 3$ J»M ma nam you §11 art refusing is do any NEPA or
LSOM OKAMOTO
RPORATIQN
:> „• * t o s ;s . * i « t *, <. , H ! I *
10349-01 ref (34)
March 6, 2020
Mr. Charles Tuttle
Ms. Tina Tuttle
95-1513 Kaalualu Road
Naalehu 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - October 22, 2018
Dear Mr. and Ms. Tuttle:
Thank you for your October 22, 2018 comment letter regarding the County of Hawai'i
Department of Environmental Management Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool (LCC) Replacement project. Our responses follow:
The Na'alehu LCC project is not the subject of the Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement project.
The Draft EA Section 5 discusses the federal cross cutter requirements for the Pahala Large
Capacity Cesspool Replacement project.
The Draft EA Sections 2.3 through 2.8 discuss project siting issues.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
-------
"/ijus/if CC BC£M{{
' ' ft* mi,
SUBMITTED TO:
Project Manager
Wilson Okamoto Cofperiiilatn
ISO? South Beretanta Street, Suite 400
Honolulu, HI 96826
Pi*;®©!iMi-iim
SUBMITTED BV:
Amanda ...r J
IS-5SS7A Hwy.
NwMmi HI MT72
Corrnnent
thu Count* iftfl im taw wcMM «nt consideration of It* Impiets el i.he
NwMm tCC Cloture ft#f»et on this Wwb WWII* and ft is ®«% 5»t«f JI miles
awsy.
it is net rifSi that our sons should haw to go to school next to ¦ new-build
wastewater plant Just because the CbhMv and CPA coftspir ed to mow the EM
grant to Pahaia on May 30,20J&, and »the Naafehu School sit# has not tof any
EA or NHPAof 65A environmental renew.
Signed in Meta, Hawaii on October 22, MIS
Amanda McDowell
/ :¦!; miMlf
LSOM OKAMOTO
RP0RAT1QN
10349-01 ref (43)
March 6, 2020
Ms. Amanda McDowell
Mr. Anthony McDowell
95-5587A Mamalahoa Highway
Naalehu, Hawaii 96772
Subject: Draft Environmental Assessment for the
Pahaia Large Capacity Cesspool Replacement Project
District of, Ka'u, Hawai'i
Response to Comment - October 22, 2018
Dear Ms. and Mr. McDowell:
Thank you for your October 22, 2018 comment letter regarding the County of Hawai'i
Department of Environmental Management Draft Environmental Assessment (EA) for the
Pahaia Large Capacity Cesspool (LCC) Replacement project. Our responses follow:
The Draft EA Section 4.1.2 states: 'The community of Na'alehu, approximately 11 miles
southwest of Pahaia, is also considering options for closure of LCCs and development of a new
wastewater treatment system. The Na'alehu project was excluded from this analysis of
cumulative improvements and impacts because, due to its distance from Pahaia, the effects of
that project are not expected to have a significant cause-and-effect relationship with the direct
and indirect effects of the Proposed Action. The Na'alehu project is undergoing separate
community outreach and environmental review processes that will identify potential impacts for
that project separately from the Pahaia wastewater system improvements."
This information will be included in the Final EA.
The Na'alehu LCC project is not the subject of the Draft EA for the Pahaia Large Capacity
Cesspool Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
-------
10349-01
Letter to Ms. Amanda McDowell/Mr. Anthony McDowell
Page 2
March 6, 2020
cc: W. Kucharski. COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
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HAWAII NOTARY ACKNOWLEDGMENT
THE STATE OF HAWAII
©nuvi J,Uy.v*_^
I inmm ptiplo»»jf observed or heart of a
tHtrtji gnu wis human tKtittai remains art or tlwMng. it Is located in Pan*,
liiwaii,. above Mamafahoa Highway. H «in Uw area Mm #w County of Hawaii
¥#®cif$ w piii a ^ewafp waste-wate* pdre. \ $m a§«8»i$f me us# 01 mm
prqpo$e6 site.
On t(A Q& , go r'' >¦ >' *" > • : ¦" 'KiP. Notary Pubic
to and to siM count* per»«iy tpptiwl
: Signature
k 11 U>'A LtVV.:R,'.
My expires! IB \R>|aOV1
-------
lute of !¦»»*»
! ¦
the person mxnfxa m ««ci wno l*ec«i«f Ww foregoing toutumeni. and
,ic*»wwie«l§ecl mat myih* wwcuwd am tatt* m m mm act ma deed.
HAWAII NOTARY ACKNOWLEDGMENT
IK n, • *. n.v-VAll
COUNTY OF
" JftSSie Kc hivephysfeartiy ob«wv«(or' 1 i <<
burial cave with human sfcewtai remains and or stteiwna- B is located m Pahata,
Haw,* Jilxwt MamatetKH Highway, it is in fit arts wftem ihf County of Hawaii
wvtte ts put ¦ Sewage wastewater treatment plant I am ¦§¦«•! 4h« im of ilia!
proposed site..
OnjOo - ,•••'• . ,-'oreitf LkV{'" ' (. Notary Public
. >< -*<><- '-.-.mi',,,parsonallf V * Yr~ -
(is§»#ff«it«tssji wne has/have mmamt mmm mmMmrnemmm% m trie
) m "Mint Hneferenoed document
p»t Jferatifr 0
AIM
-------
State of H*«*«8 |
1 5B
County of Haw»i f
Orr this . day <* . JfflA&iL. , 201 a, tefwt urn pe»Of»#f
"* »to me known to I*
the penm dexiibed m >mt who executed the Iwc§eirif instrument, and
wknowterfged thai t*/s»* e*«M«i the smw m!«, fa* *t «1 deed.
'' ¦
t6 r|
\# 5*K»lPrint Warms; ' •- >• on
« # My CslffirWlSicirt Expires: 07/1
HAWAII NOTARY ACKNOWLEDGMENT
f"- MATE OF HAWAII
COUNTY OF 1
iA,sm #*(&,mar 3i hw physically observed«twart of •
burial caw wttn ftu
•arts to- puta Sewst#
proposed site.
ills! firriat* a* of shewnfl. I is located m Palais,
Highway. it t« !fi tha aria where lift# County of Hawaii
plinl.li t the um of that
CHi',S$:i,d5»„.20•-tePeme, S> u u' *• '-<>•'•^'1. Notary Public
ina«tforuidooimly.penoMli, ow;au tVvv-^k
the
Wmtj tototie. "3'-
Prtrrt O6«tb0toin
My €siwiiis$i#(ii
-------
1
County of Maw# >
On Ibis mf&i ___. 20 i t, t**» aw pirowlfy
appear..' uH^vU 1 R*W.W ' ' , to me Known tot*
the $mm ilextfim m am) «#» mttumi the im-mtmmt imteumtat «wI
wknowtefeed mm he/tfw executed the same « h«i tm *Z «*i deqa
HAWAII NOTARY ACKNOWLEDGMENT
rsf." -.-Art i-i
COUNTY OF
: Mfrtd Hm't% «3r., __ _ ..1 if t>'"if#l©§§j ©bsftwtf or htwtf of s
I*, ,.1! rn JO w «• ttuman MMt mains and or ttttMng, i it located in Pahiila,
Mtwiil, above . n^way, ft it in ttw Mmim B» County of hwmm
that
O" ift_sEL_.»_iS_ ««•a 1». U«/ ,v,-> rv pmk
Si, , h^W \ \,t ,iM }i
) or witriiiis|«s| to «* document
¦
"Simj'r?
My comm&slofl expires; IH
(Swri)
-------
Sliiiif of Hawaii }
Coonty of Hawaii i
Ott ihfj „. it* wf , 2819, before me porsooawy
1. . t Sfc*v*<•*"<[' , Notary PvWie
in and tor said county, parsonm: >, J W-m j Wr.M •*,
|sfii«f*»fiiess| who mvmm satisttctnmy ici»nlif«a himrtiarrth* s
si|wf{»| ci* wimsam} to the abowe-re-fertneed document.
MlfVJ IlsMlTt
My corwrHwtan
-------
S«i»ef Hawaii I
County Of M»wi
On ifnj .!.f -f t1 '201«. Waft' to be
itw person described im- awl wtw executed lite K»«goMg imimmwf* »*l
acftnowtodged that his* rHe»n*a$ iw free mma aunt.
HAWAII NOTARY ACKNOWLEDGMENT
TATE OF HAWAII
COi I >' • 11
i__£Lmsak .4al _ hmm physically oliswed or heart of a
MM taw* wftli human ftaiisil rwtnins and * BtwMng. »l i* located in Pahals,
Hawaii, above Mamntahea Highway. * te to the m where fie County of Maws!
¦wains to put » sewage rnmmm treatment Ham. i am against m use of mm
prap»«i site
On OctM^a, 2011 tafcf. m». Grate 0 il^ Notary Public
in and for said county, pert.aw,.; L > £, i>\ •
tsi§r»rMlri)B#s) who hai/hava satisfactorily kMMM
glf i*f|s| or »Hii8s*{««| to th® hkmim.
I *4«"W»C* « l,.€V,Bi
ft,.. i V.
-------
swe of Hawaii 1
J SS
count* of Mi**.* \
On t«i ft- 9i Wttef , 2011, oetore me persona*?
» be
the pcnan described in Ml who «M«I th# foregoing Mrimh «i
xMWMfedqed iim ewcuiwl the sm« as
Signature of Notary Put*c
My Comrrwaiort Expire*' 07/
LSOM OKAMOTO
RP0RAT4QN
:> „• * t o s ;s . * i t « t N i H ! I *
10349-01 ref (40)
March 6, 2020
Pele Defense Fund
Residents of Paha la
P.O. Box 4969
Hilo, Hawaii 96720
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - October 23, 2018
Dear Sir/Madam:
Thank you for your October 23, 2018 comment letter regarding the County of Hawai'i
Department of Environmental Management Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement project.
Please note that in response to requests from your organization and others in the community, the
public comment period was extended through December 10, 2018. See #2 below for additional
detail.
Our responses follow:
1. As outlined in the Draft EA Section 2.1.3, the County has been discussing the need for a new
collection system, treatment and disposal facility to replace the existing collection system
and LCCs, which have been prohibited by the U.S. Environmental Protection Agency, with
the community since 2004. The Draft EA Section 7 documents the 5 public meetings held in
Pahala December 12, 13 and 14, 2017 to discuss the Pahala Large Capacity Cesspool
Replacement project. As documented in the Draft EA, the community outreach program for
the current project was designed as "talk story" sessions to optimize community
conversations in informal sessions. Further, as documented in the Draft EA, invitations and
announcements for the talk story sessions were intended to reach all audiences, as follows:
• Property owners with C. Brewer lines on their property were mailed letters from
DEM inviting them to these sessions. The letters included stamped, mail-in postcards
to facilitate the RSVP process.
• Fliers were hand-delivered to "newly-accessible" properties.
• Organizational leaders were provided copies of fliers announcing meetings and asked
to circulate among their members.
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
-------
10349-01
Letter to Pele Defense Fund
Page 2
March 6, 2020
• Fliers were posted in public venues, such as the post office, the Paha la Community
Center and the Ka'u Hospital.
• Several online announcements were included in Ka'u News Briefs available at
http://kaunewsbriefs.blogspot.com.
This information will be repeated in the Final EA.
On September 10, 2018, letters containing information on the availability of the Draft EA,
the comment period, and the October 10, 2018 meeting were mailed to all property owners
on record adjacent to the proposed collection system. This direct mailout included an
invitation from DEM to workshops conducted prior to the October 10 public meeting. The
workshop for owners served by C. Brewer lines was held on October 8, and the mailout for
this meeting also included- anyone with a current sewer account. The workshop for owners
of newly accessible properties was convened on October 9. In addition to the direct mailout,
online announcements for the October 8 and 9 workshops were available on the Ka'u News
Briefs website.
On September 26, 2018, a public notice was published in both the Hawaii Tribune Herald
and West Hawaii Today which stated a public meeting was to be held on October 10, 2018
for the Pahala Large Capacity Cesspool Replacement Project Draft EA. A public notice was
also published in the October 1, 2018 print and online editions of the Ka 'u Calendar and
made available on the Ka'u News Briefs web site http://kaunewsbriefs.blogspot.com. Fliers
were also posted in public venues such as the community shopping center, realtor office,
grocery store, library, and the Pahala Community Center.
This information will be included in the Final EA.
The Draft EA Section 7 will be revised to add that, on March 21, 2019, the County held
another meeting in Pahala which included a presentation to provide information on financing
sources available to owners whose property would become accessible to the County
collection system. The purpose of the meeting was to fulfill a County commitment made in
October, 2018 to research financing options available to the newly accessible residents of the
Pahala Community by March, 2019.
2. On October 26, 2018, the County requested the Office of Environmental Quality Control
issued a Re-Publication notice of the Draft EA in the November 8, 2018 issue of The
Environmental Notice. This was to allow additional time for public comments. Public
comments were accepted from September 23, 2018 to December 10, 2018.
3. and 4. The Draft EA Section 3.15 provides information on the archaeological and cultural
resources related to the Pahala Community Large Capacity Cesspool Replacement project.
The Draft EA Section 3.15 states, on March 29, 2018, consultation was initiated for the
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project under the National Historic Preservation Act. The Draft EA Section 10 provides a list
of the consulted parties. The Final EA Section 3.15 will include that the list of Native
Hawaiian Organizations (NHO) was generated by the EPA for NHPA Section 106 and HRS
Chapter 6E compliance from the U.S. Department of the Interior, Office of Native Hawaiian
Relations, Native Hawaiian Organization (NHO) Notification List. Letters were sent to 14
NHOS during the pre-assessment consultation. No responses were received from these
organizations.
The HRS Chapter 6E determination and Section 106 review packet were submitted to SHPD
with a draft archaeological inventory survey (AIS) on March 13, 2019. SHPD response is
pending. The Draft EA Section 3.15.2 states that prior to finalization of this EA and
initiation of the Proposed Action, the Environmental Protection Agency (EPA) and the
County of Hawai'i will conclude consultation with SHPD in accordance with Section 106 of
the NHPA and will incorporate additional impact avoidance and minimization measures as
necessary to result in a finding of no adverse effects to historic properties.
The Draft EA Section 7 will be revised to include that on September 26, 2018, a public
notice was published in the Hawaii Tribune Herald and West Hawaii Today newspapers to
advertise the October 10, 2018, public information meeting conducted by the County in
Pahala at the Ka'u Gym Multi-Purpose Conference Room to discuss the availability of Draft
EA and the process for submitting comments. The notice stated that the second part of the
meeting would address Section 106 of the National Historic Preservation Act of 1966, as
amended (2006) involving consultation with Native Hawaiian Organizations and the Native
Hawaiian descendants with ancestral lineal or cultural ties to, cultural knowledge or concerns
for, and cultural religious attachment to the proposed project area. Eight persons placed their
names on a sign in sheet at the beginning of the October 10, 2018 meeting to contribute
during the second part of the meeting dedicated to the Section 106 consultation. There were
no comments or information forthcoming during the Section 106 portion of the meeting.
The Draft EA Section 3.15 references a November 2016 archaeological field inspection
report that states, while the historical ground modifications have likely limited the
archaeological potential of the site, the discovery of both pre- and post-contact surface
artifacts within the 42.5-acre parcel (which included Site 7), as well as evidence from
plantation-era documents that the opening of a lava tube containing human remains once
existed in the southeastern corner of the parcel, indicate that further archaeological studies
may be necessary. The Final EA will clarify that the report also stated it would be advisable
to limit the development footprint to exclude the southeastern corner of the 42.5-acre parcel.
This area, which is presently not used as a macadamia nut orchard, but forms part of the
macadamia nut processing plant complex, is the location of a known (but sealed) lava tube
opening that local informants have indicated is linked to tubes that possess traditional human
burials. Further, by excluding this section of the parcel, it will be possible to avoid at least
one known historic property. The Draft EA Figure 2.3, which provides the Preliminary Site
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Plan for the new treatment and disposal facility, shows the 14.9-acre project site has been
developed to exclude the area in the southeastern corner identified as the location of the
sealed lava tube opening.
Between September 18, 2018 and January 10, 2019 a team of qualified archaeologists
conducted a pedestrian survey of the proposed project site and completed subsurface
trenching to determine the presence of archaeological resources. The work was undertaken
in accordance with the State of Hawaii Department of Land and Natural Resources State
Historic Preservation Division (SHPD) requirements, with the archaeological inventory
survey (AIS) approach accepted by SHPD in their August 20, 2018 letter. The results of the
survey and subsurface trenching showed no burials or lava tube openings were identified on-
site. The AIS submitted to SHPD in March 2019 documents that a sealed lava tube opening
is located east of the proposed wastewater treatment and disposal facility project site, outside
the proposed property boundary, and outside of the area of potential effect considered in
consultation with the SHPD.
The complete document is available for download from the County's website
at: http://recorctexo.hawau.hi.us/webliiik/l/edoc/100962/Praft%20Archeological%20Itiverit
orv'%20Siirvev%20-%20Pahaia%20WWTP%20and%20Sewer%20Svstem.t3df
The Final EA will include the pedestrian survey included residential streets within the project
area, including Pikake Street, Kamani Street, Puahala Street, Huapala Street, Hala Street, Hinano
Street, Ilima Street and Maile Street. The survey found these typically streets consist of one-to-
two-lane asphalt travel ways with no curbing or sidewalks, except for a short segment portion of
Maile Street which has a sidewalk.
Two historic properties were newly documented within the project area based on a review of
historic maps. These include Pikake Street which is a portion of a historic road alignment (SIHP
# -31088, Wood Valley Road/Coastal Road) and Maile Street which is a portion of a historic road
alignment (SIHP # -31089, Volcano Road). These two streets overlap historic-era road corridors
which functioned as primary transportation routes throughout the greater Pahala/eastern Ka'u
area. None of the constructed elements of the subject portions of the original SIHP #s -31088 or
-31089 roadways are evident today, and these portions of the historic properties lack integrity
apart from their location.
A geophysical survey of the proposed project area will be performed during detailed design
with the specific intent to locate subsurface voids (such as lava tubes) present beneath the site
that may impact design and construction of the new wastewater treatment, disposal and
collection systems.
This information will be included in the final EA.
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5. The Draft EA Section 3.9.1 (a) states:
"The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM),
Community Panel No. 155166 1800F, effective date September 29, 2017 shows that most of
the Pahala area is located in Zone A', which designates areas determined to be outside the 0.2-
percent annual chance (500-vear) floodplain. A small portion of the community of Pahala,
including some land within the collection system project site, is located within Zone X—
Other Flood Areas, indicating areas within the 0.2-percent annual chance (500-year)
floodplain, or areas with a 1-percent annual chance of flooding with average flood depths
less than 1 foot.
According to the FIRM, both existing LCCs are also located within ZoneX. However, LCC-1
is very close to the edge of the 500-year floodplain.
On April 16, 2018, in response to the pre-assessment notification, the State of Hawai'i
Department of Land and Natural Resources Engineering Division stated the responsibility for
conducting research as to the flood hazard designation for the project site lies with the project
proponent. Also on April 16, 2018 and in response to the pre-assessment notification, the
County of Hawai'i Department of Public Works confirmed that the proposed treatment and
disposal project site at Site 7 is designated as Zone X on the FIRM and is outside the 500-
year floodplain."
The relevant FIRM Panel is reproduced in Appendix B as Figure 4-13. This information will
be repeated in the Final EA.
The Draft EA Section 3.23.2 (a) states:
"The proposed wastewater treatment and disposal facility would include an on-site drainage
system to address stormwater surface runoff created by new impervious surfaces within the
facility. The site would include a system to collect runoff via grated inlets or swales, and
flows would be conveyed to on-site drainage detention systems, such as subsurface linear
infiltration or depressed detention basins."
The preceding information does not support significant historic flooding to the proposed
project area.
This information will be included in the Final EA.
The preferred alternative (Site 7) slopes from approximately north to south (mauka to makai)
such that, during rain events, surface flows pass through the existing orchard to the southern
(makai) end where the flows eventually drain through the culvert located at the Maile Street-
Mamalahoa Highway intersection to the areas below (makai) the highway. Most of the land
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surface area below the existing macadamia nut orchard contains little to no vegetation to
absorb or slow these flows. The gradient of Site 7 and surrounding area results in this natural
pattern of surface flows which also existed when the area was planted in sugar cane and is
not considered flooding.
Based on the roadway flooding concerns expressed by the community during the Paha la
public meetings held in December 2017 and October 2018, the State of Hawai'i Department
of Transportation (DOT) Hawai'i District office was contacted to discuss drainage at the
treatment and disposal facility project site and the culvert at the Maile Street and Mamalahoa
Highway intersection. On February 20, 2019, the District office confirmed via telephone that
the DOT owns and maintains the culvert at the Maile Street intersection, and that they have
no record of the roadway being inundated by stormwater drainage during precipitation events
at this location.
Stormwater runoff generated mauka of the treatment and disposal facility project site will be
directed around the perimeter of the site via diversion swales that will convey flow back to
the existing drainage pattern that flows to the existing culvert at Maile Street. During heavy
rain events, stormwater may temporarily back up behind the culvert. There will be no
changes to this culvert and the proposed treatment and disposal facilities will not be located
within the area of the culvert.
As stated in the Draft EA, the on-site stormwater management system will meet the
requirements of Hawai'i County Code (HCC), Chapter 27 Floodplain Management, Section
20, Standards for subdivisions and other developments (e) which mandates a site drainage
plan to "comply with sections 27-20(a) and (b) and section 27-24, and shall include a storm
water disposal system to contain run-off caused by the proposed development, within the site
boundaries, up to the expected [design] storm event as shown in the department of public
works "Storm Drainage Standards"."
To meet the requirements of HCC, Chapter 27, Section 20 (f), the project "shall not alter the
general drainage pattern above or below the development". Thus, for the HCC design storm
event no increase in flow amount will be directed to either of the culverts at the highway as a
result of the site development. A drainage report will be prepared during the detailed design
process to evaluate the improvements necessary to comply with HCC Chapter 27
requirements.
The wastewater treatment processes will be designed to accommodate the associated peak
flows, including precipitation that falls on the area occupied by the aerated lagoon treatment
system. The Draft EA Appendix B, Section 2.2 outlines the anticipated peak wastewater
flows from the community, based on the applicable flow standard. The Draft EA Section
2.3.1 states the aerated lagoons will be lined to prevent water seepage through the bottom and
sides of the lagoons. The Draft EA Appendix B, Section 5.3 shows the operational freeboard
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that will be available to contain and to equalize lagoon flows. In addition, the slow-rate land
application groves will be designed to completely contain both peak effluent flows and
precipitation from a 100-vear, 24-hour storm event. A geotechnical engineering assessment
of berm stability will be conducted during the design process. The tree groves will be
designed in accordance with the EPA's "Process Design Manual, Land Treatment of
Municipal Wastewater Effluents". Effluent will be applied at a hydraulic loading rate that is
a small percentage of the percolation rate of the soil, ensuring sufficient capacity for
assimilation of peak effluent flow rates and precipitation from the design storm event.
This information will be included in the Final EA.
6. The Paha la wastewater treatment plant (WWTP) 14.9-acre project site has been developed to
provide the necessary land area for the facilities needed to treat the incoming flows and to
dispose the treated effluent from the treatment processes. The project site minimizes the use
of the adjacent lands which contain a commercial macadamia orchard. A larger project site
is not required. The special permit requirement applies to the proposed WWTP parcel only,
not to the proposed utility easement. The County will apply for the required special permit
through the Planning Commission.
7. The following is a summary of information from Final EA.
The U.S. Census Bureau provides the American Community Survey (ACS), which updates
selected demographic, social, and economic information for various years. This includes age,
racial composition, and economic information, including employment and household income by
Census Designated Place for several locations in Hawai'i County. The most recent version of
the ACS is the 2012-2016 5-Year Estimates, released in 2017.
The ACS shows the Paha la population has a similar age distribution to Hawai'i County, although
Pahala has a higher proportion of individuals in the "Under 5 to 19" age category, 28.5 percent
compared to 24.4 percent for the County. The median age for Pahala is 42.4 years compared to
41.8 years for the County.
Overall, Pahala is characterized by a racial composition that includes a greater proportion of
minorities than the County. The racial distribution includes a much lower proportion of White
residents, a much higher proportion of Filipino residents, and lower populations of other
minority groups, including Native Hawaiians when compared to the County. There are also
more residents of two or more races in Pahala than in the County.
Pahala has a higher proportion of residents that have completed high school and some college
than the County overall, but a lower proportion with college degrees (bachelor's and graduate or
professional degrees). From an economic perspective, Pahala generally has more households in
lower income brackets than the County, and a lower median household income. For analysis
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purposes and to correspond with the available ACS demographic characteristic data, "low
income" is defined as having a household income of less than $24,999; "minority" is defined as
any race population other than White; and "children" is defined as the "Under 5 to 19" age
category
Despite the relatively high proportions of low-income, minority, and children residents in Paha la
compared to the County, the project would not result in disproportionately high and adverse
human health or environmental effects on these sensitive populations. The design shows the
proposed wastewater treatment and disposal facility would include odor controls to minimize
odor and air quality impacts to nearby areas. Construction of the wastewater collection system
would result in intermittent and unavoidable noise from construction vehicles and equipment
within the Paha la community, including noise associated with the removal of bedrock. However,
construction activities within the community would need to comply with provisions of HAR 11-
46 (Community Noise Control). This includes the contractor obtaining a noise permit for any
activities that would generate noise exceeding the permissible sound levels specified in HAR 11-
46. The permit would limit excessive noise sources to daytime hours; would require the use of
best available control technology to control noise levels from excessive noise sources; and would
require the applicant to notify affected members of the public in advance of any planned
nighttime construction activity (which must not exceed the permissible sound levels). Overall,
with replacement of the substandard collection system and closure of the LCCs, the project is
expected to result in positive human health and environmental effects to Pahala residents by
providing a cleaner and longer-lasting wastewater collection and treatment and treatment and
disposal system.
The Final EA Section 3.16 will include further detail information.
The Draft EA Section 2.1.4 provides a history of wastewater management for Pahala. In
2003, C. Brewer requested assistance from the County to close their large capacity cesspools
as required by the Environmental Protection Agency. The County entered into an agreement
with C. Brewer (in April 2007) and is moving forward with the Pahala Large Capacity
Cesspool Replacement project. The Draft EA Section 2.1.2 states the project may also be
funded by the State of Hawai'i DOH Clean Water State Revolving Fund (CWSRF) Program.
The CWSRF Program was created by the federal Water Quality Act of 1987 and authorizes
low interest loans for the construction of publicly owned wastewater treatment works.
The Draft EA Section 2.3.2 states the new collection system would be subject to the County
of Hawai'i Code (HCC) Chapter 21, Sewers. Specifically, HCC Chapter 21, Article 2 (Public
Sewers), Section 21-5, which states the following:
"(a)Owners of all dwellings, buildings, or properties used for human occupancy,
employment, recreation, or other purposes, which are accessible to a sewer are required at
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March 6. 2020
their expense to connect directly with the public sewer within 180 days after date of official
notice.''''
All accessible properties will be required to connect to the new wastewater collection system
in accordance with Hawaii County Code, Chapter 21, Article 2, Section 21-5. However, the
County entered into an agreement with C. Brewer (in April 2007) to eliminate LCCs from the
existing community sewer systems and connect properties discharging to them to new
County collection, treatment and disposal systems. Once the actual costs are determined,
County Council action is still required to approve the expenditures. The agreement with C.
Brewer did not address newly accessible properties..
The financial impact of the project on individual newly accessible property owners was raised
by the community during the December 2017 public meetings as summarized in Section 7 of
the Draft EA. Although not required by Hawaii Administrative Rules (HAR) Title 11,
Chapter 200, DEM voluntarily convened two additional public meetings on October 9, 2018
and March 21, 2019 to gain further input from newly accessible property owners and present
funding options for them to pursue.
The Draft EA Section 7 will be revised to add that the County held additional meetings in
Pahala including one to provide information on financing sources available to owners of
parcels which would become accessible to the County collection system. The purpose of the
March 21, 2019 meeting was to fulfill a County commitment made in October, 2018 to
research financing options available to the newly accessible residents of the Pahala
Community. At the meeting, DEM provided the preliminary results of the County
investigation into funding sources and options available for newly accessible property
owners once the new treatment and disposal facility and wastewater collection system have
been designed, permitted and constructed.
Programs discussed included:
• US Department of Housing and Urban Development (HUD) with County of Hawaii
Office of Housing and Community Development Residential Repair Program -
Community Block Grant Program, and
• US Department of Agriculture - Rural Development (USDA-RDA) Program.
As noted during the presentation, the programs may change in the coming years and
additional options may be added to this preliminary list. Hawaii Legislature, Senate Bill 221
SD1, which could amend Hawaii Revised Statutes (HRS) Chapter §342D to establish a low
interest loan program to offer financial assistance to cesspool owners to connect to
wastewater treatment systems approved by the Department of Health was also discussed;
however, this bill was subsequently not passed during the 2019 legislative session.
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This information will be included in the Final EA.
8. This is not a comment pertinent to the content requirements of the Draft EA for the Pahala
Large Capacity Cesspool Replacement project.
Regarding the attached resident petition, the Draft EA Section 2.7 describes the site selection
process, including the factors and their relative weights used to evaluate the various sites. The
section further describes the twenty-one criteria within four general categories (environmental,
social and cultural; location and site; land use and availability; and collection system and service
area) that were established and defined for the analysis. The Draft EA Appendix B, Section 8,
provides additional information regarding the site selection process. As a result of this process,
the County identified three sites (Sites 7, 8, and 9) as reasonable alternatives for construction of
the wastewater treatment and disposal facility under the Proposed Action. The final scores for
Sites 7, 8, and 9 were 4.33, 4.06, and 4.10 respectively, out of a total possible score of 5. Based
on this analysis. Site 7 was selected as the Preferred Alternative. The site is easily accessible,
has good soils for a land application system, and is close to the existing LCCs.
The Draft EA Section 2.5 describes Site 9, which is south (makai) of the Preferred Alternative
Site 7. As outlined in Appendix B Section 8, Site 9 earned a lower ranking than Site 7 for the
following criteria: presence of and or proximity to archaeological cultural sites, existing vehicle
access, power and potable water availability, and distance from the area of the wastewater
collection system. Site 7 had a lower ranking than Site 9 in one category: topography. With the
distance between the two sites less than 300 feet, they were ranked equally for the criteria of
proximity of treatment units to existing occupied buildings.
The Draft EA Sections 2.5 and 2.7 provide information as to the issues related to the use of Site 9.
An unnamed stream near the upper portion of the parcel could affect the selected configuration of
the wastewater treatment facility and the land application groves. Potentially, to maximize energy
efficiency by taking advantage of gravity flow, the headworks, lagoons and the subsurface
constructed wetlands could be sited in the upper portion of the site, or the area closest to the
highway. In addition, since the site is located across Mamalahoa Highway from the Pahala
community, it would require construction of piping and other utilities within the highway ROW
and approval by the State of Hawai'i Department of Transportation. Site 9 would require
additional access roads to facilitate both construction and operation of the treatment and disposal
facility and a slightly longer transmission line given its increased distance from the existing LCCs.
This information will be included in the Final EA.
The proposed site plan is included in the Draft EA as Figure 2.3. As noted in Section 2.3.1,
"disposal of the treated and disinfected effluent would be accomplished through land treatment
in four groves of native, water-tolerant trees occupying a total area of approximately 8.0 acres."
This 8.0 acre planted area, combined with the sloping site topography and existing Cook pine
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March 6. 2020
trees {Araucaria cohmmaris) on Maile Street, will provide a visual buffer from both the
Mamalahoa Highway and Maile Street. As outlined in Section 3.19.2 of the Draft EA, the
Proposed Action is not expected to adversely affect the views or viewsheds identified in the
County General Plan. The wastewater collection system would be installed below the streets and
therefore would not impact views. Above-grade structures may include the operations building,
headworks and UV cover structures, fuel storage tank, and low berms around the basins. The
existing pine trees along Maile Street, most of which would remain with no changes, would
continue to obstruct the viewplanes from Maile Street. The facility site would be adjacent
(mauka) to, and visible from, Mamalahoa Highway (State Route 11); however, impacts to the
viewplane would be mitigated by the planted trees in the basins and by the rise in elevation
between the highway and the facility.
Please note, the attached documentation shows the County's attempt to gather information
related to the 6 notarized attachments to your October 23, 2108 letter. Refer to response 4 above
for additional information regarding additional archaeological and geophysical investigations
undertaken since the publication of the Draft EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
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10349-01 ref (55)
March 6, 2020
Mr. Alfred Ibarra
Mrs. Mary Ibarra
P.O. Box 396
Pahala, Hawaii 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - post marked November 13, 2018
Dear Mr. and Ms. Ibarra
Thank you for your comment letter post marked November 13, 2018 regarding the County of
Hawaii Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our responses follow:
The County's intent, as stated in the June 22, 2017 US Environmental Protection Agency Region 9
Administrative Order on Consent (AOC), is to provide an industry-standard wastewater collection
system and a secondary treatment and disposal facility, a basic service to the Pahala community, to
eliminate underground injection from LCCs it operates to help protect underground drinking water
sources. The AOC, which was issued on June 22, 2017 states: "The Pahala Wastewater Treatment
Facility shall be designed in accordance with good engineering practices and capable of servicing
all residential properties currently connected to the Pahala Community Cesspools, plus a minimum
of sixty-five (65) additional properties...An electronic version of the AOC can be found on the
U SEP A website at: https://www.epa.gov/sites/production/files/2017-06/documeiits/sdwa~iiic-aoc-
09-2017-0002-aoc-2017-04-26.pdf.
Closure of individual cesspools is mandated by legislation at the State level. In 2017, Act 125
was enacted by the Hawai'i State legislature requiring all cesspools, not exempted by the
Department of Health, be upgraded or converted to septic systems, or aerobic treatment unit
systems, or connected to sewage systems by January 1, 2050. Though closure of individual
wastewater systems by the County is not part of the Proposed Action, this legislation will affect
all parcels in Pahala currently utilizing cesspools for sewage disposal.
The Draft EA Figure 2.2 shows the collection system on the various streets within the
community. The extent of the collection system is to ensure the parcels connected to the former
C. Brewer system will have access to the treatment and disposal facility so the large capacity
cesspools can be closed. It is conventional to extend the utility to the nearest intersection to
minimize the number of manholes. Similar to Huapala and Puahala Streets, the collection
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
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system in Plkake Street extends to Pakalana Street to meet the objectives of the Ka'u Community
Development Plan and not preclude a future line in Pakalana Street. As stated in the Draft EA,
the proposed collection system is routed primarily within the County right-of-way, for ease of
access for both construction and maintenance.
As outlined in the Draft EA, Section 2.3.2, the new collection system would be subject to the
Hawai'i County Code (HCC) Chapter 21, Sewers, specifically. Article 2 (Public Sewers),
Section 21-5, which states the following:
"(a) Owners of all dwellings, buildings, or properties used for human occupancy, employment,
recreation, or other purposes, which are accessible to a sewer are required at their expense to
connect directly with the public sewer within 180 days after date of official notice. "
Each adjacent lot will be provided with a lateral connection to the sewer main as required by
HCC and standards. Under the Preferred Alternative, the design of the new collection system
would extend between street intersections and include sewer service stub-outs (the lateral
connection to the sewer main) to the lot lines of adjacent properties, including the newly
accessible, to accommodate their eventual connection. Accordingly, to close the existing LCCs,
there will be additional properties in Pahala that would be required to connect to the new
wastewater collection system, at their expense, after it becomes operational. Such properties are
near the existing service area but are presently connected to individual wastewater systems. To
conform to the stated section of HCC, the respective, newly accessible property owners would be
responsible for the design, permitting and completion of sewer service connections between the
County stub-outs and improvements for stated uses on their property, as well as for the proper
closure of their individual wastewater systems. The Draft EA Figure 2.6 shows the area of the
community serviced by the current and proposed collection systems.
All accessible properties will be required to connect to the new wastewater collection system in
accordance with Hawaii County Code, Chapter 21, Article 2, Section 21-5. However, the
County entered into an agreement with C. Brewer (in April 2007) to eliminate LCCs from the
existing community sewer systems and connect properties discharging to them to new County
collection, treatment and disposal systems. Once the actual costs are determined. County
Council action is still required to approve the expenditures.
Although not a comment related to the content requirements of the Draft EA, County of Hawaii
sewer rates are outlined in HCC Chapter 21, Article 4 (Sewer Service Charges):
"Sewer user charges for residential customers shall be assessed to all lots accessible
to a public sewer or public gang cesspools whether connected or not. User charges for
sewer service... shall be according to the schedule shown under section 21-36.1"
The Hawaii County Code Chapter 21 was adopted in 1983.
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On April 25, 2010, a community meeting sponsored by Councilman Guy Enriques was held at
the Pahala Community Center to discuss the Na'alehu and Pahala Large Capacity Cesspool
Replacement project. As part of the meeting, an informational handout prepared by the County's
Wastewater Division provided a brief history of the project documenting that, in 2004, Mayor
Kim's office used a ballot system to get input from property owners regarding different
wastewater treatment disposal alternatives for those property owners connected to the LCCs
who would no longer be served by the C. Brewer system after LCC closure. As reported in the
Draft EA Section 2.1.4, 87 percent of the returned ballots were in favor of the installation of a
new sewer collection system and a treatment and disposal system to be operated and maintained
by the County. The handout indicated that Mayor Kim's office advised the property owners the
County would move forward with a new system for Na'alehu and Pahala on November 5, 2004.
Additionally, the handout stated public meetings were held in both Na'alehu and Pahala in
November 2006 to discuss the wastewater system alternatives. The handout included that
adequate land for the treatment and disposal system had not been identified in Pahala. The
handout also stated that all properties accessible to the new system would be required to connect
in accordance with Hawaii County Code Chapter 21.
The Draft EA Section 7 documents the 5 public meetings held in Pahala December 12, 13 and
14, 2017 to discuss the Pahala Large Capacity Cesspool Replacement project. As documented in
the Draft EA, the community outreach program for the current project was designed as 'talk
story" sessions to optimize community conversations in informal sessions. Further, as
documented in the Draft EA, invitations and announcements for the talk story sessions were
intended to reach all audiences, as follows:
• Property owners with C. Brewer lines on their property were mailed letters from DEM
inviting them to these sessions. The letters included stamped, mail-in postcards to
facilitate the RSVP process.
• Fliers were hand-delivered to ''newlv-accessible" properties.
• Organizational leaders were provided copies of fliers announcing meetings and asked to
circulate among their members.
• Fliers were posted in public venues, such as the post office, the Pahala Community
Center and the Ka'u Hospital.
• Several online announcements were included in Ka'u News Briefs available at
http://kaunewsbriefs.blogspot.com.
This information will be repeated in the Final EA.
On September 26, 2018, a public notice was published in both the Hawaii Tribune Herald and
West Hawaii Today which stated a public meeting was to be held on October 10, 2018 for the
Pahala Large Capacity Cesspool Replacement Project Draft EA. A public notice was also
published in the October 1, 2018 print and online editions of the Ka 'u Calendar and made
available on the Ka'u News Briefs web site http://kaunewsbriefs.blogspot.com. Fliers were also
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posted in public venues such as the community shopping center, realtor office, grocery store,
library, and the Paha la Community Center. This information will be included in the Final EA.
On September 10, 2018, letters containing information on the availability of the Draft EA, the
comment period, and the October 10, 2018 meeting were mailed to all property owners on record
adjacent to the proposed collection system. On October 26, 2018 letters were mailed to all
property owners on record adjacent to the proposed collection system informing them of the
extension of the public comment period to December 10, 2018.
The financial impact of the project on individual newly accessible property owners was raised by
the community during the December 2017 public meetings as summarized in Section 7 of the
Draft EA and again during the October 2018 meetings. Although not required by Hawai'i
Administrative Rules (HAR) Title 11, Chapter 200, DEM voluntarily convened an additional
public meeting on March 21, 2019 to gain further input from newly accessible property owners
and fulfill a County commitment made in October 2018 to research and provide financing
options available for the newly accessible residents of the Pahala Community to pursue.
Programs discussed and included:
• US Department of Housing and Urban Development (HUD) with County of Hawaii
Office of Housing and Community Development Residential Repair Program -
Community Block Grant Program, and
• US Department of Agriculture - Rural Development (USDA-RDA) Program.
As noted during the presentation, these programs may change in the coming years, and additional
options may be added to this preliminary list. Hawaii Legislature, Senate Bill 221 SD1, which
could amend Hawaii Revised Statutes (HRS) Chapter §342D to establish a low interest loan
program offering financial assistance to cesspool owners to connect to wastewater treatment
systems approved by the Department of Health was also discussed; however, this bill was
subsequently not passed during the 2019 legislative session.
This information will be included in the Final EA.
The Draft EA Section 3.9.1 (a) states:
'The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map
(FIRM), Community Panel No. 155166 1800F, effective date September 29, 2017 shows
that most of the Pahala area is located in ZoneX, which designates areas determined to be
outside the 0.2- percent annual chance (500-vear) floodplain. A small portion of the
community of Pahala, including some land within the collection system project site, is
located within ZoneX— Other Flood Areas, indicating areas within the 0.2-percent
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annual chance (500-year) floodplain, or areas with a 1-percent annual chance of flooding
with average flood depths less than 1 foot.
According to the FIRM, both existing LCCs are also located within ZoneX. However,
LCC-1 is very close to the edge of the 500-year floodplain.
On April 16, 2018, in response to the pre-assessment notification, the State of Hawai'i
Department of Land and Natural Resources Engineering Division stated the responsibility
for conducting research as to the flood hazard designation for the project site lies with the
project proponent. Also on April 16, 2018 and in response to the pre-assessment
notification, the County of Hawai'i Department of Public Works confirmed that the
proposed treatment and disposal Site 7 is designated as Zone X on the FIRM and is
outside the 500-year floodplain."
The relevant FIRM panel is reproduced in Appendix B as Figure 4-13.
This information will be repeated in the Final EA.
The Draft EA Section 3.23.2(a) states:
'The proposed wastewater treatment and disposal facility would include an on-site
drainage system to address stormwater surface runoff created by new impervious surfaces
within the facility. The site would include a system to collect runoff via grated inlets or
swales, and flows would be conveyed to on-site drainage detention systems, such as
subsurface linear infiltration or depressed detention basins."
This information will be repeated in the Final EA.
The preferred alternative (Site 7) slopes from approximately north to south (mauka to makai)
such that, during rain events, surface flows drain through the existing orchard to the southern
(makai) end where the flows eventually drain through the culvert located at the Maile Street-
Mamalahoa Highway intersection to the areas below (makai) the highway. Most of the land
surface area below the existing macadamia nut orchard contains little to no vegetation to absorb
or slow these flows. The gradient of Site 7 and surrounding area results in this natural pattern of
surface flows which also existed when the area was planted in sugar cane and is not considered
flooding.
Based on the roadway flooding concerns expressed by the community during the Pahala public
meetings held in December 2017 and October 2018, the State of Hawai'i Department of
Transportation (DOT) Hawai'i District office was contacted to discuss drainage at the treatment
and disposal facility project site and the culvert at the Maile Street and Mamalahoa Highway
intersection. On February 20, 2019, the District office confirmed via telephone that the DOT
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owns and maintains the culvert at the Maile Street intersection, and that they have no record of
the roadway being inundated by stormwater drainage during precipitation events at that location.
Stormwater runoff generated mauka of the treatment and disposal facility project site will be
directed around the perimeter of the site via diversion swales that will convey flows back to the
existing drainage pattern that flows to the existing culvert at Maile Street. During heavy rain
events, stormwater may temporarily back up behind the culvert. There will be no changes to this
culvert and the proposed treatment and disposal facilities will not be located within the area of
the culvert.
As stated in the Draft EA, the on-site stormwater management system would meet the
requirements of Hawai'i County Code (HCC), Chapter 27 Floodplain Management, Section 20,
Standards for subdivisions and other developments (e) which mandates a site drainage plan to
"comply with sections 27-20(a) and (b) and section 27-24, and shall include a storm water
disposal system to contain run-off caused by the proposed development, within the site
boundaries, up to the expected [design] storm event as shown in the department of public works
"Storm Drainage Standards".
To meet the requirements of HCC, Chapter 27, Section 20 (f), the project site "shall not alter the
general drainage pattern above or below the development". Thus, for the HCC design storm
event, no increase in flow amount will be directed to either of the culverts at the highway as a
result of the site development. A drainage report will be prepared during the design process to
evaluate the improvements that are necessary to comply with Chapter 27 HCC requirements.
The wastewater treatment processes will be designed to accommodate the associated peak flows,
including precipitation that falls on the area occupied by the aerated lagoon treatment system.
The Draft EA Appendix B, Section 2.2 outlines the anticipated peak wastewater flows from the
community, based on the applicable flow standard. The Draft EA Section 2.3.1, states the
aerated lagoons will be lined to prevent water seepage through the bottom and sides of the
lagoons. The Draft EA, Appendix B, Section 5.3 shows the operational freeboard that will be
available to contain and to equalize lagoon flows. In addition, the slow-rate land application
groves will be designed to completely contain both peak effluent flows and precipitation from a
100-vear, 24-hour storm event. A geotechnical engineering assessment of berm stability will be
conducted during the design process for berms intended to act as secondary containment. The
tree groves will be designed in accordance with the EPA's "Process Design Manual, Land
Treatment of Municipal Wastewater Effluents". Effluent will be applied at a hydraulic loading
rate that is a small percentage of the percolation rate of the soil, ensuring sufficient capacity for
assimilation of peak effluent flow rates and precipitation from the design storm event.
This information will be included in the Final EA.
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Letter to Mr. Alfred Ibarra/Mrs. Mary Ibarra
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March 6, 2020
The Draft EA Section 2.7 describes the site selection process, including the factors and their
relative weights used to evaluate the various sites. Further, Section 2.7 describes the twenty-one
criteria within four general categories (environmental, social and cultural; location and site; land
use and availability; and collection system and service area) that were established and defined for
the analysis. The Draft EA Appendix B, Section 8, provides additional information regarding
the site selection process. As a result of this process, the County identified three sites (Sites 7, 8,
and 9) as reasonable alternatives for construction of the wastewater treatment and disposal
facility under the Proposed Action. The final scores for Sites 7, 8, and 9 were 4.33, 4.06, and
4.10 respectively, out of a total possible score of 5. Based on this analysis. Site 7 was selected as
the Preferred Alternative. The site is easily accessible, has good soils for a land application
system, and is close to the existing LCCs.
The Draft EA Section 2.5 describes Site 9, which is south (makai) of the Preferred Alternative
Site 7. As outlined in Appendix B Section 8, Site 9 earned a lower ranking than Site 7 for the
following criteria: presence of and or proximity to archaeological cultural sites, existing vehicle
access, power and potable water availability, and distance from the area of the wastewater
collection system. Site 7 had a lower ranking than Site 9 in one category: topography. With the
distance between the two sites less than 300 feet, they were ranked equally for the criteria of
proximity of treatment units to existing occupied buildings.
The Draft EA Sections 2.5 and 2.7 provide information as to the issues related to the use of Site
9. An unnamed stream near the upper portion of the parcel could affect the selected
configuration of the wastewater treatment facility and the land application groves. Potentially, to
maximize energy efficiency by taking advantage of gravity flow, the headworks, lagoons and the
subsurface constructed wetlands could be sited in the upper portion of the site, or the area closest
to the highway. In addition, since the site is located across Mamalahoa Highway from the Pahala
community, it would require construction of piping and other utilities within the highway ROW
and approval by the State of Hawai'i Department of Transportation. Site 9 would require
additional access roads to facilitate both construction and operation of the treatment and disposal
facility and a slightly longer transmission line given its increased distance from the existing
LCCs.
This information will be included in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
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cc: W. Kucharski. COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
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WILSON OKAMOTO
COUP T t § II
10349-01
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ref (56)
Mr. Walter T.L. and Ms. Debra A. Wong Yuen
P.O.Box 29
Pahala, Hawai'i 96777
Subject: Draft Environmental Assessment for the,
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - November 14, 2018
Dear Mr. and Ms. Wong Yuen:
Thank you for your November 14, 2018 comment letter regarding the County of Hawai'i
Department of Environmental Management Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement project. Our responses follow:
The Draft EA Section 2.1.3 states: "In 1999, EPA promulgated regulations under the Safe
Drinking Water Act's Lender ground Injection Control (UIC) Program which prohibited the
construction of new large capacity cesspools (LCCs) as of April 2000 and required the closure of
all existing LCCs by April 5, 2005 (see 40 C.F.R. § 144.88). Under federal regulations, an LCC
is a cesspool which serves multiple dwellings, or for non-residential facilities has the capacity to
serve 20 or more persons per day. Cesspools can release disease-causing pathogens and other
pollutants (e.g., nitrates) into ground water aquifers, streams, and eventually the ocean, thus
leading to public health and environmental concerns. In June 2017, EPA and the County entered
into an Administrative Order on Consent (AOC) to close the County-operated LCCs serving the
Pahala Community by June 2021."
The Final EA Section 2.1.3 will include the County has previously abandoned or assisted with
closure of other LCCs in locations including Hilo, Kona, Honokaa and Pahala.
The County's intent, as stated in the June 22, 2017 US Environmental Protection Agency Region
9 Administrative Order on Consent is to provide an industry-standard wastewater collection
system and a secondary treatment and disposal facility, a basic service to the Pahala community,
to eliminate underground injection from LCCs it operates to help protect underground drinking
water sources. Closure of individual cesspools is mandated by legislation at the State level. In
2017, Act 125 was enacted by the Hawai'i State legislature requiring all cesspools, not exempted
by the Department of Health, be upgraded or converted to septic systems, or aerobic treatment
unit systems, or connected to sewage systems by January 1, 2050. Though closure of individual
wastewater systems by the County is not part of the Proposed Action, this legislation will affect
all parcels in Pahala currently using cesspools for sewage disposal.
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
10349-01
Letter to Mr. Walter T.L. and Ms. Debra A. Wong Yuen
Page 2
March 6, 2020
The Final EA Section 3.16 will include further detail information.
The Draft EA Section 5.7 will be revised as follows
Executive Order 12898, Environmental Justice (full title Federal Actions to Address
Environmental Justice to Minority and Low Income Populations), was signed on February 11,
1994. The intent of Executive Order 12898 is to avoid disproportionately high adverse human
health or environmental effects of projects on minority and low income populations. Executive
Order 12898 also requires federal agencies ensure that minority and low-income communities
have adequate access to public information related to health and the environment.
The 2017 American Community Survey (ACS) (5-Year Estimates) is the most recent
information related to socioeconomic conditions in the state and County. The 2017 ACS includes
Hawai'i Geographic Area Profiles - Census Designated Places: Neighbor Islands. The ACS
noted it is the Census Bureau's Population Estimates Program that produces and disseminates the
official estimates of the population for the nation, states, counties, cities and towns and estimates
of housing units for states and counties.
For purposes of this assessment, and to correspond with the available ACS demographic
characteristic data, "low income" is defined as having a household income of less than $24,999;
"minority" is defined as any race population other than White; and "children" is defined as the
"Under 5 to 19" age category. Pahala has more households in the "less than $24,999" income
bracket (33.7 percent) than the County as a whole (26.3 percent).
Overall, Pahala is characterized by a racial composition that includes a greater proportion of
minorities (92.1 percent non-White) than the County at large (66.8 percent non-White). The
racial distribution includes a much lower proportion of White residents, a much higher
proportion of Filipino residents, and lower populations of other minority groups, including
Native Hawaiians when compared to the County. There are also more residents of two or more
races in Pahala than in the County.
Pahala has a similar age distribution to Hawai'i County, although Pahala has a higher proportion
of individuals in the 'Under 5 to 19" age category (28.5 percent) compared to the County as a
whole (24.4 percent).
Based on the above, Pahala has a higher proportion of low-income, minority, and children
residents as compared to the County as a whole. However, the Proposed Action will not result in
disproportionately high and adverse human health or environmental effects on these sensitive
populations. The design and location of the proposed wastewater treatment and disposal facility
will minimize odor and air quality impacts. Construction of the wastewater collection system
will result in intermittent and unavoidable noise from construction vehicles and equipment
within the Pahala community, including noise associated with the removal of bedrock. However,
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Letter to Mr. Walter T.L. and Ms. Debra A. Wong Yuen
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March 6, 2020
construction activities within the community will comply with provisions of HAR 11-46
(Community Noise Control). This includes obtaining a noise permit for any activities that will
generate noise exceeding the permissible sound levels specified in HAR 11-46. The permit will
limit excessive noise sources to daytime hours; will require the use of best available control
technology to control noise levels from excessive noise sources; and will require the applicant to
notify affected members of the public in advance of any planned nighttime construction activity
(which must not exceed the permissible sound levels). Overall, the Proposed Action is expected
to result in positive human health and environmental effects to Pahala residents by providing a
cleaner and longer-lasting wastewater treatment system.
Based on the above, construction and operation of the collection system and the treatment and
disposal facility would have a disproportionately high adverse impact on the minority and low
income population in the Pahala community."
This information will be included in the Final EA.
The financial impact of the project on individual newly accessible property owners was raised by
the community during the December 2017 public meetings as summarized in Section 7 of the
Draft EA. Although not required by Hawaii Administrative Rules (HAR) Title 11, Chapter 200,
DEM convened two additional public meetings one on October 9, 2018 and another on March
21, 2019 to gain further input from newly accessible property owners and present funding
options for them to pursue.
The Draft EA Section 7 will be revised to add that the County held additional meetings in Pahala
including one to provide information on financing sources available to owners of parcels which
would become accessible to the County collection system. The purpose of the March 21, 2019
meeting was to fulfill a County commitment made in October, 2018 to research financing
options available to the newly accessible residents of the Pahala Community. At the meeting,
DEM provided the preliminary results of the County investigation into funding sources and
options available for newly accessible property owners once the new treatment and disposal
facility and wastewater collection system have been designed, permitted and constructed.
Programs discussed included:
• US Department of Housing and Urban Development (HUD) with County of Hawaii
Office of Housing and Community Development Residential Repair Program -
Community Block Grant Program, and
• US Department of Agriculture - Rural Development (USDA-RDA) Program.
As noted during the presentation, these programs may change in the coming years, and additional
options may be added to this preliminary list. Hawaii Legislature, Senate Bill 221 SD1, which
could amend Hawaii Revised Statutes (HRS) Chapter §342D to establish a low interest loan
10349-01
Letter to Mr. Walter T.L. and Ms. Debra A. Wong Yuen
Page 4
March 6, 2020
program to offer financial assistance to cesspool owners to connect to wastewater treatment
systems approved by the Department of Health was also discussed; however, this bill was
subsequently not passed during the 2019 legislative session.
This information will be included in the Final EA.
The Final EA Section 7 will include that on September 26, 2018 a public notice was published in
the Hawaii Tribune Herald and West Hawaii Today newspapers. The public notice was to
advertise the October 10, 2018, public information meeting conducted by the County in the
Pahala at the Ka'u Gym Multi-Purpose Conference Room to discuss the availability of the Draft
EA and process for submitting comments. The notice stated that the second part of the meeting
would address Section 106 of the National Historic Preservation Act of 1966, as amended (2006)
involving consultation with Native Hawaiian Organizations and the Native Hawaiian
descendants with ancestral lineal or cultural ties to, cultural knowledge or concerns for, and
cultural religious attachment to the proposed project area. The Office of Environmental Quality
Control rules have no provision for receiving oral comments. However, the facilitator at that
meeting offered assistance by persons available at the meeting in putting any oral comments
attendees may wish to offer into writing.
The Draft EA Section 2.7 describes the site selection process, including the factors and their
relative weights used to evaluate the various sites. Further, Section 2.7 describes the twenty-one
criteria within four general categories (environmental, social and cultural; location and site; land
use and availability; and collection system and service area) that were established and defined for
the analysis. The Draft EA Appendix B, Section 8, provides additional information regarding
the site selection process. As a result of this process, the County identified three sites (Sites 7, 8,
and 9) as reasonable alternatives for construction of the wastewater treatment and disposal
facility under the Proposed Action. The final scores for Sites 7, 8, and 9 were 4.33, 4.06, and
4.10 respectively, out of a total possible score of 5. Based on this analysis. Site 7 was selected as
the Preferred Alternative. The site is easily accessible, has good soils for a land application
system, and is close to the existing LCCs.
The Draft EA Section 2.5 describes Site 9, which is south (makai) of the Preferred Alternative
Site 7. As outlined in Appendix B Section 8, Site 9 earned a lower ranking than Site 7 for the
following criteria: presence of and or proximity to archaeological cultural sites, existing vehicle
access, power and potable water availability, and distance from the area of the wastewater
collection system. Site 7 had a lower ranking than Site 9 in one category: topography. With the
distance between the two sites less than 300 feet, they were ranked equally for the criteria of
proximity of treatment units to existing occupied buildings.
The Draft EA Sections 2.5 and 2.7 provide information as to the issues related to the use of Site
9. An unnamed stream near the upper portion of the parcel could affect the selected
configuration of the wastewater treatment facility and the land application groves. Potentially, to
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10349-01
Letter to Mr. Walter T.L. and Ms. Debra A. Wong Yuen
Page 5
March 6, 2020
maximize energy efficiency by taking advantage of gravity flow, the headworks, lagoons and the
subsurface constructed wetlands could be sited in the upper portion of the site, or the area closest
to the highway. In addition, since the site is located across Mamalahoa Highway from the Pahala
community, it would require construction of piping and other utilities within the highway ROW
and approval by the State of Hawai'i Department of Transportation. Site 9 would require
additional access roads to facilitate both construction and operation of the treatment and disposal
facility and a slightly longer transmission line given its increased distance from the existing
LCCs.
This information will be included in the Final EA.
HRS 343 Section 5 (a)(9)(A), states as follows: "(a) Except as otherwise provided,
an environmental assessment (emphasis added) shall be required for actions that: ... (9) Propose
any: (A) Wastewater treatment unit, except an individual wastewater system or a wastewater
treatment unit serving fewer than fifty single-family dwellings or the equivalent..
HRS 343-5 Applicability and requirements states under item (c) (4) "A(n environmental
impact) statement shall be required if the agency finds that the proposed action may have a
significant effect on the environment..The criteria by which the proposing agency makes the
significance determination is provided in HAR 11- 200-12 (a) and (b) which states: "(a) In
considering the significance of potential environmental effects, agencies shall consider the sum
of the effects on the quality of the environment, and shall evaluate the overall and cumulative
effects of an action, (b) In determining whether an action may have a significant effect on the
environment, the agency shall consider every phase of a proposed action, the expected
consequences,... and the... effects of the action."
HAR 11-200-10 Contents of an environmental assessment includes "(9) Findings and reasons
supporting the agency determination or anticipated determination..." The Draft EA provides this
information in Chapter 8 Findings and Determination. Neither HRS Chapter 343 nor HAR Title
11, Chapter 200 contain any requirement that all proposed wastewater systems require an EIS.
The Draft EA Section 3.15 references a November 2016 archaeological field inspection report
undertaken as part of the initial planning for the LCC closure. The report states, while the
historical ground modifications have likely limited the archaeological potential of the site, the
discovery of both pre- and post-contact surface artifacts within the 42.5-acre parcel (which
includes Site 7), as well as evidence from plantation-era documents that the opening of a lava
tube containing human remains once existed in the southeastern corner of the parcel, indicate
that further archaeological studies may be necessary. The Final EA will include that the
November 2016 archaeological field inspection report also stated it would be advisable to limit
the development footprint to exclude the southeastern corner of the 42.5-acre parcel. This area,
which is presently not used as a macadamia nut orchard, but forms part of the macadamia nut
plant, is the location of a known (but sealed) lava tube opening that local informants have
10349-01
Letter to Mr. Walter T.L. and Ms. Debra A. Wong Yuen
Page 6
March 6, 2020
indicated is linked to tubes that possess traditional human burials. Further, by excluding this
section of the parcel, it will be possible to avoid at least one known historic property. The Draft
EA Figure 2.3, which provides the Preliminary Site Plan for the new treatment and disposal
facility, shows the 14.9-acre project site has been developed to exclude the area in the
southeastern corner identified as the location of the sealed lava tube opening.
Between September 18, 2018 and January 10, 2019 a team of qualified archaeologists conducted
a pedestrian survey of the proposed project site and completed subsurface trenching to determine
the presence of archaeological resources. The work was undertaken in accordance with the State
of Hawaii Department of Land and Natural Resources State Historic Preservation Division
(SHPD) requirements, with the archaeological inventory survey (AIS) approach accepted by
SHPD in their August 20, 2018 letter. The results of the survey and subsurface trenching
showed no burials or lava tube openings were identified on-site. The AIS submitted to SHPD in
March 2019 documents that a sealed lava tube opening is located east of the proposed
wastewater treatment and disposal facility project site, outside the proposed property boundary,
and outside of the area of potential effect considered in consultation with the SHPD.
The complete document is available for download from the County's website
at: http://records,co.hawan.hi.us/weblink/l/edoc/100962/Dfaft%20ArcheQlogieal%20Inventory~
%20Siirvev%20-%20Pahaia%20WWlP%20and%20Sewer%20Svstem.pdf
A geophysical survey of the proposed project area will be performed during detailed design with
the specific intent to locate subsurface voids (such as lava tubes) present beneath the site that
may impact design and construction of the new wastewater treatment, disposal and collection
system.
This information will be included in the Final EA.
The Draft EA Section 3.9.1 (a) states:
"The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM),
Community Panel No. 155166 1800F, effective date September 29, 2017 shows that most of
the Pahala area is located in Zone A', which designates areas determined to be outside the 0.2-
percent annual chance (500-vear) floodplain. A small portion of the community of Pahala,
including some land within the collection system project site, is located within Zone X—
Other Flood Areas, indicating areas within the 0.2-percent annual chance (500-year)
floodplain, or areas with a 1-percent annual chance of flooding with average flood depths
less than 1 foot.
According to the FIRM, both existing LCCs are also located within ZoneX. However, LCC-1
is very close to the edge of the 500-year floodplain.
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10349-01
Letter to Mr. Walter T.L. and Ms. Debra A. Wong Yuen
Page 7
March 6, 2020
On April 16, 2018, in response to the pre-assessment notification, the State of Havvai'i
Department of Land and Natural Resources Engineering Division stated the responsibility for
conducting research as to the flood hazard designation for the project site lies with the project
proponent. Also on April 16, 2018 and in response to the pre-assessment notification, the
County of Havvai'i Department of Public Works confirmed that the proposed treatment and
disposal project site at Site 7 is designated as Zone X on the FIRM and is outside the 500-
vear floodplain."
The relevant FIRM panel is reproduced in Appendix B as Figure 4-13.
This information will be repeated in the Final EA.
The Draft EA Section 3.23.2 (a) states:
"The proposed wastewater treatment and disposal facility would include an on-site drainage
system to address stormwater surface runoff created by new impervious surfaces within the
facility. The site would include a system to collect runoff via grated inlets or swales, and
flows would be conveyed to on-site drainage detention systems, such as subsurface linear
infiltration or depressed detention basins."
This information will be repeated in the Final EA.
The preferred alternative (Site 7) slopes from approximately north to south (mauka to makai)
such that, during rain events, surface flows pass through the existing orchard to the southern
(makai) end where the flows eventually drain through the culvert located at the Maile Street-
Mamalahoa Highway intersection to the areas below (makai) the highway. Most of the land
surface area below the existing macadamia nut orchard contains little to no vegetation to absorb
or slow these flows. The gradient of Site 7 and surrounding area results in this natural pattern of
surface flows which also existed when the area was planted in sugar cane and is not considered
flooding.
Based on the roadway flooding concerns expressed by the community during the Paha la public
meetings held in December 2017 and October 2018, the State of Hawai'i Department of
Transportation (DOT) Hawai'i District office was contacted to discuss drainage at the treatment
and disposal facility project site and the culvert at the Maile Street and Mamalahoa Highway
intersection. On February 20, 2019, the District office confirmed via telephone that the DOT
owns and maintains the culvert at the Maile Street intersection, and that they have no record of
the roadway being inundated by stormwater drainage during precipitation events at that location.
Stormwater runoff generated from mauka of the treatment and disposal facility project site will
be directed around the perimeter of the site via diversion swales that will convey flow back to the
existing drainage pattern that flows to the existing culvert at Maile Street. During heavy rain
10349-01
Letter to Mr. Walter T.L. and Ms. Debra A. Wong Yuen
Page 8
March 6, 2020
events, stormwater may temporarily back up behind the culvert. There will be no changes to this
culvert and the proposed treatment and disposal facilities will not be located within the area of
the culvert.
As stated in the Draft EA, the on-site stormwater management system would meet the
requirements of Hawai'i County Code (HCC), Chapter 27 Floodplain Management, Section 20,
Standards for subdivisions and other developments (e) which mandates a site drainage plan to
"comply with sections 27-20(a) and (b) and section 27-24, and shall include a storm water
disposal system to contain run-off caused by the proposed development, within the site
boundaries, up to the expected [design] storm event as shown in the department of public works
"Storm Drainage Standards"."
To meet the requirements of HCC, Chapter 27, Section 20 (f), the project site "shall not alter the
general drainage pattern above or below the development". Thus, for the HCC design storm
event, no increase in flow amount will be directed to either of the culverts at the highway as a
result of the site development. A drainage report will be prepared during the design process to
evaluate the improvements necessary to comply with HCC Chapter 27 requirements.
The wastewater treatment processes will be designed to accommodate the associated peak flows,
including precipitation that falls on the area occupied by the aerated lagoon treatment system.
The Draft EA Appendix B, Section 2.2 outlines the anticipated peak wastewater flows from the
community, based on the applicable flow standard. The Draft EA Section 2.3.1, states the
aerated lagoons will be lined with high density polyethylene liners to prevent water seepage
through the bottom and sides of the lagoons. The Draft EA Appendix B, Section 5.3 shows the
operational freeboard that will be available to contain and to equalize lagoon flows. In addition,
the slow-rate land application groves will be designed to completely contain both peak effluent
flows and precipitation from a 100-vear, 24-hour storm event. A geotechnical engineering
assessment of berm stability will be conducted during the design process. The tree groves will
be designed in accordance with the EPA's "Process Design Manual, Land Treatment of
Municipal Wastewater Effluents". Effluent will be applied at a hydraulic loading rate that is a
small percentage of the percolation rate of the soil, ensuring sufficient capacity for assimilation
of peak effluent flow rates and precipitation from the design storm event.
Final EA Section 2.3.1 will state the entire wastewater treatment and disposal facility would be
enclosed with a six-foot-high chain-link fence to prevent public access at the gated access
driveway entrance.
The proposed site plan is included in the Draft EA as Figure 2.3. As noted in Section 2.3.1,
"disposal of the treated and disinfected effluent would be accomplished through land treatment
in four groves of native, water-tolerant trees occupying a total area of approximately 8.0 acres."
This 8.0 acre planted area, combined with the sloping site topography, berms, and existing Cook
pine trees {Araucaria cohmmaris) on Maile Street, will provide a visual buffer from both the
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10349-01
Letter to Mr. Walter T.L. and Ms. Debra A. Wong Yuen
Page 9
March 6, 2020
Mamalahoa Highway and Maile Street. As outlined in Section 3.19.2 of the Draft EA, the
Proposed Action is not expected to adversely affect the views or viewsheds identified in the
County General Plan. The wastewater collection system would be installed below the streets and
therefore would not impact views. Above-grade structures may include the operations building,
headworks and UV cover structures, fuel storage tank and berms around the basins. The existing
pine trees along Maile Street, most of which would remain with no changes, would continue to
obstruct the viewplanes from Maile Street. The facility site would be adjacent (mauka) to, and
visible from, Mamalahoa Highway (State Route 11); however, impacts to the viewplane would
be mitigated by the planted trees in the basins and by the rise in elevation between the highway
and the facility.
The Draft EA Section 2.3.1 states the driveway access to the wastewater treatment and disposal
facility will be located west (mauka) of the Maile Street and Mamalahoa Highway intersection.
Appropriate signs identifying the plant will be posted at the driveway access.
This information will be included in the Final EA.
The Draft EA Section 3.14.2 states:
"Wastewater treatment plants can be a source of nuisance odors to the surrounding
community if not properly designed or operated. Typically, nuisance odors are most
commonly associated with anaerobic (without oxygen) conditions and with processing of
residual solids. Incoming raw sewage flows to the proposed wastewater treatment and
disposal facility would first be routed to the headworks, which is the facility where the
solids are removed from the flows.
To mitigate potential nuisance odors, the headworks would be equipped with an odor
control system with a granulated activated carbon (GAC) scrubber to remove odors. A
package GAC scrubber passes the odorous air through a bed of activated carbon, which
adsorbs the odorous constituents within the pore spaces of the carbon. The County
currently operates GAC scrubbers at other facilities, and it has been proven to be an
effective means of odor control both locally and nationwide. The treatment lagoons
would be equipped with mechanical aerators capable of maintaining sufficiently aerobic
(with oxygen) conditions within the water column, which would prevent nuisance odor
conditions from occurring. The disposal groves would be irrigated with fully-treated and
aerobic secondary effluent from the treatment process; irrigation with secondary effluent
is not associated with development of nuisance odor conditions."
This information will be repeated in the Final EA Section 3.14.2.
10349-01
Letter to Mr. Walter T.L. and Ms. Debra A. Wong Yuen
Page 10
March 6, 2020
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
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10349-01
March 6, 2020
ref(63)
Ms. Gwendolyn Sorensen
P.O. Box 27
Pahala, Hawai'i 96777
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment- November 2, 2018; 2:37 p.m.
Dear Ms. Sorensen:
Thank you for your November 2, 2018 2:37 p.m. comment letter regarding the County of
Hawai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our responses follow:
1. a.
The proposed site plan is included in the Draft EA as Figure 2.3. As noted in Section 2.3.1,
"disposal of the treated and disinfected effluent would be accomplished through land treatment
in four groves of native, water-tolerant trees occupying a total area of approximately 8.0 acres."
This 8.0 acre planted area, combined with the sloping site topography and existing Cook pine
trees {Araucaria cohmmaris) on Maile Street, will provide a visual buffer from both the
Mamalahoa Highway and Maile Street. As outlined in Section 3.19.2 of the Draft EAthe
Proposed Action is not expected to adversely affect the views or viewsheds identified in the
County General Plan. The wastewater collection system would be installed below the streets and
therefore would not impact views. Above-grade structures may include the operations building,
headworks and UV cover structures, fuel storage tank, and low berms around the basins. The
existing pine trees along Maile Street, most of which would remain with no changes, would
continue to obstruct the viewplanes from Maile Street. The facility site would be adjacent
(mauka) to, and visible from, Mamalahoa Highway (State Route 11); however, impacts to the
viewplane would be mitigated by the planted trees in the basins and by the rise in elevation
between the highway and the facility. The property will be fenced and driveway access will be
gated to prevent public access along with appropriate signage.
The Draft EA Sections 2.5 and 2.7 provide information as to the issues related to the use of Site
9 including its visibility from the highway. Potentially, to maximize energy efficiency by taking
advantage of gravity flow, the headworks, lagoons and the subsurface constructed wetlands
could be sited in the upper portion of the site, or the area closest to the highway, without the
benefit of viewplane mitigation by the planted trees in the basins and by the rise in elevation
between the highway and the facility."
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
10349-01
Letter to Ms. Gwendolyn Sorensen
Page 2
March 6, 2020
1. b.
The Draft EA Section 3.9.1 (a) states:
"The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM),
Community Panel No. 155166 1800F, effective date September 29, 2017 shows that most of
the Pahala area is located in Zone X, which designates areas determined to be outside the 0.2-
percent annual chance (500-vear) floodplain. A small portion of the community of Pahala,
including some land within the collection system project site, is located within Zone X—
Other Flood Areas, indicating areas within the 0.2-percent annual chance (500-year)
floodplain, or areas with a 1-percent annual chance of flooding with average flood depths
less than 1 foot.
According to the FIRM, both existing LCCs are also located within ZoneX. However, LCC-
1 is very close to the edge of the 500-year floodplain.
On April 16, 2018, in response to the pre-assessment notification, the State of Hawai'i
Department of Land and Natural Resources Engineering Division stated the responsibility for
conducting research as to the flood hazard designation for the project site lies with the project
proponent. Also on April 16, 2018 and in response to the pre-assessment notification, the
County of Hawai'i Department of Public Works confirmed that the proposed treatment and
disposal project site at Site 7 is designated as Zone X on the FIRM and is outside the 500-
year floodplain."
The relevant FIRM panel is reproduced in Appendix B as Figure 4-13.
This information will be repeated in the Final EA.
The Draft EA Section 3.23.2 (a) states:
"The proposed wastewater treatment and disposal facility would include an on-site drainage
system to address stormwater surface runoff created by new impervious surfaces within the
facility. The site would include a system to collect runoff via grated inlets or swales, and
flows would be conveyed to on-site drainage detention systems, such as subsurface linear
infiltration or depressed detention basins."
This information will be repeated in the Final EA.
The preferred alternative (Site 7) slopes from approximately north to south (mauka to makai)
such that, during rain events, surface flows pass through the existing orchard to the southern
(makai) end where the flows eventually drain through the culvert located at the Maile Street-
Mamalahoa Highway intersection to the areas below (makai) the highway. Most of the land
surface area below the existing macadamia nut orchard contains little to no vegetation to absorb
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10349-01
Letter to Ms. Gwendolyn Sorensen
Page 3
March 6, 2020
or slow these flows. The gradient of Site 7 and surrounding area results in this natural pattern of
surface flows which also existed when the area was planted in sugar cane and is not considered
flooding.
Based on the roadway flooding concerns expressed by the community during the Paha la public
meetings held in December 2017 and October 2018, the State of Hawai'i Department of
Transportation (DOT) Hawai'i District office was contacted to discuss drainage at the treatment
and disposal facility project site and the culvert at the Maile Street and Mamalahoa Highway
intersection. On a telephone call on February 20, 2019, the District office indicated the DOT
owns and maintains the culvert at the Maile Street intersection, and that they have no record of
the roadway being inundated by stormwater drainage during precipitation events at that location.
Stormwater runoff generated mauka of the treatment and disposal facility project site will be
directed around the perimeter of the site via diversion swales that will convey flow back to the
existing drainage pattern that flows to the existing culvert at Maile Street. During heavy rain
events, stormwater may temporarily back up behind the culvert. There will be no changes to this
culvert and the proposed treatment and disposal facility will not be located within the area of the
culvert.
As stated in the Draft EA, the on-site stormwater management system would meet the
requirements of Hawai'i County Code (HCC), Chapter 27 Floodplain Management, Section 20,
Standards for subdivisions and other developments (e) which mandates a site drainage plan to
"comply with sections 27-20(a) and (b) and section 27-24, and shall include a storm water
disposal system to contain run-off caused by the proposed development, within the site
boundaries, up to the expected [design] storm event, as shown in the department of public works
"Storm Drainage Standards"."
To meet the requirements of HCC, Chapter 27, Section 20 (f), the project "shall not alter the
general drainage pattern above or below the development". Thus, for the HCC design storm
event, no increase in flow amount will be directed to either of the culverts at the highway as a
result of the site development. A drainage report will be prepared during the design process to
evaluate the improvements necessary to comply with HCC Chapter 27 requirements.
The wastewater treatment processes will be designed to accommodate the associated peak flows,
including precipitation that falls on the area occupied by the aerated lagoon treatment system.
The Draft EA Appendix B, Section 2.2 outlines the anticipated peak wastewater flows from the
community, based on the applicable flow standard. The Draft EA Section 2.3.1, states the
aerated lagoons will be lined to prevent water seepage through the bottom and sides of the
lagoons. The Draft EA Appendix B, Section 5.3 shows the operational freeboard that will be
available to contain and to equalize lagoon flows. In addition, the slow-rate land application
groves will be designed to completely contain both peak effluent flows and precipitation from a
100-vear, 24-hour storm event. A geotechnical engineering assessment of berm stability will be
10349-01
Letter to Ms. Gwendolyn Sorensen
Page 4
March 6, 2020
conducted during the design process for any berms intended to act as secondary containment.
The tree groves will be designed in accordance with the EPA's "Process Design Manual, Land
Treatment of Municipal Wastewater Effluents". Effluent will be applied at a hydraulic loading
rate that is a small percentage of the percolation rate of the soil, ensuring sufficient capacity for
assimilation of peak effluent flow rates and precipitation from the design storm event.
2.
The Draft EA Section 2.3.1 provides a detailed description of the proposed treatment and
disposal system, descriptions of the various facilities and their functions, a schematic drawing of
the various processes, the proposed site plan, and a description of the various areas which have
the potential to be disturbed during construction. Further, Section 2.3.2 describes the wastewater
collection system, including the streets where the system would be routed and the two phases for
construction. Lastly, Section 2.3.3 describes closure of the two large capacity cesspools, as
required by the US Environmental Protection Agency, and abandonment of the existing
collection system.
The County's intent, as stated in the June 22, 2017 US Environmental Protection Agency Region
9 Administrative Order on Consent is to provide an industry-standard wastewater collection
system and a secondary treatment and disposal facility, a basic service to the Paha la community,
to eliminate underground injection from LCCs it operates to help protect underground drinking
water sources. Closure of individual cesspools is mandated by legislation at the State level. In
2017, Act 125 was enacted by the Hawai'i State legislature requiring all cesspools, not exempted
by the Department of Health, be upgraded or converted to septic systems, or aerobic treatment
unit systems, or connected to sewage systems by January 1, 2050. Though closure of individual
wastewater systems by the County is not part of the Proposed Action, this legislation will affect
all parcels in Paha la currently utilizing cesspools for sewage disposal.
3.
The financial impact of the project on individual newly accessible property owners was raised by
the community during the December 2017 public meetings as summarized in Section 7 of the
Draft EA and again during the October 2018 meetings. Although not required by Hawai'i
Administrative Rules (HAR) Title 11, Chapter 200, DEM voluntarily convened an additional
public meeting on March 21, 2019 to gain further input from newly accessible property owners
and fulfill a County commitment made in October 2018 to research and provide financing
options available for the newly accessible residents of the Pahala Community to pursue.
Programs discussed and included:
• US Department of Housing and Urban Development (HUD) with County of Hawai'i
Office of Housing and Community Development Residential Repair Program -
Community Block Grant Program, and
• US Department of Agriculture - Rural Development (USDA-RDA) Program.
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10349-01
Letter to Ms. Gwendolyn Sorensen
Page 5
March 6, 2020
As noted during the presentation, these programs may change in the coming years, and additional
options may be added to this preliminary list. Havvai'i Legislature, Senate Bill 221 SD1, which
could amend Hawai'i Revised Statutes (HRS) Chapter §342D to establish a low interest loan
program to offer financial assistance to cesspool owners to connect to wastewater treatment
systems approved by the Department of Health was also discussed; however, this bill was
subsequently not passed during the 2019 legislative session.
This information will be included in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
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10349-01 ref (62)
March 6, 2020
Mr. Prodincio Fuerte
P.O. Box 725
Pahala, Hawai'i 96777
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - November 18, 2018
Dear Mr. Fuerte:
Thank you for your comment letter received on November 18, 2018 regarding the County of
Hawai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our responses follow:
The Draft EA Section 2.7 describes the site selection process, including the factors and their
relative weights used to evaluate the various sites. Further, Section 2.7 describes the twenty-one
criteria within four general categories (environmental, social and cultural; location and site; land
use and availability; and collection system and service area) that were established and defined for
the analysis. _The Draft EA Appendix B, Section 8, provides additional information regarding
the site selection process. As a result of this process, the County identified three sites (Sites 7, 8,
and 9) as reasonable alternatives for construction of the wastewater treatment and disposal
facility under the Proposed Action. The final scores for Sites 7, 8, and 9 were 4.33, 4.06, and
4.10 respectively, out of a total possible score of 5. Based on this analysis, Site 7 was selected as
the Preferred Alternative. The site is easily accessible, has good soils for a land application
system, and is close to the existing LCCs.
The Draft EA Section 2.5 describes Site 9 which is south (makai) of the Preferred Alternative
Site 7. As outlined in Appendix B Section 8, Site 9 earned a lower ranking than Site 7 for the
following criteria: presence of and or proximity to archaeological/cultural sites, existing vehicle
access, power and potable water availability, and distance from the area of the wastewater
collection system. Site 7 had a lower ranking than Site 9 in one category: topography. With the
distance between the two sites less than 300 feet, they were ranked equally for the criteria of
proximity of treatment units to existing occupied buildings.
The Draft EA Sections 2.5 and 2.7 provide information as to the issues related to the use of Site
9. An unnamed stream near the upper portion of the parcel could affect the selected
configuration of the wastewater treatment facility and the land application groves. Potentially, to
maximize energy efficiency by taking advantage of gravity flow, the headworks, lagoons and the
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii ~ 96826 • (808) 946-2277
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10349-01
Letter to Mr. Prodincio
Fuerte Page 2
March 6, 2020
subsurface constructed wetlands could be sited in the upper portion of the site, or the area closest
to the highway. In addition, since the site is located across Mamalahoa Highway from the Pahala
community, it would require construction of piping and other utilities within the highway ROW,
and approval by the State of Hawai'i Department of Transportation. Site 9 would require
additional access roads to facilitate both construction and operation of the treatment and disposal
facility and a slightly longer transmission line given its increased distance from the existing
LCCs.
This information will be included in the Final EA
The Draft EA Section 2.2 describes the purpose of the Pahala Large Capacity Cesspool
Replacement project is to close the Pahala LCCs. The Draft EA Section 2.3.2 discusses the
construction of a new sewer collection system in the Pahala community to replace the existing
system of substandard gravity lines that currently conveys sewage to the two LCCs. As described
in Section 6.2.1, the current collection system includes facilities located in the backyards of
many parcels. Where easements for the existing collection system aren't accessible, the County
must obtain permission from individual landowners to enter them, through private property, to
inspect, maintain, repair or replace existing sewer facilities: all activities essential to an efficient,
functioning system. The Draft EA Section 2.3.2 states the new collection system would be
subject to the County of Hawai'i Code (HCC) Chapter 21, Sewers, specifically. Article 2 (Public
Sewers), Section 21-5, which states the following
"(a)Owners of all dwellings, buildings, or properties used for human occupancy,
employment, recreation, or other purposes, which are accessible to a sewer are required
at their expense to connect directly with the public sewer within 180 days after date of
official notice.
Each adjacent lot will be provided with a lateral connection to the sewer main as required by
HCC and standards. Under the Preferred Alternative, the design of the new collection system
would extend between street intersections and include sewer service stub-outs (the lateral
connection to the sewer main) to the lot lines of adjacent properties, including the newly
accessible, to accommodate their eventual connection. Accordingly, to close the existing LCCs,
there will be additional properties in Pahala that would be required to connect to the new
wastewater collection system, at their expense, after it becomes operational. Such properties are
near the existing service area but are presently connected to individual wastewater systems. To
conform to the stated section of HCC, the respective, newly accessible property owners would be
responsible for the design, permitting and completion of sewer service connections between the
County stub-outs and improvements for stated uses on their property, as well as for the proper
closure of their individual wastewater systems. The Draft EA Figure 2.6 shows the area of the
community serviced by the current and proposed collection systems.
10349-01
Letter to Mr. Prodincio Fuerte
Page 3
March 6, 2020
All accessible properties will be required to connect to the new wastewater collection system in
accordance with Hawaii County Code, Chapter 21, Article 2, Section 21-5. However, the
County entered into an agreement with C. Brewer (in April 2007) to eliminate LCCs from the
existing community sewer systems and connect properties discharging to them to new County
collection, treatment and disposal systems. Once the actual costs are determined. County
Council action is still required to approve the expenditures.
This information will be included in the Final EA.
The County's intent, as stated in the June 22, 2017 US Environmental Protection Agency Region
9 Administrative Order on Consent, is to provide an industry-standard wastewater collection
system and a secondary treatment and disposal facility, a basic service to the Pahala community,
to eliminate underground injection from LCCs it operates to help protect underground drinking
water sources.
The Draft EA Section 2 provides the scope of the Proposed Action. The Draft EA Section 2.3.1
provides a detailed description of the proposed treatment and disposal system, descriptions of the
various facilities and their functions, a schematic drawing of the various processes, the proposed
site plan, and a description of the various areas which have the potential to be disturbed during
construction. Further, Section 2.3.2 describes the wastewater collection system, including the
streets where the system would be routed and the two phases for construction. Lastly, Section
2.3.3 describes closure of the two large capacity cesspools, as required by the US Environmental
Protection Agency, and abandonment of the existing collection system. Figure 2.6 shows the
extent of the proposed collection system and preferred wastewater treatment and disposal facility
location within the community.
Although not a comment specific to the content of the Draft EA, information regarding project
schedules, including US Environmental Protection Agency (USEPA) compliance dates, project
updates and milestones can be found on the USEPA website: https ://www,epa, gov/uic/county-
hawaii-admmistrative-order-consent-closure-cesspools-pahala-and-naalehu
Closure of individual cesspools is mandated by legislation at the State level. In 2017, Act 125
was enacted by the Hawai'i State legislature requiring all cesspools, not exempted by the
Department of Health, be upgraded or converted to septic systems, or aerobic treatment unit
systems, or connected to sewage systems by January 1, 2050. Though closure of individual
wastewater systems by the County is not part of the Proposed Action, this legislation will affect
all parcels in Pahala currently utilizing cesspools for sewage disposal.
The Draft EA Section 6.2.2 discusses the Ka'u Community Development Plan (CDP): "Section
5 of the CDP prioritizes improvements in infrastructure, facilities, and services, including
Section 5.8 applicable to ... Environmental management facilities, including expanded sewer
lines, ..." Policy 120 is to "Extend the primary wastewater collection lines in Pahala and
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10349-01
Letter to Mr. Prodincio Fuerte
Page 4
March 6, 2020
Na'alehu so that infill development projects can connect wastewater systems built for new
subdivisions to the County systems."
The collection system will be consistent with Policy 120 as the improvements for the Pahala
(LCC) Replacement project have been designed not to preclude accommodating the Pahala
community. Similarly, the treatment and disposal facility has been designed not to preclude
accommodating wastewater flows from the collection system from the Pahala community.
Further, the Draft EA, Appendix B, Section 5.6 provides information related improvements
needed to wastewater services to the Pahala community as envisioned in the CDP. Appendix B,
Section 5.6.2 states:
To accommodate the flow increase anticipated from the full buildout of the Pahala
wastewater collection system, the WWTP will require facility upgrades. The
recommended upgrades include headworks and odor control expansion within thel4.9-
acre site. Additionally, the lagoon system will require modifications. Lagoon 1 will be
converted to a complete mix aerated lagoon environment to accommodate wastewater
treatment needs. In a complete mix aerated lagoon, sufficient mixing energy is provided
to maintain the lagoon solids in suspension always. A completely mixed aerated lagoon
system performs as an activated sludge process without solid recycle. The higher mixing
energy, as compared to a partial mix lagoon, creates greater opportunity for contact
between the naturally-occurring micro-organisms in the lagoon and dissolved organic
matter. As a result, complete mix lagoons provide greater levels of treatment within a
smaller volume than partial mix lagoons. However, facilities must be provided
downstream of complete mixed lagoons to allow removal of settleable solids from the
water column. To provide a place for solid settling, lagoons 2 through 4 will continue to
act as partial mix aerated lagoons downstream of the complete mix lagoon 1. Lagoon 4
will require no aeration and will continue to be covered to deprive algae of sunlight and
allow suspended solids to settle out of the system effluent. Utilizing this lagoon system
approach, the Pahala WWTP will require modification at full buildout flow, but is not
anticipated to expand beyond the initial build 14.9-acre site."
This information will be repeated in the Final EA.
The Draft EA Section 2.3 states that under the Preferred Alternative, the County of Hawai'i
would acquire, or otherwise obtain the right to develop and use, a portion of the 42.5-acre Site 7
then construct a new secondary wastewater treatment and disposal facility within a portion of the
parcel (see Figure 2.3). Further, as stated in Section 2.3.1:
'The County would work with the current landowner to subdivide the 42.5-acre parcel
into two parcels: 1) a 14.9-acre parcel that would be owned by the County; and 2) a 27.6-
acre parcel that would include a 25-foot-wide by 1,500-foot-long utility easement and
10349-01
Letter to Mr. Prodincio Fuerte
Page 5
March 6, 2020
would continue to be owned by the current owner. See Figure 2.3 for a preliminary site
plan showing the proposed location of the treatment and disposal facility within the
southeast portion of Site 7."
The Final EA will note, the County is working with the current landowner, BP Bishop Estate
Trustees (Kamehameha Schools), to subdivide the 42.5-acre parcel (Tax Map Key (TMK): 9-6-
002:018) to acquire the property.
The Draft EA Section 2.10.2 states:
''Construction of the portions of the collection system located within County ROWs
would not require further land transfer approvals. As previously discussed, two short
segments of the planned collection system would be located with privately owned
parcels. The County would obtain easements from the land owner(s) as part of the
construction process. The Hawai'i County Code Chapter 23, Subdivisions, states that all
subdivision plats and all streets or ways within the County created for the purpose of
partitioning land shall be approved by the County Planning Department Director."
Future sewer main extensions and subdivisions will be accommodated, as capacity allows, on a
first come, first served basis.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
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10349-01 ref (59)
March 6, 2020
Mr. Larry Navarro
Idnaval@gmail.com
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - November 19, 2018 11:27 a.m.
Dear Mr. Navarro:
Thank you for your November 19, 2018 11:27 a.m. comment message regarding the County of
Hawai'i Department of Environmental Management (DEM) Draft Environmental Assessment
(EA) for the Pahala Large Capacity Cesspool Replacement project. Our response follows:
The Draft EA Section 2.3.2 states the new collection system would be subject to the County of
Hawai'i Code (HCC) Chapter 21, Sewers, specifically, Article 2 (Public Sewers), Section 21-5,
which states the following:
"(a) Owners of all dwellings, buildings, or properties used for human occupancy, employment,
recreation, or other purposes, which are accessible to a sewer are required at their expense to
connect directly with the public sewer within 180 days after date of official notice. "
Further:
"(c) The director may grant a variance/exemption of the foregoing connection requirements to
owners of single-family dwellings existing at the time of installation of the public wastewater
system, if the following is found:
(1) There are special or unusual circumstances applying to the subject real property
-which exist that render the ability to connect to a wastewater system an extreme physical
or financial hardship; and
(2) There are no other reasonable alternatives; and
(3) The variance is consistent with the general purpose of the chapter and will not be
materially detrimental to public health, safety, or welfare. "
The financial impact of the project on individual newly accessible property owners was raised by
the community during the December 2017 public meetings as summarized in Section 7 of the
Draft EA. Although not required by Hawaii Administrative Rules (HAR) Title 11, Chapter 200,
DEM voluntarily convened two additional public meetings on October 9, 2018 and March 21,
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii • 96826 • (808) 946-2277
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10349-01
Letter to Mr. Larry Navarro
Page 2
March 6, 2020
2019 to gain further input from newly accessible property owners and present funding options
for them to pursue.
The Draft EA Section 7 will be revised to add that the County held additional meetings in Paha la
including one to provide information on financing sources available to owners of parcels which
would become accessible to the County collection system. The purpose of the March 21, 2019
meeting was to fulfill a County commitment made in October, 2018 to research financing
options available to the newly accessible residents of the Pahala Community. At the meeting,
DEM provided the preliminary results of the County investigation into funding sources and
options available for newly accessible property owners once the new treatment and disposal
facility and the wastewater collection system have been designed, permitted and constructed.
Programs discussed included:
• US Department of Housing and Urban Development (HUD) with County of Hawaii
Office of Housing and Community Development Residential Repair Program -
Community Block Grant Program, and
• US Department of Agriculture - Rural Development (USDA-RDA) Program.
As noted during the presentation, these programs may change in the coming years, and additional
options may be added to this preliminary list. Hawaii Legislature, Senate Bill 221 SD1, which
could amend Hawaii Revised Statutes (HRS) Chapter §342D to establish a low interest loan
program to offer financial assistance to cesspool owners to connect to wastewater treatment
systems approved by the Department of Health was also discussed; however, this bill was
subsequently not passed during the 2019 legislative session.
This information will be included in the Final EA.
Some ways to stay informed about the project include:
• The County will submit the Final EA to the State of Hawaii Department of Health Office
of Environmental Quality Control (OEQC), which facilitates Hawaii's environmental
review process and announces the availability of EAs for public review and comment in
The Environmental Notice (TEN). Issues of TEN can be found on the OEQC website
at: http://heatth,hawaii.gov/oeqc/.
• The Draft EA and other project information can be found on the County of Hawaii
website at: http://www.hawaiicoutity.gov/dem-wastewaterHlivision.
• Information regarding project schedules, including US Environmental Protection Agency
(USEPA) compliance dates, project updates and milestones can be found on the USEPA
website at: https://www.epa.gov/uic/coutity-hawatwidmmtstrative-order--consent-closure-
cesspools-pahaia-and-naalehu.
10349-01
Letter to Mr. Larry Navarro
Page 3
March 6, 2020
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
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10349-01 ref (60)
March 6, 2020
Ms. Lisa Gollin. PhD
Ixgollin@hawaii.edu
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - November 19, 2018; 11:46 a.m.
Dear Dr. Gollin:
Thank you for your November 19, 2018 11:46 a.m. comment message regarding the County of
Hawai'i Department of Environmental Management (DEM) Draft Environmental Assessment
(EA) for the Pahala Large Capacity Cesspool Replacement project. Our response follows:
The Draft EA Preface states: The DEM has determined that the requirements of Hawaii Revised
Statutes, Chapter 343, can be fulfilled by preparing an EA with FONSI. A Final Environmental
Assessment (EA) will be issued for this project. As such, a cultural impact assessment will not
be included.
The Draft EA Summary states: No significant environmental impacts are anticipated from
construction and use of the collection system and the wastewater treatment and disposal facility.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
-------
John Sakaguehi 14* I"? "*'
—————— i————** mi—
cX-" uc a)rt
From: Fujio, Mary
Sent Monday, December 3,2018 8:19 AM
To: Kucharski, William; Beck Dora; eplan1@aoI.com; Michelle Sorensen
Subject: FW: Pahala Sewer Project comments (from Tanya Ibarra)
Attachments: County of Pahala Sewer Project.pdf
Received at COHDEM.
From; Tanya Ibarra [mailto:tibarra2000@gmail.com]
Sent: Saturday, December 01, 2018 9:35 PM
To: cohdem
Subject: Pahala Sewer Project comments
Please review the attached comments regarding the Pahala Sewer Project.
I
Dear Mayor Harry Kim,
I am writing regarding the Pahala Community Large Capacity Cesspool Replacement Project.
T have read the Draft Environmental Assessment for the Pahala Large Capacity Cesspool Replacement Project
and have some concerns regarding the proposal and it's details.
COMMUNITY INPUT ON THE PROJECT: According to the Draft, Section 2.1.4 History ofWastewa
ter Management in Pahala the document shows that the County held a community meeting to present
sewer system replacement alternatives as well as a voting system in which the Pahala community chose
the preferred sewer alternative resulting in 87% of the returned ballots in favor of a new sewer collection
system and a treatment and disposal system to be operated and maintained by the County,
MY CONCERN: !he entire Pahala community was NOT included in the determination of whether or
not a sewer system for the entire community was wanted.
According to the Communication document (COM 0293.004 2004-2006), the ballots were only sent to
homeowners who were connected to the Large Capacity Cesspool (LCC) provided by C. Brewer. In the
communication, it includes a question and answer section, in which one of the questions (shown below)
specifically shows that if a homeowner needs to connect, C. Brewer has provided money to the County
to remain in escrow to pay for the connection of these homes to the sewer lines.
Question #S - Alternative 1:
If Alternative 1 is selected, will the residents be required to connect to the new
system?
Answer #5:
Yes, once a county system is installed in front or near your home, you will need
to connect. Please be aware however, that the cost for the service laterals that
connect to the County sewer lines will be funded by C. Brewer and Company,
Limited. The homeowner will not need to pay for this cost.
The current proposal is expanding the system to include homeowners who are not in violation to the
Federal law against the use of Large Capacity Cesspools (LCC). This seems like a waste of time and re-
sources which could be directed to more important needs in our community.
It is obvious that the original proposal in 2004 was intended only for those homeowners who were on
the LCC system. Since the inception of this project, the costs have skyrocketed to far beyond the $1.6
million which was outlined originally in the ballot system (COM 0293.004 2004-2006). The County
should simply work with the original proposal to give those homeowners on the LCC the sewer system
they requested. To include the entire community of Pahala is an unnecessary burden to the County and
to the homeowners who are required to hook into the line at the cost of $20,000 each.
-------
REASON FOR THE PROJECT: According to the proposal, the Federal government issued a mandate
that all Large Capacity Cesspools (LCC) be shut down by April 5, 2005. The county is concerned with
fines by the Federal government because of the LCC in Pahala and other districts around the island.
MY CONCERN: If this is truly a means for Hawaii County to avoid fines from the federal government
for the LCC violations, then that is what the focus of this proposal should be about. Expanding the proj-
ect is not necessary and would cost more and take more time for the county to avoid these fines. This
again is costing more for the county and for hardworking community members of Pahala who do not
have the means to pay the outrageous costs of connecting to this unnecessary line simply because it runs
in front of their homes.
WATER LINE/SEWER LINE PLACEMENT: I am concerned with the placement of the sewer lines near
the water lines of Pahala.
MY CONCERN: Is there some kind of spec sheet that shows how far away the sewer line will be to the
water line?
ERRORS IN THE PROPOSAL: One section of the Draft Environmental Assessment {Pahala LCC
Replacement Project) September 2018 (Section 2-1 Pahala Community) states that Pahala is the largest
and most populated town in Ka'u, however, that is not correct. In fact, it is a well-known fact that Ocean
View is three times more populated and is in fact the largest subdivision in the United States.
Draft EA, Pahala LCC Replacement Project
Pahala, Ka'u District, Hawai i
2 PROPOSED PROJECT DESCRIPTION
2.1 Background
2.1.1 Pahala Community
The community of Pahala is located about 52 miles southwest of Hilo, in the Ka'u District, Island
of Hawaii Pahala is located west (mauka) of Mamalahoa Highway (Slate Route 11) about 3.8
miles from the shoreline. Most of the community lies between 980 feet above mean sea level
(msl) on the western end and approximately 800 feet above msl on the eastern end. Figure 2.1
shows the location of Pahala.
Even though Ka'u was one of the originally settled areas in the Hawaiian Islands, it remains a
vast remote area. Only a fraction of a percent has been developed with residential properties, and
the remainder is largely used for agricultural purposes or is undeveloped. The District of Ka'u is
situated at the southern tip of the island and extends across the southern and southeastern flanks
of Mauna Loa. The Ka'u District covers about 922 square miles (approximately 590,000 acres),
with over 80 miles of virtually undeveloped coastline. Nearly two-thirds of its total land area is in
the Conservation district. The Ka'u district includes several communities of which the Pahala
community is the largest, with a population of approximately 1,405 persons in 2016, the most
recent estimate. The distance to the communities of Hilo and Kailua-Kona means that the Ka'u
District is relatively isolated from the major infrastructure systems found in these communities,
including wastewater treatment and disposal facilities.
MY CONCERN: If the proposal was made with the idea that Pahala is the largest populated town in
Ka'u, it is erroneous. The population of residents who are actually hooked up to the LCC in Pahala is in
fact only a fraction of the entire community of Pahala.
PLACEMENT OF THE FIRST PHASE OF THE SEWER PROJECT:
Draft EA Pahala LCC Replacement Project
Pahala Ka u District, Hawai'i
LEGEND
I IC BrewB Sy tern Lots to La^ja Capacity Cesspool (LCC)
I I Newly Accessible Lots toWWTP
I Proposed Pahala WWTP Site
- Pahala Fuhjro County Sewer System
Mi Existing Large Capacity Cesspool (LCC)
Existing Large Capacity
Cesspool ilCC 2.1
Existing Large Capacity
Cesspool {LCC tj
MY CONCERN: According to documents showing where the new line will be placed, there are some
homes which will have the sewer line running near their homes, but are not part of the original C.
Brewer LCC line, The homes across the street and connecting are not part of the LCC line either, so it is
perplexing as to why this initial phase of the project is including lines in areas that are not necessary.
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WILSON OKAMOTO
COUP T t § II
10349-01
March 6, 2020
ref (61)
Ms. Tanya Ibarara
tibarftra2000@gmail.com
Subject: Draft Environmental Assessment for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment - December 3, 2018; 8:19: a.m.
Dear Ms. Ibarra:
Thank you for your December 3, 2018 8:19 a.m. comment message regarding the County of
Havvai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our responses follow:
COMMUNITY INPUT ON THE PROJECT
On April 25, 2010, a community meeting sponsored by Councilman Guy Enriques was held at
the Pahala Community Center to discuss the Na'alehu and Pahala Large Capacity Cesspool
Replacement project. As part of the meeting, an informational handout prepared by the County's
Wastewater Division provided a brief history of the project documenting that, in 2004, Mayor
Kim's office used a ballot system to get input from property owners regarding different
wastewater treatment disposal alternatives for those property owners connected to the LCCs who
would no longer be served by the C. Brewer system after LCC closure. As reported in the Draft
EA Section 2.1.4, 87 percent of the returned ballots were in favor of the installation of a new
sewer collection system and a treatment and disposal system to be operated and maintained by
the County. The handout indicated that Mayor Kim's office advised the property owners the
County would move forward with new systems for Na'alehu and Pahala on November 5, 2004.
Additionally, the handout stated public meetings were held in both Na'alehu and Pahala in
November 2006 to discuss the wastewater system alternatives. The handout included that
adequate land for the treatment and disposal system had not been identified in Pahala. The
handout also stated that all properties accessible to the new sewer system would be required to
connect in accordance with Hawaii County Code Chapter 21.
The Draft EA Section 2.9 discusses the relationship between the current project and the 2007
Final EA for the Naalehu-Pahala Large Capacity Cesspool (LCC) Conversion project. As stated
in Section 2.9:
"After the issuance of the Final EA and Negative Declaration/FONSI in 2007, the County
conducted additional study and evaluation of the proposed LCC conversion project. The
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
10349-01
Letter to Ms. Tanya Ibarara
Page 2
March 6, 2020
County eventually concluded that the LCC conversion project described in the 2007 Final
EA would not meet the need to provide a collection system and a treatment and disposal
facility, close the LCCs, and provide for the future needs of the Pahala community. This
determination was based on several factors..."
REASON FOR THE PROJECT
The Draft EA Section 2.2 describes the purpose of the Pahala Large Capacity Cesspool
Replacement project is to close the Pahala LCCs. The Draft EA Section 2.3.2 discusses the
construction of a new sewer collection system in the Pahala community to replace the existing
system of substandard gravity lines that currently conveys sewage to the two LCCs. As described
in Section 6.2.1, the current collection system includes facilities located in the backyards of
many parcels. Where easements for the existing collection system aren't accessible, the County
must obtain permission from individual landowners to enter them, through private property, to
inspect, maintain, repair or replace existing sewer facilities: all activities essential to an efficient,
functioning system. The Draft EA Section 2.3.2 states the new collection system would be
subject to Hawai'i County Code (HCC) Chapter 21, Sewers. Specifically, Article 2 (Public
Sewers), Section 21-5, states the following:
"(a) Owners of all dwellings, buildings, or properties used for human occupancy,
employment, recreation, or other purposes, which are accessible to a sewer are required
at their expense to connect directly with the public sewer within 180 days after date of
official notice."
Each adjacent lot will be provided with a lateral connection to the sewer main as required by
HCC and standards. Under the Preferred Alternative, the design of the new collection system
would extend between street intersections and include sewer service stub-outs (the lateral
connection to the sewer main) to the lot lines of adjacent properties, including the newly
accessible, to accommodate their eventual connection. Accordingly, to close the existing LCCs,
there will be additional properties in Pahala that would be required to connect to the new
wastewater collection system, at their expense, after it becomes operational. Such properties are
near the existing service area but are presently connected to individual wastewater systems. To
conform to the stated section of HCC, the respective, newly accessible property owners would be
responsible for the design, permitting and completion of sewer service connections between the
County stub-outs and improvements for stated uses on their property, as well as for the proper
closure of their individual wastewater systems. The Draft EA Figure 2.6 shows the area of the
community serviced by the current and proposed collection systems.
The financial impact of the project on individual newly accessible property owners was raised by
the community during the December 2017 public meetings as summarized in Section 7 of the
Draft EA. Although not required by Hawaii Administrative Rules (HAR) Title 11, Chapter 200,
DEM voluntarily convened two additional public meetings on October 9, 2018 and March 21,
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10349-01
Letter to Ms. Tanya Ibarara
Page 3
March 6, 2020
2019 to gain further input from newly accessible property owners and present funding options
for them to pursue.
The Draft EA Figure 2.2 shows the collection system on the various streets within the
community. The Draft EA Section 2.2 states the Paha la Large Capacity Cesspool Replacement
project is to provide infrastructure necessary to enable the County to comply with the Safe
Drinking Water Act and Administrative Order on Consent between the County and the
Environmental Protection Agency with respect to closure of the Pahala large capacity cesspools.
The extent of the collection system is to ensure the parcels connected to the former C. Brewer
system will have access to the treatment and disposal facility, so the large capacity cesspools can
be closed.
The Draft EA Section 6.2.2 discusses the Ka'u Community Development Plan (CDP): "Section
5 of the CDP prioritizes improvements in infrastructure, facilities, and services, including
Section 5.8 which is applicable to ... Environmental management facilities, including expanded
sewer lines, ...Policy 120 is to "Extend the primary wastewater collection lines in Pahala and
Na'alehu so that infill development projects can connect wastewater systems built for new
subdivisions to the County systems."
The collection system will be consistent with Policy 120 as the improvements for the Pahala
LCC Replacement project have been designed not to preclude accommodating the Pahala
community. Similarly, the treatment and disposal facility has been designed not to preclude
accommodating the wastewater flows from the collection system from the Pahala community.
It is conventional to extend a utility between street intersections to minimize the number of
manholes required. As stated in the Draft EA, the collection system is routed within the County
right-of-way for ease of access for construction and maintenance.
WATER LINE/SEWER LINE PLACEMENT
On April 5, 2018, the County of Hawai'i Department of Water Supply (DWS) provided the
following (See the Draft EA Appendix A):
'The Department requests that the construction plans show, and the proposed sewer lines
be installed with, the proper horizontal and vertical clearances from our existing water
system facilities and concrete jacketing at waterline crossings, where necessary, as
recommended by the Department's Water System Standards.
In addition, backflow prevention devices must be installed where there are connections to
our water system at wastewater processing and treatment facilities".
10349-01
Letter to Ms. Tanya Ibarara
Page 4
March 6, 2020
The detailed design will be informed by and the construction documents will reference the DWS
Water System Standards.
The above information will be included in Section 2.3.2 of the final EA.
ERRORS IN THE PROPOSAL
Neither the geographical size nor population of Pahala affect the Purpose and Need for Action as
outlined in the Draft EA Section 2.2 The purpose is to close the County-operated LCCs Section
2.1.1 will be revised to state: 'The Ka'u district includes several communities, including the
town of Pahala. Pahala had a population of approximately 1,341 persons in 2016."
PLACEMENT OF THE FIRST PHASE OF THE SEWER PROJECT
Please refer to the above response under heading REASON FOR THE PROJECT.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
December 4,2018
Tiis County of Hawaii
Environmental Protection Agency
From: Dorothy Kalia
!'¦ 0. Box t,?.h
Paliaii, Hawaii 96777
R»>; Wastewater Treatment Site
Mf name Is Dorothy lilwi and I Live on MaUe Street: in
Pa ha la, l would like iu w.ikv known my #ff #*lli«®n to the
chosen site on the corner of Mailt Street ami Mamalahoa
Wiiway. With all the available land in PahJlu 1 fed the
area below Mamalahoa Mfhway would be a better option,
Thetrr is a coiirern of flooding which could cause rood
closure to Mamalahoa Highway. i ntenml our facility
K similar Ui Kraukalia's and havr .HpukuntO residents in
that area ahout the smell, Our Mupmia In Pdltala susprct
pos&ibic ^itc nwr ur un
Again, I express my concern and opposition to I ho chosrn
site.
Mahalol
'V
Dorothy f&lua
% b\-m )
f¦'
¦"s
• V, \ i
VA-
¦ I i
LSOM OKAMOTO
BPORATIQK
:> „• * t o 3 ;s . * i « t *, <. , H ! I *
10349-01 ref (68)
March 6, 2020
Ms Dorothy Kalua
P.O. Box 626
Pahala Hawai'i 96777
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - December 4, 2018
Dear Ms. Kalua:
Thank you for your December 4, 2018 comment letter regarding the regarding the County of
Hawai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool (LCC) Replacement project. Our responses follow
The Draft EA Section 2.7 describes the site selection process, including the factors and their
relative weights used to evaluate the various sites. Further, Section 2.7 describes the twenty-one
criteria within four general categories (environmental, social and cultural; location and site; land
use and availability; and collection system and service area) that were established and defined for
the analysis. The Draft EA Appendix B, Section 8, provides additional information regarding
the site selection process. As a result of this process, the County identified three sites (Sites 7, 8,
and 9) as reasonable alternatives for construction of the wastewater treatment and disposal
facility under the Proposed Action. The final scores for Sites 7, 8, and 9 were 4.33, 4.06, and
4.10 respectively, out of a total possible score of 5. Based on this analysis, Site 7 was selected as
the Preferred Alternative. The site is easily accessible, has good soils for a land application
system, and is close to the existing LCCs. r
The Draft EA Section 2.5 describes Site 9, which is south (makai) of the Preferred Alternative
Site 7. As outlined in Appendix B Section 8, Site 9 earned a lower ranking than Site 7 for the
following criteria: presence of and or proximity to archaeological/cultural sites, existing vehicle
access, power and potable water availability, and distance from the area of the wastewater
collection system. Site 7 had a lower ranking than Site 9 in one category: topography. With the
distance between the two sites less than 300 feet, they were ranked equally for the criteria of
proximity of treatment units to existing occupied buildings.
The Draft EA Sections 2.5 and 2.7 provide information as to the issues related to the use of Site
9. An unnamed stream near the upper portion of the parcel could affect the selected
configuration of the wastewater treatment facility and the land application groves. Potentially, to
maximize energy efficiency by taking advantage of gravity flow, the headworks, lagoons and the
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii ~ 96826 • (808) 946-2277
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10349-01
Letter to Ms Dorothy Kalua
Page 2
March 6, 2020
subsurface constructed wetlands could be sited in the upper portion of the site, or the area closest
to the highway. In addition, since the site is located across Mamalahoa Highway from the Pahala
community, it would require construction of piping and other utilities within the highway ROW
and approval by the State of Hawai'i Department of Transportation. Site 9 would require
additional access roads to facilitate both construction and operation of the treatment and disposal
facility and a slightly longer transmission line given its increased distance from the existing
LCCs.
This information will be included in the Final EA.
The County is aware of two existing culverts that allow stormwater to flow across the
Mamalahoa Highway in the vicinity of the project.
The Draft EA Section 3.9.1 (a) states:
"The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM),
Community Panel No. 155166 1800F, effective date September 29, 2017 shows that most of
the Pahala area is located in Zone A', which designates areas determined to be outside the 0.2-
percent annual chance (500-vear) floodplain. A small portion of the community of Pahala,
including some land within the collection system project site, is located within Zone X—
Other Flood Areas, indicating areas within the 0.2-percent annual chance (500-year)
floodplain, or areas with a 1-percent annual chance of flooding with average flood depths
less than 1 foot.
On April 16, 2018, in response to the pre-assessment notification, the State of Hawai'i
Department of Land and Natural Resources Engineering Division stated the responsibility for
conducting research as to the flood hazard designation for the project site lies with the project
proponent. Also on April 16, 2018 and in response to the pre-assessment notification, the
County of Hawai'i Department of Public Works confirmed that the proposed treatment and
disposal Site 7 is designated as ZoneXon the FIRM and is outside the 500-year floodplain."
The relevant FIRM panel is reproduced in Appendix B as Figure 4-13.
This information will be repeated in the Final EA.
The Draft EA Section 3.23.2 (a) states:
"The proposed wastewater treatment and disposal facility would include an on-site drainage
system to address stormwater surface runoff created by new impervious surfaces within the
facility. The site would include a system to collect runoff via grated inlets or swales, and
flows would be conveyed to on-site drainage detention systems, such as subsurface linear
infiltration or depressed detention basins."
10349-01
Letter to Ms Dorothy Kalua
Page 3
March 6, 2020
This information will be repeated in the Final EA.
The preferred alternative (Site 7) slopes from approximately north to south (mauka to makai)
such that, during rain events, surface flows drain through the existing orchard to the southern
(makai) end where the flows eventually drain through the culvert located at the Maile Street-
Mamalahoa Highway intersection to the areas below (makai) the highway. Most of the land
surface area below the existing macadamia nut orchard contains little to no vegetation to absorb
or slow these flows. The gradient of Site 7 and surrounding area results in this natural pattern of
surface flows which also existed when the area was planted in sugar cane and is not considered
flooding.
Based on the roadway flooding concerns expressed by the community during the Pahala public
meetings held in December 2017 and October 2018, the State of Hawai'i Department of
Transportation (DOT) Hawai'i District office was contacted to discuss drainage at the treatment
and disposal facility project site and the culvert at the Maile Street and Mamalahoa Highway
intersection. On February 20, 2019, the District office confirmed via telephone that the DOT
owns and maintains the culvert at the Maile Street intersection, and that they have no record of
the roadway being inundated by stormwater drainage during precipitation events at that location.
Stormwater runoff generated mauka of the treatment and disposal facility project site will be
directed around the perimeter of the site via diversion swales that will convey flow back to the
existing drainage pattern that flows to the existing culvert at Maile Street. During heavy rain
events, stormwater may temporarily back up behind the culvert. There will be no changes to this
culvert and the proposed treatment and disposal facilities will not be located within the area of
the culvert.
As stated in the Draft EA, the on-site stormwater management system would meet the
requirements of Hawai'i County Code (HCC), Chapter 27 Floodplain Management, Section 20,
Standards for subdivisions and other developments (e) which mandates a site drainage plan to
"comply with sections 27-20(a) and (b) and section 27-24, and shall include a storm water
disposal system to contain run-off caused by the proposed development, within the site
boundaries, up to the expected [design] storm event as shown in the Department of Public Works
"Storm Drainage Standards".
To meet the requirements of HCC, Chapter 27, Section 20 (f), the project site "shall not alter the
general drainage pattern above or below the development". Thus, for the HCC design storm
event, no increase in flow amount will be directed to either of the culverts at the highway as a
result of the site development. A drainage report will be prepared during the design process to
evaluate the improvements necessary to comply with HCC Chapter 27 requirements.
The wastewater treatment processes will be designed to accommodate the associated peak flows,
including precipitation that falls on the area occupied by the aerated lagoon treatment system.
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10349-01
Letter to Ms Dorothy Kalua
Page 4
March 6, 2020
The Draft EA Appendix B, Section 2.2 outlines the anticipated peak wastewater flows from the
community, based on the applicable flow standard. The Draft EA Section 2.3.1 states the aerated
lagoons will be equipped with high-density polyethylene liners to prevent water seepage through
the bottom and sides of the lagoons. The Draft EA Appendix B, Section 5.3 shows the
operational freeboard that will be available to contain and to equalize lagoon flows. In addition,
the slow-rate land application groves will be designed to completely contain both peak effluent
flows and precipitation from a 100-vear, 24-hour storm event. A geotechnical engineering
assessment of berm stability will be conducted during the design process. The tree groves will
be designed in accordance with the EPA's "Process Design Manual, Land Treatment of
Municipal Wastewater Effluents". Effluent will be applied at a hydraulic loading rate that is a
small percentage of the percolation rate of the soil, ensuring sufficient capacity for assimilation
of peak effluent flow rates and precipitation from the design storm event.
This information will be included in the Final EA.
The former Hilo Wastewater Treatment Plant (WWTP) at Keaukaha is not currently in use as a
County WWTP, nor was it similar to the wastewater treatment and disposal facilities proposed
for this project. Facilities at TMK 2-1-011:004 are currently owned by the State of Hawai'i,
University of Hawai'i, as the Pacific Aquaculture Coastal Resource Center.
The Draft EA Section 3.14.2 states:
"Wastewater treatment plants can be a source of nuisance odors to the surrounding
community if not properly designed or operated. Typically, nuisance odors are most
commonly associated with anaerobic (without oxygen) conditions and with processing of
residual solids. Incoming raw sewage flows to the proposed wastewater treatment and
disposal facility would first be routed to the headworks, which is the facility where the
solids are removed from the flows.
To mitigate potential nuisance odors, the headworks would be equipped with an odor
control system with a GAC scrubber to remove odor. A package GAC scrubber passes
the odorous air through a bed of activated carbon, which adsorbs the odorous constituents
within the pore spaces of the carbon. The County currently operates GAC scrubbers at
other facilities, and it has been proven to be an effective means of odor control both
locally and nationwide. The treatment lagoons would be equipped with mechanical
aerators capable of maintaining sufficiently aerobic (with oxygen) conditions within the
water column, which would prevent nuisance odor conditions from occurring. The
disposal groves would be irrigated with fully-treated and aerobic secondary effluent from
the treatment process; irrigation with secondary effluent is not associated with
development of nuisance odor conditions."
This information will be repeated in the Final EA Section 3.14.2.
10349-01
Letter to Ms Dorothy Kalua
Page 5
March 6, 2020
The Draft EA Section 3.15 references a November 2016 archaeological field inspection report
that states, while the historical ground modifications have likely limited the archaeological
potential of the site, the discovery of both pre- and post-contact surface artifacts within the 42.5-
acre parcel (which includes Site 7), as well as evidence from plantation-era documents that the
opening of a lava tube containing human remains once existed in the southeastern corner of the
parcel, indicate that further archaeological studies may be necessary. The Final EA will clarify
that the report also stated it would be advisable to limit the development footprint to exclude the
southeastern corner of the 42.5-acre parcel. This area, which is presently not used as a
macadamia nut orchard, but forms part of the macadamia nut processing plant complex, is the
location of a known (but sealed) lava tube opening that local informants have indicated is linked
to tubes that possess traditional human burials. Further, by excluding this section of the parcel, it
will be possible to avoid at least one known historic property. The Draft EA Figure 2.3 provides
the Preliminary Site Plan for the new treatment and disposal facility, which shows the 14.9-acre
project site has been developed to exclude the area in the southeastern corner identified as the
location of the sealed lava tube opening.
The complete document is available for download from the County's website
at: http://records,co.hawan.hi.us/weblink/l/edoc/100962/Dfaft%20ArcheQlogieal%20Inventory~
%20Siirvev%20-%20Pahaia%20WWlP%20and%20Sewer%20Svstem.pcif
Between September 18, 2018 and January 10, 2019, a team of qualified archaeologists conducted
a pedestrian survey of the proposed project site and completed subsurface trenching to determine
the presence of archaeological resources. The work was undertaken in accordance with the State
of Hawaii Department of Land and Natural Resources State Historic Preservation Division
(SHPD) requirements, with the archaeological inventory survey (AIS) approach accepted by
SHPD in their August 20, 2018 letter. The results of the survey and subsurface trenching
showed no burials or lava tube openings were present. The AIS completed in March 2019
documents that a sealed lava tube is located east of the proposed wastewater treatment and
disposal facility project site, outside the proposed property boundary, and outside of the area of
potential effect considered in consultation with the SHPD.
A geophysical survey of the proposed project area will be performed during detailed design with
the specific intent to locate subsurface voids (such as lava tubes) present beneath the site that
may impact design and construction of the new wastewater treatment, disposal and collection
systems.
This information will be included in the final EA.
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10349-01
Letter to Ms Dorothy Kalua
Page 6
March 6, 2020
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
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10349-01 ref (67; 69;70)
March 6, 2020
Ms. Terri L. Napeahi, Secretary
Pele Defense Fund
P.O. Box 4969
Hilo, Hawai'i 96720
Subject: Draft Environmental Assessment for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment- December 10, 2018
Dear Ms. Napeahi:
Thank you for your hand delivered December 10, 2018 comment letter regarding the County of
Hawai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. This responds to duplicate letters to
Mayor Kim and the Department of Environmental Management.
Our responses follow:
The Draft EA Section 2.7 describes the site selection process, including the factors and their
relative weights used to evaluate the various sites. Further, Section 2.7 describes the twenty-one
criteria within four general categories (environmental, social and cultural; location and site; land
use and availability; and collection system and service area) that were established and defined for
the analysis. The Draft EA Appendix B, Section 8, provides additional information regarding the
site selection process. As a result of this process, the County identified three sites (Sites 7, 8, and
9) as reasonable alternatives for construction of the wastewater treatment and disposal facility
under the Proposed Action. The final scores for Sites 7, 8, and 9 were 4.33, 4.06, and 4.10
respectively, out of a total possible score of 5. Based on this analysis, Site 7 was selected as the
Preferred Alternative. The site is easily accessible, has good soils for a land application system,
and is close to the existing LCCs.
The Draft EA Section 2.5 describes Site 9, which is south (makai) of the Preferred Alternative
Site 7. As outlined in Appendix B Section 8, Site 9 earned a lower ranking than Site 7 for the
following criteria: presence of and or proximity to archaeological cultural sites, existing vehicle
access, power and potable water availability, and distance from the area of the wastewater
collection system. Site 7 had a lower ranking than Site 9 in one category: topography. With the
distance between the two sites less than 300 feet, they were ranked equally for the criteria of
proximity of treatment units to existing occupied buildings.
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii • 96826 • (808) 946-2277
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10349-01
Letter to Ms. Terri L. Napeahi
Page 2
March 6, 2020
The Draft EA Sections 2.5 and 2.7 provide information as to the issues related to the use of Site 9.
An unnamed stream near the upper portion of the parcel could affect the selected configuration of
the wastewater treatment facility and the land application groves. Potentially, to maximize energy
efficiency by taking advantage of gravity flow, the headworks, lagoons and the subsurface
constructed wetlands could be sited in the upper portion of the site, or the area closest to the
highway. In addition, since the site is located across Mamalahoa Highway from the Pahala
community, it would require construction of piping and other utilities within the highway ROW
and approval by the State of Hawai'i Department of Transportation. Site 9 would require
additional access roads to facilitate both construction and operation of the treatment and disposal
facility and a slightly longer transmission line given its increased distance from the existing
LCCs.
This information will be included in the Final EA.
Flooding
1. The Draft EA Section 3.9.1 (a) states:
"The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM),
Community Panel No. 155166 1800F, effective date September 29, 2017 shows that most of
the Pahala area is located in Zone A', which designates areas determined to be outside the 0.2-
percent annual chance (500-vear) floodplain. A small portion of the community of Pahala,
including some land within the collection system project site, is located within Zone X—
Other Flood Areas, indicating areas within the 0.2-percent annual chance (500-year)
floodplain, or areas with a 1-percent annual chance of flooding with average flood depths
less than 1 foot.
According to the FIRM, both existing LCCs are also located within ZoneX. However, LCC-1
is very close to the edge of the 500-year floodplain.
On April 16, 2018, in response to the pre-assessment notification, the State of Hawai'i
Department of Land and Natural Resources Engineering Division stated the responsibility for
conducting research as to the flood hazard designation for the project site lies with the project
proponent. Also on April 16, 2018 and in response to the pre-assessment notification, the
County of Hawai'i Department of Public Works confirmed that the proposed treatment and
disposal project site at Site 7 is designated as Zone X on the FIRM and is outside the 500-
year floodplain."
The relevant FIRM panel is reproduced in Appendix B as figure 4-13.
This information will be repeated in the Final EA.
10349-01
Letter to Ms. Terri L. Napeahi
Page 3
March 6, 2020
The Draft EA Section 3.23.2 (a) states:
"The proposed wastewater treatment and disposal facility would include an on-site drainage
system to address stormwater surface runoff created by new impervious surfaces within the
facility. The site would include a system to collect runoff via grated inlets or swales, and
flows would be conveyed to on-site drainage detention systems, such as subsurface linear
infiltration or depressed detention basins."
This information will be repeated in the Final EA.
The preferred alternative (Site 7) slopes from approximately north to south (mauka to makai)
such that, during rain events, surface flows drain through the existing orchard to the southern
(makai) end where the flows eventually drain through the culvert located at the Maile Street-
Mamalahoa Highway intersection to the areas below (makai) the highway. Most of the
surface area below the existing macadamia nut orchard contains little to no vegetation to
absorb or slow these flows. The gradient of Site 7 and surrounding area results in this natural
pattern of surface flows which also existed when the area was planted in sugar cane and is
not considered flooding.
Based on the roadway flooding concerns expressed by the community during the Pahala
public meetings held in December 2017 and October 2018, the State of Hawai'i Department
of Transportation (DOT) Hawai'i District office was contacted to discuss drainage at the
treatment and disposal facility project site and the culvert at the Maile Street and Mamalahoa
Highway intersection. On February 20, 2019, the District office confirmed via telephone that
the DOT owns and maintains the culvert at the Maile Street intersection, and that they have
no record of the roadway being inundated by stormwater drainage during precipitation events
at that location.
Stormwater runoff generated from mauka of the treatment and disposal facility project site
will be directed around the perimeter of the site via diversion swales that will convey flow
back to the existing drainage pattern that flows to the existing culvert at Maile Street.
During heavy rain events, stormwater may temporarily back up behind the culvert. There
will be no changes to this culvert and the proposed treatment and disposal facilities will not
be located within the area of the culvert.
As stated in the Draft EA, the on-site stormwater management system would meet the
requirements of Hawai'i County Code (HCC) Chapter 27 Floodplain Management Section
20, Standards for subdivisions and other developments (e) which mandates a site drainage
plan to "comply with sections 27-20(a) and (b) and section 27-24, and shall include a storm
water disposal system to contain run-off caused by the proposed development, within the site
boundaries, up to the expected [design] storm event as shown in the department of public
works "Storm Drainage Standards".
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10349-01
Letter to Ms. Terri L. Napeahi
Page 4
March 6, 2020
Adherence to HCC Chapter 27 Section 20 (f) will ensure the treatment and disposal facility
shall not alter the general drainage pattern above or below the development. Thus, for the
HCC design storm event, no increase in flow amount will be directed to either of the culverts
at the highway as a result of the site development. A drainage report will be prepared during
the design process to evaluate the improvements necessary to comply with HCC Chapter 27
requirements.
The facilities related to the wastewater treatment processes will be designed to accommodate
the associated peak flows, including precipitation that falls on the area occupied by the
aerated lagoon treatment system. The Draft EA Appendix B, Section 2.2 outlines the
anticipated peak wastewater flows from the community, based on the applicable flow
standard. The Draft EA Section 2.3.1 states the aerated lagoons will be lined to prevent
water seepage through the bottom and sides of the lagoons. The Draft EA Appendix B,
Section 5.3 shows the operational freeboard that will be available to contain and to equalize
lagoon flows. In addition, the slow-rate land application groves will be designed to
completely contain both peak effluent flows and precipitation from a 100-vear, 24-hour
storm event. A geotechnical engineering assessment of berm stability will be conducted
during the design process for any berms intended to act as secondary containment. The tree
groves will be designed in accordance with the EPA's "Process Design Manual, Land
Treatment of Municipal Wastewater Effluents". Effluent will be applied at a hydraulic
loading rate that is a small percentage of the percolation rate of the soil, ensuring sufficient
capacity for assimilation of peak effluent flow rates and precipitation from the design storm
event.
This information will be included in the Final EA.
2. See 1 above. Based on this analysis, the project will not contribute to an increase in road
closures due to flooding.
3. See 1 above. As a result, heavy debris generated from the proposed project will be designed
to be retained onsite.
4. The Draft EA Section 3.15 references a November 2016 archaeological field inspection
report that states, while the historical ground modifications have likely limited the
archaeological potential of the site, the discovery of both pre- and post-contact surface
artifacts within the 42.5-acre parcel (which includes Site 7), as well as evidence from
plantation-era documents that the opening of a lava tube containing human remains once
existed in the southeastern corner of the parcel, indicate that further archaeological studies
may be necessary. The Final EA will clarify that the report also stated it would be advisable
to limit the development footprint to exclude the southeastern corner of the 42.5-acre parcel.
This area, which is presently not used as a macadamia nut orchard, but forms part of the
macadamia nut processing plant complex, is the location of a known (but sealed) lava tube
10349-01
Letter to Ms. Terri L. Napeahi
Page 5
March 6, 2020
opening that local informants have indicated is linked to tubes that possess traditional human
burials. Further, by excluding this section of the parcel, it will be possible to avoid at least
one known historic property. The Draft EA Figure 2.3, which provides the Preliminary Site
Plan for the new treatment and disposal facility, shows the 14.9-acre project site has been
developed to exclude the area in the southeastern corner identified as the location of the
sealed lava tube opening.
Between September 18, 2018 and January 10, 20194 a team of qualified archaeologists
conducted a pedestrian survey of the proposed project site and completed subsurface
trenching to determine the presence of archaeological resources. The work was undertaken
in accordance with the State of Hawaii Department of Land and Natural Resources State
Historic Preservation Division (SHPD) requirements, with the archaeological inventory
survey (AIS) approach accepted by SHPD in their August 20, 2018 letter. The results of the
survey and subsurface trenching showed no burials or lava tube openings were identified on-
site. The AIS submitted to SHPD in March 2019 documents that a sealed lava tube opening
is located east of the proposed wastewater treatment and disposal facility project site, outside
the proposed property boundary, and outside of the area of potential effect considered in
consultation with SHPD.
The complete document is available for download from the County's website
at: http://records.go.hawan.ht.us/weblink/l/edoc/100962/Dra"ft%20Archeological%20Invent
orv%20Siirvev%20-%20Pahaia%20WWTP%20and%20Sewcr%20SYstem.pdf
A geophysical survey of the proposed project area will be performed during detailed design
with the specific intent to locate subsurface voids (such as lava tubes) present beneath the site
that may impact design and construction of the new wastewater treatment, disposal and
collection systems.
Based on information in 1 and above, excessive damage to lava tubes and burials will not
result from construction of the collection system or construction of the treatment and disposal
facility at the proposed project Site 7.
This information will be included in the final EA.
5. The Draft EA Figure 2.3 shows the intersection of Maile Street and Mamalahoa Highway lies
at about 580 feet above mean sea level (MSL). The Draft EA Figure 2.2 shows the Pa'au'au
Gulch crosses under Mamalahoa Highway near the hospital about 0.88 miles north of that
intersection and lies at approximately 780 feet MSL or about 200 feet higher in elevation
than the culvert at the Maile Street and Mamalahoa Highway intersection. Due to this
distance and the elevation difference, surface flows at Site 7 would not affect the gulch.
Similarly, the Kaimani Street and Mamalahoa Highway intersection lies about 0.84 miles
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10349-01
Letter to Ms. Terri L. Napeahi
Page 6
March 6, 2020
north of the proposed facility site and at about 780 feet MSL. Surface flows at the facility
would also not affect that intersection. Figures 2.2 and 2.3 will be repeated in the Final EA.
Based on this information and 1 above, development of the treatment and disposal facility is
not anticipated to create restrictions related to access to hospital and emergency facilities.
6. See 1 and 5 above. In accordance with Hawaii Fire Department requirements. Fire
Department access and water supply to the proposed Site 7 will be designed to comply with
Chapter 18 of NFPA 2006 Uniform Fire Code as amended by Hawaii County.
Section 106
1. See 4 above in Flooding section. Geophysical and geotechnical subsurface testing will be
completed for the Paha la Large Capacity Cesspool Replacement Project.
2. See 4 above in Flooding section.
Hook Ups
1. The Draft EA Section 2.1.4 states:
"Around 2006, C. Brewer requested the County construct and maintain a new and improved
community sewer system. A County Council Resolution approved the C. Brewer request. In
anticipation of C. Brewer's dissolution, C. Brewer proposed, and the County agreed in 2007,
to enter into a formal agreement to not only construct and maintain a new and improved
community sewer system but to assume ownership of the existing system including the
LCCs by April 30, 2010."
The agreements are not pertinent to the content requirements of the Paha la Large Capacity
Cesspool Replacement Project Draft EA.
2. The Draft EA Section 2.3 states, the County would acquire, or otherwise obtain the right to
develop and use, a portion of the 42.5-acre Site 7, then construct a new secondary wastewater
treatment and disposal facility within a portion of the parcel. The Final EA will note, the
County is working with the current landowner, BP Bishop Estate Trustees (Kamehameha
Schools), to subdivide the 42.5-acre parcel (Tax Map Key (TMK): 9-6-002:018) to acquire
the property by means of the method they prefer. Sites 7, 8 and 9 would all involve a similar
property acquisition process, as all are currently owned by the same entity. Additional
property acquisition is not anticipated for the Preferred Action beyond that outlined in
Section 2.3.
10349-01
Letter to Ms. Terri L. Napeahi
Page 7
March 6, 2020
3. The County's intent, as stated in the June 22, 2017 US Environmental Protection Agency
Region 9 Administrative Order on Consent is to provide an industry-standard wastewater
collection system and a secondary treatment and disposal facility, a basic service to the
Pahala community, to eliminate underground injection from LCCs it operates to help protect
underground drinking water sources.
In order to meet the intent as stated in the 2017 AOC, the County has committed to perform
the following actions for the Pahala Large Capacity Cesspool Replacement project:
i. Construct a secondary wastewater treatment facility;
ii. Replace the wastewater collection system serving Pahala Community; and
iii. Close the Pahala community cesspools.
Completion of the above actions includes connecting those properties currently served by the
LCCs to the proposed new wastewater collection, treatment and disposal system. Once the
actual costs are determined. County Council action is still required to approve the
expenditures.
The Draft EA Section 2.2 describes the purpose of the Pahala Large Capacity Cesspool
Replacement project is to close the County-operated Pahala LCCs. The Draft EA Section
2.3.2 discusses the construction of a new sewer collection system in the Pahala community to
replace the existing system of substandard gravity lines that currently conveys sewage to the
two LCCs. As described in Section 6.2.1, the current collection system includes facilities
located in the backyards of many parcels. Where easements for the existing collection system
aren't accessible, the County must obtain permission from individual landowners to enter
them, through private property, to inspect, maintain, repair or replace existing sewer
facilities: all activities essential to an efficient, functioning system. The Draft EA Section
2.3.2 states the new collection system would be subject to the County of Hawai'i Code
(HCC) Chapter 21, Sewers, specifically, Article 2 (Public Sewers), Section 21-5, which
states the following:
"(a)Owners of all dwellings, buildings, or properties used for human occupancy,
employment, recreation, or other purposes, which are accessible to a sewer are required at
their expense to connect directly with the public sewer within 180 days after date of official
notice.''''
Each adjacent lot will be provided with a lateral connection to the sewer main as required by
HCC and standards. Under the Preferred Alternative, the design of the new collection system
would extend between street intersections and include sewer service stub-outs (the lateral
connection to the sewer main) to the lot lines of adjacent properties, including the newly
accessible, to accommodate their eventual connection. Accordingly, to close the existing
LCCs, there will be additional properties in Pahala that would be required to connect to the
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10349-01
Letter to Ms. Terri L. Napeahi
Page 8
March 6, 2020
new wastewater collection system, at their expense, after it becomes operational. Such
properties are near the existing service area but are presently connected to individual
wastewater systems. To conform to the stated section of HCC, the respective, newly
accessible property owners would be responsible for the design, permitting and completion
of sewer service connections between the County stub-outs and improvements for stated uses
on their property, as well as for the proper closure of their individual wastewater systems.
The Draft EA Figure 2.6 shows the area of the community serviced by the current and
proposed collection systems.
4. This is not a comment pertinent to the content requirement of the Draft EA.
5. See 3 above.
6. The Draft EA Section 2.1.3 states:
"In 1999, EPA promulgated regulations under the Safe Drinking Water Act's (SDWA)
Underground Injection Control (UIC) Program which prohibited the construction of new
LCCs as of April 2000 and required the closure of all existing LCCs by April 5, 2005 (40
CFR § 144.88). Under federal regulations, an LCC is a cesspool which serves multiple
dwellings, or for non-residential facilities has the capacity to serve 20 or more persons per
day. Cesspools can release disease-causing pathogens and other pollutants (e.g., nitrates) into
groundwater aquifers, streams, and eventually the ocean, thus leading to public health and
environmental concerns."
In June 2017, EPA and the County entered into an Administrative Order on Consent (AOC)
to close the County-operated LCCs serving the Paha la Community by June 2021."
40 C.F.R. § 144.88 applies to all existing LCCs across the nation. Closure of individual
cesspools is mandated by legislation at the State level. In 2017, Act 125 was enacted
requiring all cesspools, not exempted by the Department of Health, be upgraded or converted
to septic systems, or aerobic treatment unit systems, or connected to sewage systems by
January 1, 2050. Though closure of individual wastewater systems by the County is not part
of the Proposed Action, this legislation will affect all parcels in Paha la currently using
cesspools for sewage disposal.
7. No groundwater quality data is available in the vicinity of the existing LCCs. The Draft EA
Section 2.2 states:
"The purpose of the actions considered in this Environmental Assessment (EA) is to provide
the infrastructure necessary to enable the County to comply with the SDWA and fulfill the
compliance provisions of the AOC between EPA and the County with respect to closure of
the Pahala LCCs by June 2021.
10349-01
Letter to Ms. Terri L. Napeahi
Page 9
March 6, 2020
The need for action is driven by the public health and environmental concerns associated
with LCCs, as described in Section 2.1.3." (See 6 above).
8. No.
Nuisance
1. The Draft EA Section 3.14.2 states:
"Wastewater treatment plants can be a source of nuisance odors to the surrounding
community if not properly designed or operated. Typically, nuisance odors are most
commonly associated with anaerobic (without oxygen) conditions and with processing of
residual solids. Incoming raw sewage flows to the proposed wastewater treatment and
disposal facility would first be routed to the headworks, which is the facility where the solids
are removed from the flows.
To mitigate potential nuisance odors, the headworks would be equipped with an odor control
system with a granulated activated carbon (GAC) scrubber to remove odors. A GAC
scrubber passes the odorous air through a bed of activated carbon, which adsorbs the odorous
constituents within the pore spaces of the carbon. The County currently operates GAC
scrubbers at other facilities, and it has been proven to be an effective means of odor control
both locally and nationwide. The treatment lagoons would be equipped with mechanical
aerators capable of maintaining sufficiently aerobic (with oxygen) conditions within the
water column, which would prevent nuisance odor conditions from occurring. The disposal
groves would be irrigated with fully-treated and aerobic secondary effluent from the
treatment process; irrigation with secondary effluent is not associated with development of
nuisance odor conditions."
This information will be repeated in the Final EA Section 3.14.2.
2. The proposed site plan is included in the Draft EA as Figure 2.3. As noted in Section 2.3.1,
"disposal of the treated and disinfected effluent would be accomplished through land
treatment in four groves of native, water-tolerant trees occupying a total area of
approximately 8.0 acres." This 8.0 acre planted area, combined with the sloping site
topography and existing Cook pine trees {Araucaria cohmmaris) on Maile Street, will
provide a visual buffer from both the Mamalahoa Highway and Maile Street. As outlined in
Section 3.19.2 of the Draft EA, the Proposed Action is not expected to adversely affect the
views or viewsheds identified in the County General Plan. The wastewater collection system
would be installed below the streets and therefore would not impact views. Above grade
structures may include the operations building, headworks and UV cover structures, fuel
storage tank, and low berms around the groves. The existing pine trees along Maile Street,
most of which would remain with no changes, would continue to obstruct the viewplanes
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10349-01
Letter to Ms. Terri L. Napeahi
Page 10
March 6, 2020
from Maile Street. The facility site would be adjacent (mauka) to, and visible from,
Mamalahoa Highway (State Route 11); however, impacts to the viewplane would be
mitigated by the planted trees in the basins and by the rise in elevation between the highway
and the facility.
The Draft EA Section 2.3.1 states the driveway access to the wastewater treatment and
disposal facility will be located west (mauka) of the Maile Street and Mamalahoa Highway
intersection. Appropriate signs identifying the facility will be posted at the driveway access.
This information will be repeated in the Final EA.
3. The County's intent, as stated in the June 22, 2017 US Environmental Protection Agency
Region 9 Administrative Order on Consent is to provide an industry-standard wastewater
collection system. The new sewer will replace the old, and there will be less likelihood of
pests attracted to the modern, intact system.
4. The aerated lagoon plant design will not result in the migration of aerosols outside of the site
boundaries. In addition, disinfection processes selectively kill pathogens or render them
incapable of reproduction or harm to humans. As outlined in the Draft EA Appendix B
Section 3.2, continuous disinfection of the treated effluent will be provided to protect human
health and the environment. The land application groves will incorporate a distribution
system at the ground surface which will not produce aerosols (Appendix B, section 4.5.1).
Natural Disasters
1. The County will develop a facility management plan in accordance with applicable rules and
regulations.
2. Seismic loading, including earthquake and soil loads, will be taken into account during
detailed design. The Draft EA Section 3.4.2 states:
"Hawai'i County Code Chapter 5 (Building), Section 5.3 indicates the "International
Building Code, 2006 Edition" (IBC) - copyrighted and published in 2006 by the
International Code Council, Incorporated - is adopted by the County. Chapter 5 is the
applicable code for the construction of buildings, structures, and facilities in the County. The
purpose of the seismic provisions in the IBC is primarily to safeguard against major
structural failures and loss of life; limiting damage or maintaining functions is not a primary
purpose. At a minimum, structures are to be designed and constructed to resist the effects of
ground motions from seismic events. The seismic hazard characteristics described in the IBC
are based on the seismic zone and proximity of the site to active seismic sources.
10349-01
Letter to Ms. Terri L. Napeahi
Page 11
March 6, 2020
The wastewater treatment and disposal facility would be designed and constructed to meet
the requirements of the 2006 IBC and Hawai'i County Code Chapter 5 and would comply
with seismic loadings established for the County of Hawai'i. This would minimize the
potential for an uncontrolled release of untreated or partially treated sanitary wastewater,
emergency generator diesel fuel, or disinfection chemicals from the facility during a seismic
event."
3. See 1 in Flooding above.
4. Hazards related to hurricanes, such as wind, rain, and flood loads, will be taken into account
during detailed design. Applicable regulations and standards, including IBC 2006, will be
adhered to.
5. The Draft EA Section 3.22.2 states:
"The proposed wastewater treatment and disposal facility would require potable water and
fire protection lines from the end of the existing DWS system to the preferred location of the
headworks [and] operations building"
All alternatives would be designed according to NFPA 820 "Standard for Fire Protection in
Wastewater Treatment and Collection Facilities." In accordance with Hawaii Fire
Department requirements. Fire Department access and water supply to the proposed Site 7
will be designed to comply with Chapter 18 of NFPA 2006 Uniform Fire Code as amended
by Hawaii County.
This information will be included in the Final EA Section 3.22.2.
6. The Draft EA, Appendix B, Section 4 describes the facility, and contains preliminary design
information, including redundant equipment and processes. The Draft EA, Section 3.24.2
states: "A land-line and or cellular telephone telemetry system would be used to connect the
wastewater treatment and disposal facility to DEM and facilitate communication with staff."
As outlined in the Draft EA, Appendix B, Section 4.6.6, this system will have an auto-dialer
to inform operators of alarm conditions. In addition, the treatment processes will be
appropriately designed to have capacity to accommodate upset conditions, including pump
and other equipment failures and operational procedures in place to address mechanical and
electrical outages. "A standby power system would be provided by a diesel generator and
aboveground fuel tank with capacity to support three consecutive days of operation. An
electrical service panel would be equipped with a manual transfer switch and generator
receptacle. This would provide a connection to a trailer-mounted generator, in the event of
[standby] generator failure...."
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10349-01
Letter to Ms. Terri L. Napeahi
Page 12
March 6, 2020
7. The proposed facility will be managed in accordance with County of Hawaii policies and
procedures in the event of a labor disruption.
8. See 6 above.
9. Operation of the sewer system will not require a water source external to the proposed
treatment and disposal facility. As stated in the Draft EA Section 2.3.1, "A 25-foot-wide by
1,500-foot-long easement located along the northern edge of the pare el would be used to
provide access to utilities from Maile Street to the treatment and disposal facility. The
easement would contain the incoming sewer line from the collection system, potable water
line..."
F igure 2.3 shows the potential location of a fire hydrant. The Draft EA Section 3.22.2 states:
"The proposed wastewater treatment and disposal facility would require potable water and
fire protection lines from the end of the existing DWS system to the preferred location of the
headworks [and] operations building." Further: "As required by DWS, construction plans
would show the estimated maximum daily water usage calculations prepared by a
professional engineer licensed in the State of Hawai'i. After review of the calculations,
DWS would determine if enough water is available and a water commitment could be
issued."
The above information will be repeated in the Final EA.
Applicable portions of the above will be repeated or included in the Final EA.
The signed petition will be included in the Final EA. Please refer to the response to the 10/25/18
comment letter submitted by the Pele Defense Fund for additional information.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
10349-01
Letter to Ms. Terri L. Napeahi
Page 13
March 6, 2020
P. Goodwin, ERG
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-------
WILSON OKAMOTO
UltMUTtOH
10349-01
March 6, 2020
ref(73)
Ms. Ngaire Gilmour
P.O. Box 843
96-3190 Pakalana St.
Pahala, Hawai'i 96777
ngaire. j ovfoj gmail. com
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - December 10, 2018 5:01 p.m.
Dear Ms. Gilmour:
Thank you for your December 10, 2018 5:01 p.m. comment message regarding the County of
Hawai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our responses follow:
1.
As outlined in the Draft EA, Section 2.3.1, the Proposed Alternative does not include utilizing
alternative energy systems such as photovoltaic solar or wind as a total replacement for
connection to the HELCO grid due to:
• the need for consistent power supply;
• up front capital cost;
• insufficient space on the 14.9-acre proposed site to accommodate alternative energy
systems;
• the objective to minimize the amount of land area removed from agricultural production;
and
• EPA-enforced project deadlines.
Emergency backup power is required whether alternative or traditional energy systems are
utilized. Partial augmentation of traditional power utilizing photovoltaic solar panel arrays on
the headworks and operations building rooftops, however, is feasible and will be further
analyzed during the detailed design phase after loads and demand patterns are better
understood. Additional alternative energy systems can be added in the future if prioritized and
funded by County Council, and the proposed electrical systems will be designed to accept or be
adaptable to additional alternative energy input.
1907 S. Beretania Street, Suite 400 ~ Honoiuiu, Hawaii ~ 96826 ~ (808) 946-2277
10349-01
Letter to Ms. Ngaire Gilmour
Page 2
March 6, 2020
Methane gas is generated at wastewater treatment plants using a process called anaerobic
digestion. The proposed wastewater treatment plant (WWTP) is too small for anaerobic
digestion to be economical. The dry weather design flow to the Pahala WWTP is 190,000
gallons per day, and anaerobic digestion is only economically attractive for WWTPs that treat at
least 5 to 10 million gallons per day. In addition, the anaerobic digestion process requires
primary clarifiers as part of the liquid treatment process, but primary clarifiers tend to be odorous
in tropical climates, due to the relatively high wastewater temperatures. The proposed
alternative relies on natural treatment systems that require relatively low energy
input. Additional detail regarding the preliminary analysis of alternative energy options can be
found in the Final EA, Appendix B.
This information will be included in the Final EA
2.
The Draft EA Section 2.7 describes the site selection process, including the factors and their
relative weights used to evaluate the various sites. Further, Section 2.7 describes the twenty-one
criteria within four general categories (environmental, social and cultural; location and site; land
use and availability; and collection system and service area) that were established and defined for
the analysis. The Draft EA Appendix B, Section 8, provides additional information regarding the
site selection process. As a result of this process, the County identified three sites (Sites 7, 8, and
9) as reasonable alternatives for construction of the wastewater treatment and disposal facility
under the Proposed Action. The final scores for Sites 7, 8, and 9 were 4.33, 4.06, and 4.10
respectively, out of a total possible score of 5. Based on this analysis. Site 7 was selected as the
Preferred Alternative. The site is easily accessible, has good soils for a land application system,
and is close to the existing LCCs.
The Draft EA Section 2.5 describes Site 9, which is south (makai) of the Preferred Alternative
Site 7. As outlined in Appendix B Section 8, Site 9 earned a lower ranking than Site 7 for the
following criteria: presence of and or proximity to archaeological cultural sites, existing vehicle
access, power and potable water availability, and distance from the area of the wastewater
collection system. Site 7 had a lower ranking than Site 9 in one category: topography. With the
distance between the two sites less than 300 feet, they were ranked equally for the criteria of
proximity of treatment units to existing occupied buildings.
The Draft EA Sections 2.5 and 2.7 provide information as to the issues related to the use of Site
9. An unnamed stream near the upper portion of the parcel could affect the selected
configuration of the wastewater treatment facility and the land application groves. Potentially, to
maximize energy efficiency by taking advantage of gravity flow, the headworks, lagoons and the
subsurface constructed wetlands could be sited in the upper portion of the site, or the area closest
to the highway. In addition, since the site is located across Mamalahoa Highway from the Pahala
community, it would require construction of piping and other utilities within the highway ROW
and approval by the State of Hawai'i Department of Transportation. Site 9 would require
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10349-01
Letter to Ms. Ngaire Gilmour
Page 3
March 6, 2020
additional access roads to facilitate both construction and operation of the treatment and disposal
facility and a slightly longer transmission line given its increased distance from the existing
LCCs.
This information will be included in the Final EA.
The Draft EA Section 3.15 references a November 2016 archaeological field inspection report
that states, while the historical ground modifications have likely limited the archaeological
potential of the site, the discovery of both pre- and post-contact surface artifacts within the 42.5-
acre parcel (which includes Site 7), as well as evidence from plantation-era documents that the
opening of a lava tube containing human remains once existed in the southeastern corner of the
parcel, indicate that further archaeological studies may be necessary. The Final EA will clarify
that the report also stated it would be advisable to limit the development footprint to exclude the
southeastern corner of the 42.5-acre parcel. This area, which is presently not used as a
macadamia nut orchard, but forms part of the macadamia nut processing plant complex, is the
location of a known (but sealed) lava tube opening that local informants have indicated is linked
to tubes that possess traditional human burials. Further, by excluding this section of the parcel, it
will be possible to avoid at least one known historic property. The Draft EA Figure 2.3 provides
the Preliminary Site Plan for the new treatment and disposal facility, which shows the 14.9-acre
project site has been developed to exclude the area in the southeastern corner identified as the
location of the sealed lava tube opening.
Between September 18, 2018 and January 10, 2019 a team of qualified archaeologists conducted
a pedestrian survey of the proposed project site and completed subsurface trenching to determine
the presence of archaeological resources. The work was undertaken in accordance with the State
of Hawaii Department of Land and Natural Resources State Historic Preservation Division
(SHPD) requirements, with the archaeological inventory survey (AIS) approach accepted by
SHPD in their August 20, 2018 letter. The results of the survey and subsurface trenching
showed no burials or lava tube openings were present on-site. The AIS submitted to SHPD in
March 2019 documents that a sealed lava tube opening is located east of the proposed
wastewater treatment and disposal facility project site, outside the proposed property boundary,
and outside of the area of potential effect considered in consultation with the SHPD.
A geophysical survey of the proposed project area will be performed during detailed design with
the specific intent to locate subsurface voids (such as lava tubes) present beneath the site that
may impact design and construction of the new wastewater treatment, disposal and collection
systems.
This information will be included in the Final EA.
The Draft EA Section 3.15 provides information on the archaeological and cultural resources
related to the Pahala Large Capacity Cesspool Replacement project. The Draft EA Section 3.15
10349-01
Letter to Ms. Ngaire Gilmour
Page 4
March 6, 2020
states, on March 29, 2018, consultation was initiated for the project under the National Historic
Preservation Act. The Draft EA Section 10 provides a list a list of the consulted parties. The
Final EA Section 3.15 will include that the list of Native Hawaiian Organizations (NHO) was
generated by the EPA from the U.S. Department of the Interior, Office of Native Hawaiian
Relations, Native Hawaiian Organization (NHO) Notification List for NHPA Section 106 and
HRS Chapter 6E compliance. Letters were sent to 14 NHOs during the pre-assessment
consultation. No responses were received from these organizations.
The HRS Chapter 6E determination and Section 106 review packet were submitted to SHPD
with a draft archaeological inventory survey (AIS) on March 13, 2019. SHPD response is
pending. The Draft EA Section 3.15.2 states that prior to finalization of this EA and initiation of
the Proposed Action, the Environmental Protection Agency (EPA) and the County of Hawai'i
will conclude consultation with SHPD in accordance with Section 106 of the NHPA and will
incorporate additional impact avoidance and minimization measures as necessary to result in a
finding of no adverse effects to historic properties.
The Final EA Section 7 will be include that on September 26, 2018, a public notice was
published in the Hawaii Tribune Herald and West Hawaii Today newspapers. The public notice
was to advertise the October 10, 2018, public information meeting conducted by the County in
the Pahala at the Ka'u Gym Multi-Purpose Conference Room to discuss the availability of the
Draft EA and process for submitting comments. The notice stated that the second part of the
meeting would address Section 106 of the National Historic Preservation Act of 1966, as
amended (2006),involving consultation with Native Hawaiian Organizations and the Native
Hawaiian descendants with ancestral lineal or cultural ties to, cultural knowledge or concerns
for, and cultural religious attachment to the proposed project area. Eight persons placed their
names on a sign in sheet at the October 10, 2018 public meeting to contribute during the second
part of the meeting dedicated to the Section 106 consultation. No comments or information were
forthcoming during the Section 106 portion of the meeting.
3. a) and b)
The Draft EA Section 2.2 describes the purpose of the Pahala Large Capacity Cesspool
Replacement project is to close the Pahala large capacity cesspools (LCC). The County's intent,
as stated in the June 22, 2017 US Environmental Protection Agency Region 9 Administrative
Order on Consent is to provide an industry-standard wastewater collection system and a
secondary treatment and disposal facility, a basic service to the Pahala community, to eliminate
underground injection from LCCs it operates to help protect underground drinking water
sources.
The Draft EA Section 2.3.2 discusses the construction of a new sewer collection system in the
Pahala community to replace the existing system of substandard gravity lines that currently
conveys sewage to the two LCCs. As described in Section 6.2.1, the current collection system
includes facilities located in the backyards of many parcels. Where easements for the existing
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10349-01
Letter to Ms. Ngaire Gilmour
Page 5
March 6, 2020
collection system aren't accessible, the County must obtain permission from individual
landowners to enter them, through private property, to inspect, maintain, repair or replace
existing sewer facilities: all activities essential to an efficient, functioning system. As a result,
the proposed new collection system would consist of a total of approximately 12,150 linear feet
(LF) (2.3 miles) of corrosion-resistant polyvinyl chloride (PVC) piping located almost entirely
within the right of way (ROW) of eight public streets.
The extent of the collection system is to ensure the parcels connected to the former C. Brewer
system will have access to the treatment and disposal facility so the large capacity cesspools can
be closed. It is conventional to extend the utility to the nearest intersection to minimize the
number of manholes.
The Draft EA, Section 2.3.2, states the new collection system would be subject to the Hawai'i
County Code (HCC) Chapter 21, Sewers, specifically, Article 2 (Public Sewers), Section 21-5,
which states the following:
"(a) Owners of all dwellings, buildings, or properties used for human occupancy, employment,
recreation, or other purposes, which are accessible to a sewer are required at their expense to
connect directly with the public sewer within 180 days after date of official notice. "
All accessible properties will be required to connect to the new wastewater collection system in
accordance with Hawaii County Code, Chapter 21, Article 2, Section 21-5. However, the
County entered into an agreement with C. Brewer (in April 2007) to eliminate LCCs from the
existing community sewer systems and connect properties discharging to them to new County
collection, treatment and disposal systems. Once the actual costs are determined. County
Council action is still required to approve the expenditures.
Each adjacent lot will be provided with a lateral connection to the sewer main as required by
HCC and standards. Under the Preferred Alternative, the design of the new collection system
would extend between street intersections and include sewer service stub-outs (the lateral
connection to the sewer main) to the lot lines of adjacent properties, including the newly
accessible, to accommodate their eventual connection. Accordingly, to close the existing LCCs,
there will be additional properties in Pahala that would be required to connect to the new
wastewater collection system, at their expense, after it becomes operational. Such properties are
near the existing service area but are presently connected to individual wastewater systems. To
conform to the stated section of HCC, the respective, newly accessible property owners would be
responsible for the design, permitting and completion of sewer service connections between the
County stub-outs and improvements for stated uses on their property, as well as for the proper
closure of their individual wastewater systems. The Draft EA Figure 2.6 shows the area of the
community serviced by the current and proposed collection systems.
10349-01
Letter to Ms. Ngaire Gilmour
Page 6
March 6, 2020
The financial impact of the project on individual newly accessible property owners was raised by
the community during the December 2017 public meetings as summarized in Section 7 of the
Draft EA. Although not required by Hawaii Administrative Rules (HAR) Title 11, Chapter 200,
DEM voluntarily convened two additional public meetings on October 9, 2018 and March 21,
2019 to gain further input from newly accessible property owners and present funding options
for them to pursue.
The Draft EA Section 7 will be revised to add that the County held additional meetings in Pahala
including one to provide information on financing sources available to owners of parcels which
would become accessible to the County collection system. The purpose of the March 21, 2019
meeting was to fulfill a County commitment made in October, 2018 to research financing
options available to the newly accessible residents of the Pahala Community. At the meeting,
DEM provided the preliminary results of the County investigation into funding sources and
options available to newly accessible property owners once the new treatment and disposal
facility and wastewater collection system have been designed, permitted and constructed.
Programs discussed included:
• US Department of Housing and Urban Development (HUD) with County of Hawaii
Office of Housing and Community Development Residential Repair Program -
Community Block Grant Program, and
• US Department of Agriculture - Rural Development (USDA-RDA) Program.
As noted during the presentation, these programs may change in the coming years, and additional
options may be added to this preliminary list. Hawaii Legislature, Senate Bill 221 SD1, which
could amend Hawaii Revised Statutes (HRS) Chapter §342D to establish a low interest loan
program to offer financial assistance to cesspool owners to connect to wastewater treatment
systems approved by the Department of Health was also discussed; however, this bill was
subsequently not passed during the 2019 legislative session.
This information will be included in the Final EA.
Closure of individual cesspools is mandated by legislation at the State level. In 2017, Act 125
was enacted by the Hawai'i State legislature requiring all cesspools, not exempted by the
Department of Health, be upgraded or converted to septic systems, or aerobic treatment unit
systems, or connected to sewage systems by January 1, 2050. Though closure of individual
wastewater systems by the County is not part of the Proposed Action, this legislation will affect
all parcels in Pahala currently utilizing cesspools for sewage disposal.
The Draft EA Section 6.2.2 discusses the Ka'u Community Development Plan (CDP): "Section
5 of the CDP prioritizes improvements in infrastructure, facilities, and services, including
Section 5.8 which applicable to ... Environmental management facilities, including expanded
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10349-01
Letter to Ms. Ngaire Gilmour
Page 7
March 6, 2020
sewer lines, ...Policy 120 is to "Extend the primary wastewater collection lines in Pahala and
Na'alehu so that infill development projects can connect wastewater systems built for new
subdivisions to the County systems."
The collection system will be consistent with Policy 120 as the improvements for the Pahala
(LCC) Replacement project have been designed not to preclude accommodating the Pahala
community. Similarly, the treatment and disposal facility has been designed not to preclude
accommodating the wastewater flows from the collection system from the Pahala community.
This information will be included in the Final EA.
The Draft EA Section 3.16 provides information on the socioeconomic characteristics of the
Pahala community.
The Draft EA Section 5.7 Environmental Justice Executive Order 12898 will be revised as
follows
Executive Order 12898, Environmental Justice (full title Federal Actions to Address
Environmental Justice to Minority and Low Income Populations), was signed on February 11,
1994. The intent of Executive Order 12898 is to avoid disproportionately high adverse human
health or environmental effects of projects on minority and low income populations. Executive
Order 12898 also requires federal agencies ensure that minority and low-income communities
have adequate access to public information related to health and the environment.
The 2017 American Community Survey (ACS) (5-Year Estimates) is the most recent
information related to socioeconomic conditions in the state and County. The 2017 ACS
includes Hawai'i Geographic Area Profiles - Census Designated Places: Neighbor Islands. The
ACS noted it is the Census Bureau's Population Estimates Program that produces and
disseminates the official estimates of the population for the nation, states, counties, cities and
towns and estimates of housing units for states and counties.
For purposes of this assessment, and to correspond with the available ACS demographic
characteristic data, "low income" is defined as having a household income of less than $24,999;
"minority" is defined as any race population other than White; and "children" is defined as the
"Under 5 to 19" age category. Pahala has more households in the "less than $24,999" income
bracket (33.7 percent) than the County as a whole (26.3 percent).
Overall, Pahala is characterized by a racial composition that includes a greater proportion of
minorities (92.1 percent non-White) than the County at large (66.8 percent non-White). The
racial distribution includes a much lower proportion of White residents, a much higher
proportion of Filipino residents, and lower populations of other minority groups, including
10349-01
Letter to Ms. Ngaire Gilmour
Page 8
March 6, 2020
Native Hawaiians when compared to the County. There are also more residents of two or more
races in Pahala than in the County.
Pahala has a similar age distribution to Hawai'i County, although Pahala has a higher proportion
of individuals in the "Under 5 to 19" age category (28.5 percent) compared to the County as a
whole (24.4 percent).
Based on the above, Pahala has a higher proportion of low-income, minority, and children
residents as compared to the County as a whole. However, the Proposed Action will not result in
disproportionately high and adverse human health or environmental effects on these sensitive
populations. The design and location of the proposed wastewater treatment and disposal facility
will minimize odor and air quality impacts. Construction of the wastewater collection system
will result in intermittent and unavoidable noise from construction vehicles and equipment
within the Pahala community, including noise associated with the removal of bedrock. However,
construction activities within the community will comply with provisions of HAR 11-46
(Community Noise Control). This includes obtaining a noise permit for any activities that will
generate noise exceeding the permissible sound levels specified in HAR 11-46. The permit will
limit excessive noise sources to daytime hours; will require the use of best available control
technology to control noise levels from excessive noise sources; and will require the applicant to
notify affected members of the public in advance of any planned nighttime construction activity
(which must not exceed the permissible sound levels). Overall, the Proposed Action is expected
to result in positive human health and environmental effects to Pahala residents by providing a
cleaner and longer-lasting wastewater treatment system.
This information will be included in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
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10349-01 ref (74)
March 6, 2020
Mr. Keoni Fox
48-472 Kamehameha Highway
Kaneohe, Hawai'i 96744
Subject: Draft Environmental Assessment for the
Pahala Large Capacity Cesspool Replacement Project
District of, Ka'u, Hawai'i
Response to Comment - December 10, 2018; 5:34 p.m.
Dear Mr. Fox:
Thank you for your December 10, 2018 5:34 p.m. comment message regarding the County of
Hawai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our response follows:
The Draft EA Section 3.15 references a November 2016 archaeological field inspection report
that states, while the historical ground modifications have likely limited the archaeological
potential of the site, the discovery of both pre- and post-contact surface artifacts within the 42.5-
acre parcel (which includes Site 7), as well as evidence from plantation-era documents that the
opening of a lava tube containing human remains once existed in the southeastern corner of the
parcel, indicate that further archaeological studies may be necessary. The Final EA will clarify
that the report also stated it would be advisable to limit the development footprint to exclude the
southeastern corner of the 42.5-acre parcel. This area, which is presently not used as a
macadamia nut orchard, but forms part of the macadamia nut processing plant complex, is the
location of a known (but sealed) lava tube opening that local informants have indicated is linked
to tubes that possess traditional human burials. Further, by excluding this section of the parcel, it
will be possible to avoid at least one known historic property. The Draft EA Figure 2.3, which
provides the Preliminary Site Plan for the new treatment and disposal facility, shows the 14.9-
acre project site has been developed to exclude the area in the southeastern corner identified as
the location of the sealed lava tube opening.
Between September 18, 2018 and January 10, 2019 a team of qualified archaeologists conducted
a pedestrian survey of the proposed project site and completed subsurface trenching to determine
the presence of archaeological resources. The work was undertaken in accordance with the State
of Hawaii Department of Land and Natural Resources State Historic Preservation Division
(SHPD) requirements, with the archaeological inventory survey (AIS) approach accepted by
SHPD in their August 20, 2018 letter. The results of the survey and subsurface trenching showed
no burials or lava tube openings were identified on-site. The AIS submitted to SHPD in March
2019 documents that a sealed lava tube opening is located east of the proposed wastewater
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 ~ (808) 946-2277
-------
10349-01
Letter to Mr. Keoni Fox
Page 2
March 6, 2020
treatment and disposal facility project site, outside the proposed property boundary, and outside
of the area of potential effect considered in consultation with the SHPD.
The complete document is available for download from the County's website
at: http://records,co.hawan.hi.us/weblink/l/edoc/100962/Dfaft%20ArcheQlogieal%20Inventory~
%20Survcy%20-%20Pahala%20WWTPH.20and%20Sewer%20Systcm.Ddf
A geophysical survey of the proposed project area will be performed during detailed design with
the specific intent to locate subsurface voids (such as lava tubes) present beneath the site that
may impact design and construction of the new wastewater treatment, disposal and collection
systems.
This information will be included in the Final EA.
The Draft EA Section 2.3.1 states the aerated lagoons will be lined to prevent water seepage
through the bottom and sides of the lagoons. Thus, untreated wastewater will not enter the
ground beneath the WWTP. In addition, the preferred alternative (Site 7) slopes from
approximately north to south (mauka to makai) such that, during rain events, surface flows pass
through the existing orchard to the southern (makai) end where the flows eventually drain
through the culvert located at the Maile Street-Mamalahoa Highway intersection to the areas
below (makai) the highway. The gradient of Site 7 and surrounding area results in this natural
pattern of surface flows which also existed when the area was planted in sugar cane.
The Draft EA Summary shows the Hawai'i Island Burial Council was consulted as part of the
Draft EA preparation process. The Draft EA Section 3.15 states, on March 29, 2018,
consultation was initiated for the project under the National Historic Preservation Act. The Draft
EA Section 10 provides a list of the consulted parties. The Final EA Section 3.15 include that
the list of Native Hawaiian Organizations (NHO) was generated by the EPA from the U.S.
Department of the Interior, Office of Native Hawaiian Relations, Native Hawaiian Organization
(NHO) Notification List for HRS Chapter 6E and NHPA Section 106 compliance. Letters were
sent to 14 NHOs during the pre-assessment consultation. No responses were received from these
organizations.
The HRS Chapter 6E determination and Section 106 review packet were submitted to SHPD
with a draft AIS on March 13, 2019. SHPD response is pending. The Draft EA Section 3.15.2,
states thatprior to finalization of this EA and initiation of the Proposed Action, EPA and the
County of Hawai'i will conclude consultation with SHPD in accordance with Section 106 of the
NHPA and will incorporate additional impact avoidance and minimization measures as
necessary to result in a finding of no adverse effects to historic properties.
The Final EA Section 7 will include that on September 26, 2018, a public notice was published
in the Hawaii Tribune Herald and West Hawaii Today newspapers. The public notice was to
10349-01
Letter to Mr. Keoni Fox
Page 3
March 6, 2020
advertise the October 10, 2018 public information meeting conducted by the County in Pahala at
the Ka'u Gym Multi-Purpose Conference Room to discuss the availability of the Draft EA
process for submitting comments. The notice stated that the second part of the meeting would
address Section 106 of the National Historic Preservation Act of 1966, as amended (2006)
involving consultation with Native Hawaiian Organizations and the Native Hawaiian
descendants with ancestral lineal or cultural ties to, cultural knowledge or concerns for, and
cultural religious attachment to the proposed project area. Eight persons placed their names on a
sign in sheet at the beginning of the October 10, 2018 meeting to contribute during the second
part of the meeting dedicated to the Section 106 consultation. No comments or information were
forthcoming during the Section 106 portion of the meeting.
The above will be repeated or included in the Final EA as applicable.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski. COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
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10349-01 ref (76)
March 6, 2020
Dr. B Noelani Hong, PhD, OTR/L
P.O. Box 64
Volcano, Hawai'i 96785
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - October 28, 2018
Dear Dr. Hong:
Thank you for your October 28, 2018 comment letter regarding the County of Hawai'i
Department of Environmental Management Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement project. Our responses follow:
The Draft EA Section 3.9.1 (a) states:
'The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map
(FIRM), Community Panel No. 155166 1800F, effective date September 29, 2017 shows
that most of the Pahala area is located in ZoneX, which designates areas determined to be
outside the 0.2- percent annual chance (500-vear) floodplain. A small portion of the
community of Pahala, including some land within the collection system project site, is
located within ZoneX— Other Flood Areas, indicating areas within the 0.2-percent
annual chance (500-year) floodplain, or areas with a 1-percent annual chance of flooding
with average flood depths less than 1 foot.
According to the FIRM, both existing LCCs are also located within ZoneX. However,
LCC-1 is very close to the edge of the 500-year floodplain.
On April 16, 2018, in response to the pre-assessment notification, the State of Hawai'i
Department of Land and Natural Resources Engineering Division stated the responsibility
for conducting research as to the flood hazard designation for the project site lies with the
project proponent. Also on April 16, 2018 and in response to the pre-assessment
notification, the County of Hawai'i Department of Public Works confirmed that the
proposed treatment and disposal project site is designated as ZoneX on the FIRM and is
outside the 500-year floodplain."
The relevant FIRM panel is reproduced in Appendix B as Figure 4-13.
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii • 96826 • (808) 946-2277
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10349-01
Letter to Dr. B Noelani Hong, PhD, OTR/L
Page 2
March 6, 2020
This information will be repeated in the Final EA.
The Draft EA Section 3.23.2 states:
'The proposed wastewater treatment and disposal facility would include an on-site
drainage system to address stormwater surface runoff created by new impervious surfaces
within the facility. The site would include a system to collect runoff via grated inlets or
swales, and flows would be conveyed to on-site drainage detention systems, such as
subsurface linear infiltration or depressed detention basins."
This information will be repeated in the Final EA.
The preferred alternative (Site 7) slopes from approximately north to south (mauka to makai)
such that, during rain events, surface flows drain through the existing orchard to the southern
(makai) end where the flows eventually drain through the culvert located at the Maile Street-
Mamalahoa Highway intersection to the areas below (makai) the highway. Most of the land
surface area below the existing macadamia nut orchard contains little to no vegetation to absorb
or slow these flows. The gradient of Site 7 and surrounding area results in this natural pattern of
surface flows which also existed when the area was planted in sugar cane and is not considered
flooding.
Based on the roadway flooding concerns expressed by the community during the Paha la public
meetings held in December 2017 and October 2018, the State of Hawai'i Department of
Transportation (DOT) Hawai'i District office was contacted to discuss drainage at the treatment
and disposal facility project site and the culvert at the Maile Street and Mamalahoa Highway
intersection. On February 20, 2019, the District office confirmed via telephone that the DOT
owns and maintains the culvert at the Maile Street intersection, and that they have no record of
the roadway being inundated at that location by stormwater drainage during precipitation events
at that location.
Stormwater runoff generated mauka of the treatment and disposal facility project site will be
directed around the perimeter of the site via diversion swales that will convey flows back to the
existing drainage pattern that flows to the existing culvert at Maile Street. During heavy rain
events, stormwater may temporarily back up behind the culvert. There will be no changes to this
culvert and the proposed wastewater treatment and disposal facilities will not be located within
the area of the culvert.
As stated in the Draft EA, the on-site stormwater management system will meet the requirements
of Hawai'i County Code (HCC), Chapter 27 Floodplain Management, Section 20, Standards
for subdivisions and other developments (e) which mandates a site drainage plan to "comply
with sections 27-20(a) and (b) and section 27-24, and shall include a storm water disposal system
to contain run-off caused by the proposed development, within the site boundaries, up to the
10349-01
Letter to Dr. B Noelani Hong, PhD, OTR/L
Page 3
March 6, 2020
expected [design] storm event as shown in the department of public works "Storm Drainage
Standards".
To meet the requirements of HCC, Chapter 27, Section 20 (f), the project site "shall not alter the
general drainage pattern above or below the development". Thus, for the HCC design storm
event, no increase in flow amount will be directed to either of the culverts at the highway as a
result of the site development. A drainage report will be prepared during the design process to
evaluate the improvements that are necessary to comply with HCC Chapter 27 requirements.
The wastewater treatment processes will be designed to accommodate the associated peak flows,
including precipitation that falls on the area occupied by the aerated lagoon treatment system.
The Draft EA Appendix B, Section 2.2 outlines the anticipated peak wastewater flows from the
community, based on the applicable flow standard. The Draft EA Section 2.3.1 states the aerated
lagoons will be lined with to prevent water seepage through the bottom and sides of the lagoons.
The Draft EA, Appendix B, Section 5.3 shows the operational freeboard that will be available to
contain and to equalize lagoon flows. In addition, the slow-rate land application groves will be
designed to completely contain both peak effluent flows and precipitation from a 100-vear, 24-
hour storm event. A geotechnical engineering assessment of berm stability will be conducted
during the design process for any berms intended to act as secondary containment. The tree
groves will be designed in accordance with the EPA's "Process Design Manual, Land Treatment
of Municipal Wastewater Effluents". Effluent will be applied at a hydraulic loading rate that is a
small percentage of the percolation rate of the soil, ensuring sufficient capacity for assimilation
of peak effluent flow rates and precipitation from the design storm event.
Treatment process options are discussed in Section 2.8.2 of the DEA. In summary, any "type" of
wastewater treatment process (such as e.g., aerated lagoons, activated sludge "mechanical"
treatment plants, etc.) must incorporate both peak flows from the collection system and
precipitation that falls on the exposed process components into the design. The proposed aerated
lagoon system is a "flow through" process, not a storage reservoir. Wastewater from the
community (including peak wet weather flows) will move through the lagoon system to the
disposal system and will not be stored in the lagoons. The proposed aerated lagoon system will
be lined and designed to have adequate freeboard to contain the required storm event and not
overflow offsite. Further:
• stormwater flows generated outside of the treatment and disposal facility will be directed
around the site;
• an onsite stormwater collection and management system will contain runoff generated at
the facility; and
• the proposed land application groves will be designed to completely contain both peak
effluent flows and precipitation from a design storm event.
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10349-01
Letter to Dr. B Noelani Hong, PhD, OTR/L
Page 4
March 6, 2020
Because the above measures would be incorporated no matter what "type" of treatment process
is chosen, flooding was not a criterion specifically evaluated as part of the treatment process
selection.
This information will be included in the Final EA.
The Draft EA Section 2.7 describes the site selection process, including the factors and their
relative weights used to evaluate the various sites. Further, Section 2.7 describes the twenty-one
criteria within four general categories (environmental, social and cultural; location and site; land
use and availability; and collection system and service area) that were established and defined for
the analysis. The Draft EA Appendix B, Section 8, provides additional information regarding
the site selection process. As a result of this process, the County identified three sites (Sites 7, 8,
and 9) as reasonable alternatives for construction of the wastewater treatment and disposal
facility under the Proposed Action. The final scores for Sites 7, 8, and 9 were 4.33, 4.06, and
4.10 respectively, out of a total possible score of 5. None of the three sites were located in
Special Flood Hazard Areas as designated on the FIRM map in Appendix B. Based on this
analysis, Site 7 was selected as the Preferred Alternative. The site is easily accessible, has good
soils for a land application system, and is close to the existing LCCs.
This information will be included in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
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WILSON OKAMOTO
COUP T t § II
i \ . '
10349-01
March 6, 2020
ref(l)
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment - September 24, 2018 8:57 a.m.
Dear Ms. Demoruelle:
Thank you for your September 24, 2018 8:57 a.m. comment message regarding the County of
Havvai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our responses follow:
#1. This is not a comment pertinent to the Draft EA for the Pahala Large Capacity Cesspool
Replacement project.
#2. The proposed Pahala wastewater treatment plant (WWTP) 14.9-acre project site has been
developed to provide the necessary land area for the facilities needed to treat the
incoming flows and to dispose the treated effluent from the treatment processes. The
proposed project site minimizes the use of the adjacent lands which contain a commercial
macadamia orchard. A larger project site is not required. The special permit requirement
applies to the proposed WWTP parcel only, not to the proposed utility easement. The
County will apply for the required special permit through the Planning Commission.
Chapter 4 of the Draft EA discusses cumulative impacts, including the scope of the
analysis.
#3 The June 7, 2018 letter is a designation letter from the US Environmental Protection
(EPA) to the US Fish and Wildlife Services (FWS) to meet the requirements of 50 C.F.R.
§402.28 for the Pahala project. As stated in Section 3.12.2 of the Draft EA, prior to
finalization of the EA, the EPA and County of Hawai'i will conclude consultation with
the FWS. The Final EA will include the final consultation letter from FWS.
#4 On, November 7, 2018, the eleven copies of the Draft EA were hand delivered by the
County of Havvai'i to the Pahala Public Library and a similar number of copies to the
Naalehu Public Library. The County of Havvai'i transmittal requested the library make
the copies available for checkout. This information will be included Final EA, Section 7.
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
10349-01
Letter to Ms. Sandra Demoruelle
Page 2
March 6, 2020
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
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PAHALA DEA/AFNSI SANDRA DEMORUEUE COMMENT #5
New build wamewatei treatment plants ("WWTTV) in the Stale of Hawaii ate not
approved si il* ElmiwmMtl Awwmeiu f*EA") tetirl. so (he fact that (his is published as a
DEA/AFNSI far a new build consbuctkm of a four lagoon secondary sewage
UeaSnsent facility In close 109 LCCs, on I5 acres of land, w ith a twin facility to he
built 11 mites away. btkJ in vtgJalron ol KtHA'creHTuMing environmental review requirements
of the cumulative imparts, means I will be farced to sue if the COIVEPA fails to decide to do the
EISs for the cumulative impacts of the (win projects, as was done on the following WWTP
projects in Hawaii;
HAWAII WWmHEPAllS:
19% WaiaJua -Halriwa WWTP
IWS Waimanalo WWTP
2009 Koloa-Poipu WWTP
2010 Waiak Water Treatment f acility
2011 Kancohc-Kai lua Treat incut Facility
2017 llixioulitili WWTP Secondary Treatment
3/2V20I7 Kealakehe WWTP RI
The FKA/FONSI 4fitf20l5 Ijiwj Krma Sewer Improvement IJisiiict (DWAFNSi
IA5.70IS) was beemc. like I hi: original Nualehi^ftihula LCC etmwrefam projects, no installation
of a new-build itecondaty sewage treatment plant was required. Hie same was true fat the FEA
liTX/'W/ of the lliinnkflii Modification of Existing WW I p.
In fact, theCOWEiPA^OpntratKus should fully explain why Iwti new build smnhiy
sewage plants 11 miles apart in remote, rural Kau would not require a USFN Act 172-12 (Direct
bo E1S) Notice instead of a DEA/AFNSI that is avoiding the cumulative impacts of the twin
projects.
-------
WILSON OKAMOTO
COUP T t § II
10349-01
March 6, 2020
ref(2)
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment - September 24, 2018 10:26 a.m.
Dear Ms. Demoruelle:
Thank you for your September 24, 2018 10:26 a.m. comment message regarding the County of
Havvai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our responses follow:
On, November 7, 2018, the County of Havvai'i hand delivered eleven copies of the Draft EA to
the Pahala Public Library and a similar number of copies to the Naalehu Public Library. The
County of Havvai'i transmittal requested the library make the copies available for checkout.
This information will be included in the Final EA Section 7.
Hawaii Revised Statutes (HRS) Chapter 343 Section 5 (a)(9)(A), states as follows: "(a) Except as
otherwise provided, an environmental assessment (emphasis added) shall be required for actions
that: ... (9) Propose any: (A) Wastewater treatment unit, except an individual wastewater system
or a wastewater treatment unit serving fewer than fifty single-family dwellings or the
equivalent...HAR Title 11, Chapter 200, which implements HRS Chapter 343, however,
differentiates between "agency actions" that utilize state or county lands or funds and "applicant
actions" for which an applicant must seek agency approval. Since the proposed action will
utilize county lands and funds, it is an "agency action" requiring compliance with HRS Chapter
343 and HAR Title 11, Chapter 200, pursuant to which an environmental assessment is being
prepared and processed.
Comment #5 - HRS 343-5 Applicability and requirements states under (c) (4) "A(n
environmental impact) statement shall be required if the agency finds that the proposed action
may have a significant effect on the environment..." The criteria by which the proposing agency
makes the significance determination is provided in Hawaii Administrative Rules (HAR) Title 11
Section 200-12 (a) and (b) which states: "(a) In considering the significance of potential
environmental effects, agencies shall consider the sum of the effects on the quality of the
environment, and shall evaluate the overall and cumulative effects of an action, (b) In
determining whether an action may have a significant effect on the environment, the agency shall
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
10349-01
Letter to Ms. Sandra Demoruelle
Page 2
March 6, 2020
consider every phase of a proposed action, the expected consequences... and the... effects of the
action."
HAR Title 11-200-10 Contents of an environmental assessment includes "(9) Findings and
reasons supporting the agency determination or anticipated determination...". The Draft EA
provides this in Chapter 8 Findings and Determination. Neither HRS Chapter 343 nor HAR Title
11, Chapter 200 contain any requirement that all proposed wastewater systems require an EIS.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
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BPORATIQK
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10349-01 ref (3)
March 6, 2020
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - September 24, 2018 11:15 a.m.
Dear Ms. Demoruelle:
Thank you for your September 24, 2018 11:15 a.m. comment message regarding the County of
Hawai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our responses follow:
Comment # 1 - This is not a comment pertinent to the content requirements of the Draft (EA) for
the Pahala Large Capacity Cesspool Replacement project.
Your mailing address will be corrected.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
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NOTICE OF CITIZEN SUIT UNDER THE ENDANGERED SHOES ACT,
I* U.S.C, tsm CfMlM,*) mi PIP-IPI
PI&SON GIVING NOTICli:
Sandra DemomeHe.
Physical address; »«!•1511 tC»fi,ii»tu« Road, HmUm Hi Wm
Mailing. address: 1*0 Box 588, NimMim III W72-0588
Telephone: 1.808-929-9244
Email:
NOTICIi;
L«ati»ns NmrMm mi I"*!®!#, District «f Km, Gwmtr of Hawaii, Stat* of
Hawaii, ti,S,A.
Half ill corameHcemrst of ongoing ISA See. 7 eoraujMmn violation:
Date. September 11,21115 par U.S. Environmental Protection Agency Grant
Agreement w»W> Cowwy of Hawaii, Assistance ID Numl*rXP-9$fM240l-O for
project period 06/01/2005 - 1201/2007,
CClH Project Manager: Dora Beck
EPA Project Officer: Laura How Official 46 C.f.ft i.2#J|tMS|l
($« llxfciliit 5,Cwe i;Il-ev-CKJ172-1MS-KSC Ooeumwt 25-9 Filed iWI«I»ll
Panes 11® 7).
7he tmifnmi f County of Hamttiij a&vm not is MM or
rafiiisa relmb)trxttanmifr<*,;> ni>i'lK,!hk-1>< ilih (M, Seetim J1!,/
fttff j < v
< in i' i'- i 'i>; !• ,, i11 s «i),, 'ti\'ii"'i i \, • ! n 'ii'
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i '\ mi ti» !i ¦. ' i Ml. ii iii 1 j"i r ir. • 'S,.mi • 'i \ i.' i. ', f ,-i ¦' r •'p,ii., II'-.im i •> ¦¦¦ *!
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\ >, 11- I \ \ ; -rii " •, ''i ¦* •,>> i|,e i . i . . i,! i ;iy ,t I' ' " i . , • • ¦
'•.| I' ..ii. ¦ .x's.'i.iii .tv.i,, i. >. >:» 11 a:iii .!¦>- i" \, i.> i«pi', .i »,, ii!. \
ii, -r.* p it I,. . v.i,,:i,.ir "¦ , l,'1 * \S'i ,! ,i *i,.i. ^ iiiiJ1., ,(!, '"ii, *f 1
i,sr1 >il :!>, I> -II', !'>••"¦'! IS i " ! I 'J o i . If, ¦ ' I I" I 11,1 •[ ' •'! !.
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[ -i Ht- - it ¦' '.'iSi','.',[ it ,-iiii .ss.."-, I ,:>,/ t ,vi.
decUion is made. Ageiwies must '|e|BcoiiF4ge tnil ftttiliiate public iftvohijiiMsiii
il.'.'K: i' - i.!, ,"i '"i. I S' i'H.il'1. •>( i i r . ir .'i 'ii:i I 1 >li i I fi I "V
. I,'.! . /i-, • H'.'f . -,-i I .l(s S •! I'Sir" \?l I'M, I
-------
2) EPA HAS SEPARATED THE It All LCC CLOSURE GRANT XP-
ft»t424ll|As AhmcIb! II through TJIM.j I W<, SI p Mi «. It IT OfECTS AND
IMPISii!) TO FOLLOW MBPAJ1SA PROCEDURiS THAT EPA FOLLOWED
FORTHEPAHALAPRO/i ¦ 1 ^ •< T ! I :i %i \ALUII! WWTP WORK
PLAN
No NEPA nmnnmU wkw procedure* have been wmmcii sa«wr m
«igin»i ¦ t» " • '> v f mian u> Mplic i < . ' ¦ >1 the illegal k . T f >. >-
; VMM. o August 21,2007 issae of TEN. The wijsJnal
2007 ITsA/l'ONSI for t»th the ftibajji arul Maaletiij I..0C clnaima Ims never susss is
Supplemental Notice piibllsihtxl to account for the obvfou* change*tolie original
Kau Ceupool Project
Further since tfita Nwfelw/I'ilitlt 2017 I-EA/fONSI never been
Supplemented or Wilhdnw; .. v««. . i »% (> ci >• .¦•rnfiiitelo publish the
TEN patjiilii DBA/AFNSI Notice on September 2:3,2018 «* part of the
N'EPA/HEPA requisite procedural review,
""To laiike an informed decision about how or whether lo proceed with the
proposed nK»j®cis and lo comply with NEPA, an agency must identify their
potential combined environmental impact* and nuixe wat «*ji Herniation avaifathle lo
ilie public,:" Kkimfdik^SbMtmt v. Bureau of Land "it! F.Jtl 989 f§*
Cir. 2004).
Therefore, I contend herein that lie COHDEM proposed Naalehu WWS EA
» i , .-.yi ,0,'„ V.V.M! 1M H- I...m I-..' L. ,1
separate studies anil documents prepared atdifferent points in time, fail to consider
the aggregate*! and cumulative effect* of the connected actions of the prepensed
wastewater sewage treatment projects m the human environment in the itiilittsi
and apawely populated Ktlrielof Ea'ii,
CfMJ regulations implementing NEPA "wcjuiK avn an agency coiuider
'connected fietitiiiT and 'cumulative ttctinnx' within a single &l offfiT Wtihmdx
Actio* v. US Army Corps #£««««, 222 F,3d 1115, i 1 ill***'' Or,
2000) (emphuit added) (citing, 40 CFR 15(1*25}, Further, under i 5*25,. two or
more t§#»Ky actions rnwt U tmmvti in flit mm impaet statement when they t«
**c»miecl«l* m "eumidHtivv" aclim 40 CFR 15i»,25-(«M 1 i,(2| m cilti in Klamath-
SMUwm v. Bmmtm of l,tmi Management, if-; u: -fPH ff* Cif. 2004),
Ptt/t j of s
A cuitiulalfve impact is defined In NEIWs implementing regulations m "the
¦ « ' «: on (he environment which results <•.«»' ¦> ¦ .r -1. mttttil impact of the action
when added to crt't. i f *s r ¦ j ,, .'i, f®Ksec»Mi ftiiMr«*lio« ....
Cwiimlaiivc impacts cifc rcsuli fre»» iBclwidtitJIf mi nor bat coIle«ti»c(j' liiiiifiaul
actfcKM place over a period tiSTifiie." 40 CT«t lSit.7,
For "eowKcttd" mi ucltwii,, lie agency » IpH it "slwuli*
analyze them in isinfle i s, ki w, i l >• i ... . m .... l-.-.I .. ..
iiwmliiety a«tpiiw«eai. Six Eagk Mami Imiam % C'lfXIJI F.3win§ EPA SAAP fciiliit for the original Ka'u LCC
U» , ' V< . . ^ . 1 'i, 1 . , i „ I,.) . > \ , . P ii ,
in ¥inlt»i«n of NEPA, and faiiM » mxt ISA Section ? confutation
wT. I \\ * j •It.* « '-I ,1 . !««i t»i«» iilsESA in ttcJw* ?»
2011 leller. By altowiug iivniiiwcie of consideration «ir cwtMitnlm! iirnpaicfsi «nit
stoiiiing, NRPA awl ESA statute*. Ms Rao ha* allowed the sepiMtieu of time two
ICt'i ncw-taiW WWfP» Willi ns tfjgtregitiea «i iiiioiea «i sie suBiaoas alfestctl
endangered plam$ and wildlife and appttrently ti»iei*k»aiillf avoiding any NEPA
cumulative impact anatysis. ("{TJhe district court property t!en:nr»iwu that the
Purest Sfciwicis viniated the l*SA when it daciiM twt tn rdntiMte mmmttaihm alter
lie FWI revisill ils «.r*S«c«l hal>iliil:•siftsifi.it.Atiom...,'** CmmirnrniImmnmrnmiml
Low Cenur v. IIS, Forest Servkt. 789 F.3d IBISffClr, 2ilS|)t,
In CtMmmmd, the Fiweil Service eatMeinlial ilia! "fljtie fej%. or tlx on adt
action... will document lie cumulative impacts oMwt action unci all previous
action*," The Cowl believed "thai MiisltathM of e«nutat«e impcta tftt* the
rm4 hw alreaidy (*«n approved »innifUdefn te fulfill the mandate of NEPA. A
central putpwc of the IIS is w few Ac ccwiiicriitiiim of cnvtronrncmal impacts in
s'vm !,«> ,-.,m i i(il. ( 1 A'j- » "u' i * >>• j • }
Sehtwin&sr. mi ¥M 5B5 Cir. Iff!), CifrtfD&w r S21 FiJ Ml
{*» Cir. mS); ijiikrn v. iritwgm 506 f,2l 677,693 (~» Cir. 1974) |«i tow);
-------
CWw/ aifft • C"<.a»i»iw».r * ,«€, 449 FVM 1IW, i 113-1 i 14
flMlClr, 1971). 'filial purpose require* ite the NF-PA process be integrated with
¦geiicy iteming *¦* the earliest possible tine,14# CJFJt. IStti.2, ml lis purpose
cannot be (uly sen-el if consideration of the cumulative effects of successive,
interdependent steps is delayed until lite first step is already token." Thomas v.
Peterson, IT} I-24 W4i, *M»(9* Ck.
Because Ite EPA lias taken specific steps to change the EPA-COH Garni
Asmimm Amendments t* XP-965M240I»us demonstrated by the May 30.20IS
.( 1 ' • ' i ">#"?, wbiek result in effectively mmi , <. ¦ \ II1 \ 1 s \
procedures on the Naalelui WWTP Project by simply moving the EPA ssiuiiory
ik* away to the twin ftifisilt WWTP Project, I hereby give Notice
®fa pending citiwn suit under the USA.
Hereto 1 #a» the EPA I uii. • .«• . ¦ *. . > m .. i * * Set ? coraultttkm
foi Mtiitehu as Rate Rao did for Pahata ml request that before there Is any
decisions cm either Project, that a* EPA-COH1*: required to provide Hie same
ESA Section ? consuftmion and issuance of a iliotogjcui Optnkm covering the
cumulative actions Hint will "jeopardize it* continued existence* of multiple
h «:t«ur«i and plants far Iwti the Pahal* ami the Naaietm
WWTP Project*.
I dv'.l i V m* Ct [• .-ulty ofpwjwy that the forgoing is true mill comet.
Dsieil;: September M, 21!I« Naalehu, Hawaii
s/Sandra Dentoitieite
SANDRA DEMORUELLE
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10349-01 ref (4)
March 6, 2020
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - September 24, 2018 1:21 p.m.
Dear Ms. Demoruelle:
Thank you for your September 24, 2018 1:21 p.m. comment message regarding the County of
Hawaii Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our response follows:
This is not a comment pertinent to the Draft EA for the Pahala Large Capacity Cesspool
Replacement project.
We appreciate your participation in the Draft E A process.
Sincerely,
Keola Chang
Project Manager
W. Kucharski. COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin ERG
1907 S. Beretania Street, Suite 400 * Honolulu, Hawaii • 96826 • (808) 946-2277
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|j>rl
woe 10-18-2018
To-
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MHuUjK OEA..Co»nwt_<6.%Hi_CKKyb»_f<»Oi_Unr9e^U»nt.tfaoc
PAHALA OIA/AIMIS SANDRA DCMORUE U.E COMMENT *
COMMHfTI#- lilt Patiiflsi WWIP 11 built to h utittfe 180*000 f,,il/d,iv «Wfc
actual flow reported for a larger population bdv«? m 2DQf FEA waa 10,000 i/d sa
tli* faciRty design Is is# large.
To paraphrase Pat Tummcm srs her iBvimmmmi HawoN environmental
rwwstatier fWtjl. I, ffc, 5 Now, 1990): ftw quoted material In tali tfpt|
tots of Perl, little Stw*K«»" n-, " m Ka'u Sewage flams
"Sartout proM«m» mfof scwKflnf to the results of "talk-story* meetings beW by
Count? af Hawaii Department of Environmental Management contractor irown
mi Caldwell. B&C finltf iBtitin.fi April 10* -1 J* in riaaf#hu as ia$l 3,2 at the
Mmlehtt Community Lorgt Capacity Cesspool (tCCf Replacement fmimit.
The COHDEM plans to locate a ful-sii* Wastewater Treatment Plant, featuring
tour open mmm Ufoom. on property next to the fteattw Elementary School.
To demonstrate how serious the COMKM m to put this sewage plant nest»a
school, last November, the County started condemning private property and
acquire a famlfy-owned -ranch by June 201S.
lie problems Identified by the community can lit placed generally in mm
r.iti^prio%: .wt .if thenawfacility and capacity (th»planned sewsp plant
autctrlpi any dmumrf litolf to dawtap in Ksateiii for the Iff# af tut mm
-------
fie Clean iVaffeMcf
tt »# the County h»d wanted wxt compliance with el«»f»-w»fm requirements,
and with Am taut inw to the taxpayer and payer of mmmiBw mar
feet, it pcotalif would have «ptaf«l aiternativi* mivjni ut M'VMge treatment -
methwitv, s-uvh ,11. lunttructod wetUnh, lh.it aum-rally.m- i*v, tjpiij? jnd
UltfH • mwnMtff than m«iod treatment plants. At th# very least, it would
hate brought the planned treatment plant's slw more In line with reallstie
demand projections and would have developed »timetable for construction to
mlntmtee the Naatehw ICC problem.
once again. as with the Wo sewage plant in 1181, none of Oust mmum
pursued, When ciit«s *u§pstiit attamaifo* tmummt mMhotfi, the tettm
and accompanying MrrmIm mm ignored »the CPA's RESPONSES TO pubuc
COMMENTS ®n the AOC Attachment 8, No nwi of any further dncmsion ef
IMs proposal win tie provided upon request of Naalehu resident Sandra
Demoruelle without IP* requiring i payment of $1112 in F 0»A fees.
The Emimament HammM article goes on to «mai the problems at • swage plant
that is too targe for the amount of wastewater requiring treatment:
The problem of too large a sine fibm is 'unctenrtilitation (plants do not function
well * routinely opera fed.»«* ff«tiMctftfciirc«p „• * t o s ;s . * i « t *, <. , H ! I Si •.
10349-01 ref (5)
March 6, 2020
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - September 25, 2018 8:32 a.m.
Dear Ms. Demoruelle:
Thank you for your September 25, 2018 8:32 a.m. comment message regarding the County of
Hawai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our response follows:
Comment #6 - The Draft EA Section 2.3.1 states that wastewater flow projections were
developed for the treatment and disposal facility using the City and County ofHonolulu
wastewater standards, most recently updated in 2017. Based on these standards, the Pahala
treatment and disposal facility would be designed to provide an average dry weather flow
capacity of 190,000 gallons per day (gpd), which would be sufficient capacity to close the two
LCCs. The Draft EA Appendix B contains additional detail on the flow projections. The
corresponding peak day wet weather flow is 650,000 gpd. This information will be repeated in
the Final EA.
Future sewer main extensions and subdivisions will be accommodated, as capacity allows, on a
first come, first served basis. The Draft EA, Appendix B, states the wastewater treatment plant
(WWTP) design will be expandable not to preclude treating future average dry weather flows up
to 360,000 gpd (with a corresponding peak day wet weather flow of 1,260,000 gpd) to meet the
future needs of the community, in accordance with the requirements established in the Ka'u
Community Development Plan Policy 120. The Draft EA, Appendix B states the proposed
WWTP will accommodate modification within the proposed 14.9-acre site for the future
expansion of the service area.
Hawaii Administrative Rules (HAR) Title 11-62 requires wastewater treatment works to be
designed in accordance with county standards. If a county does not have design standards, then
the design standards for the City and County of Honolulu shall be used. The County of Hawai'i
does not have design standards; therefore, the City and County ofHonolulu standards are
applicable to the Pahala WWTP. Application of the standards resulted in the flow capacities
presented in the Draft EA Section 2.3.1. Additional detail is provided in the Draft EA Appendix B
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
-------
10349-01
Letter to Ms. Sandra Demoruelle
Page 2
March 6, 2020
Section 5.6.1. It should be noted that wastewater flows from a community are highly variable, and
peak flow rates from small community wastewater collection systems are typically three to five
times higher than the average flow rates. The City and County of Honolulu standards take this
variability into account, and application of the standards results in conservatively-designed
facilities that are protective of human health and the environment in anticipated operational
conditions. This information will be included in the Final EA.
The Naalehu and Hilo projects are not the subject of the Pahala Large Capacity Cesspool
Replacement Draft EA.
The proposed treatment system for the Pahala WWTP includes aerated lagoons that are more-
energy efficient than conventional activated sludge wastewater treatment processes. The aerated
lagoon process is less sensitive to underloading conditions than conventional activated sludge
wastewater treatment processes and will provide excellent treatment performance during low
flow conditions. The "negative removal efficiency" effect is not applicable to the aerated lagoon
technology. The proposed WWTP does include a constructed wetland treatment system and the
proposed land treatment tree groves provide an energy-efficient "natural" technology that will
use sunlight, vegetation, and soil properties to achieve the desired results.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
fU,i« ,K».„ WOC 1U-10-ZU16
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i!t54»|J) J*«i»:ls or hn4 tftc antat*f which is gnaltr IS .*;«« «r f»» talis m
mi|M nili -full t<( Mih|ul 1.» ,if.pr>'».ii in Iht I mi! um ...(rrmMinri I tit t.iml u-i
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covers a minimum of 667,S00 sij. ft f 15, i bspssJ plus thr utility hob trntsl lw cwwMwwl as f»ft« of the futtjixt
imjuct* no nutter WtK) wilewi»ii».tot!i»ii*iiiK>ih£f mwrhmk Im ikl *ae*.
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msmmtif m the nest of At DBA lafi.wwtiti.cnL
TV COIIDKM et ».l. wouH be weB KWwd th* tftqr •«* goingto fciwe to "rnStm »it* niptewttlitms" tlie?
•tile in the EA ami Special fetfnit a|ifIfciilfoo, iitista I..IJC stpetvision. I1IC oiiij; see ihrougli j-oiir jmrporinl
fcctuiif MmMiM to (fct Mm clai«m tint iiinkflie ga| j.j
SWBRA OSIOtWI!,1 J- Bmi Ikptmimr 25. »l S ail KisJtii* Hxwaii
Osf«»Kfc*. 2«# »M *7 m KSt NmMw fh, «m> wtet».
LSOM OKAMOT©
RPORATIOK
:> „• 4 t o s ;s . * i ^ t « t N i H ! I *
10349-01 ref (6)
March 6, 2020
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - September 25, 2018 9:39 a.m.
Dear Ms. Demoruelle:
Thank you for your September 25, 2018 9:39 a.m. message regarding the County of Hawai'i
Department of Environmental Management Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement project. Our responses follow:
The Draft EA Section 2.3.1 states the County would acquire or obtain the right to develop and
use a 14.9-acre area for construction of a new secondary treatment and disposal facility. The
Draft EA Section 2.10.3 states according to Chapter 205, Hawaii Revised Statutes (HRS), §205-
4.5 (a) within the Agricultural District on lands with Land Study Bureau master productivity
rating class A or B shall be restricted to the following permitted uses: (7) public, private and
quasi-public utility lines. Thus, the 1,500-foot by 25-foot utility easement is a permitted use.
The 14.9-acre area is the appropriate project size as it provides sufficient area to meet the current
and future needs of the community that the WWTP will serve, while minimizing the impact to
the adjacent macadamia nut farm. Further, as stated in the Draft EA Section 2.10.3, the County
of Hawai'i Department of Environmental Management will submit a Special Permit application
to the County of Hawai'i Planning Commission. This information will be repeated in the Final
EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
-------
10349-01
Letter to Ms. Sandra Demoruelle
Page 2
March 6, 2020
cc: W. Kucharski. COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
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-------
WILSON OKAMOTO
COUP T t § II
10349-01
March 6, 2020
ref(7)
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment - September 25, 2018 12:28 p.m.
Dear Ms. Demoruelle:
Thank you for your September 25, 2018 12:28 p.m. comment message regarding the County of
Havvai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our responses follow:
On March 8, 2018, the US Environmental Protection Agency (EPA) notified various Native
Hawaiian Organizations (NHOs) that the County of Hawai'i Department of Environmental
Management (DEM) had been authorized to act in EPA's behalf when initiating consultation
under 54 U.S.C §300101 and 36 CFR §800.2(e)4 for the Pahala Large Capacity Cesspool
Replacement project. The NHOs to be notified were selected from those listed by the U.S.
Department of the Interior, Office of Native Hawaiian Relations, Native Hawaiian Organization
(NHO) Notification List, Updated December 14, 2017. On March 29, 2018, the DEM notified
those on the list about the proposed Pahala project and welcomed their comments under 54
U.S.C. §32706 also called Section 106 of the National Historic Preservation Act (NHPA).
Further, the DEM letter requested the addressed organization, if acquainted with persons or
organizations knowledgeable about the proposed project area, or any descendants with ancestral
lineal or cultural ties or cultural knowledge or concerns, or religious attachment to the proposed
project area, provide their names and contact information.
Notice of availability of the Draft EA was published on September 23, 2018. Subsequently on
September 26, 2018, a public notice was published in the Hawaii Tribune Herald, West Hawaii
Today newspapers, and the online Ka 'u News Brief. The public notice was to advertise the
October 10, 2018 public information meeting conducted be the County in Pahala to discuss the
availability of the Draft EA and process for submitting comments. The notice stated that the
second part of the meeting would address Section 106 of the NHPA involving consultation with
NHOs and Native Hawaiian descendants with ancestral lineal or cultural ties or cultural
knowledge or concerns, or religious attachment to the proposed project area. During the October
10th meeting attendees were invited to provide information about the proposed project area.
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
10349-01
Letter to Ms. Sandra Demoruelle
Page 2
March 6, 2020
Subsequently, notice of availability of the Draft EA was republished on November 8, 2018 and
the comment period ended on December 10, 2018.
Based on the above, the EPA and the DEM have provided the necessary notifications and the
opportunities for comment to NHOs and Native Hawaiian descendants with ancestral lineal or
cultural ties or cultural knowledge or concerns, or religious attachment to the project area.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
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-------
WILSON OKAMOTO
COUP T t § II
10349-01
March 6, 2020
ref (8)
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment - September 25, 2018 12:39 p.m.
Dear Ms. Demoruelle:
Thank you for your September 25, 2018 12:39 p.m. message regarding the County of Havvai'i
Department of Environmental Management Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement project. Our response follows:
The councilmember's name will be corrected in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
-------
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»
-------
WILSON OKAMOTO
COUP T t § II
10349-01
March 6, 2020
ref (9)
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment - September 28, 2018 9:54 a.m.
Dear Ms. Demoruelle:
Thank you for your September 28, 2018 9:54 a.m. message regarding the County of Havvai'i
Department of Environmental Management Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement project. Our responses follow:
Hawaii Administrative Rules (HAR) Title 11 Chapter 200 has no requirement for conducting a
public meeting in conjunction with preparing an environmental assessment. The October 10,
2018 meeting was voluntarily sponsored by the County of Hawai'i Department of Environmental
Management (DEM) to encourage public participation in the environmental review process.
HAR 11-200-9.1(b) states that the "period for public review and for submitting written
comments for both agency actions and applicant actions shall begin... Written comments to the
proposing agency... shall be received or postmarked..." (emphasis added).
There is no provision for receiving oral comments in HAR 11-200. However, during the
October 10, 2018 public meeting, the facilitator offered assistance by persons available at the
meeting to put any oral comments attendees might wish to offer into writing.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
10349-01
Letter to Ms. Sandra Demoruelle
Page 2
March 6, 2020
cc: W. Kucharski. COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
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LSOM OKAMOT©
RPORATIOK
:> „• 4 t o s ;s . * i * i, t « t *, i H ! I Si •.
10349-01 ref (10)
March 6, 2020
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - September 28, 2018 11:52 a.m.
Dear Ms. Demoruelle:
Thank you for your September 28, 2018 11:52 a.m. comment message regarding the County of
Hawai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our responses follow:
Please refer to Appendix E for additional information regarding this issue.
Hawaii Administrative Rules (HAR) Title 11 Chapter 200 has no requirement for conducting a
public meeting in conjunction with preparing an environmental assessment. The October 10,
2018 meeting was voluntarily sponsored by the County of Hawai'i Department of Environmental
Management (DEM) to encourage public participation in the environmental review process.
There is no provision for receiving oral comments in HAR 11-200. However, during the
October 10, 2018 public meeting, the facilitator offered assistance by persons available at the
meeting to put any oral comments attendees might wish to offer into writing.
HAR 11-200-9.1(b) states that the "period for public review and for submitting written
comments for both agency actions and applicant actions shall begin... Written comments to the
proposing agency... shall be received or postmarked... (emphasis added).
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
1907 S. Beretania Street, Suite 400 * Honolulu, Hawaii • 96826 • (808) 946-2277
-------
10349-01
Letter to Ms. Sandra Demoruelle
Page 2
March 6, 2020
cc: W. Kucharski. COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
prorr^
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S«fc|»ec Sr. MwtlBf «• fatal* tm Om ¦ on Oct. Itt ®»- «• «w:e i» ttmm m mtt ml
At* y«u planning lt» h*,» peil« jpramnt to anwt u« for *p*»king tm fhl« tail*.**»!% cBntiwr-fiai
PttHSeitM*^' >1' I ,v ' 1.1 < , rK ¦ , .1 , , },
0 adequate mm tmmlim, I will to pmmm to <*»t wiM *
all EPACCM«:» nrt any MMm to OCR.- San Franoaco.
• • « • ¦ ¦ >• • •' >• ¦ >' mtmm.why-wmrnrnmtmmcomments
m 9m m»t UEA Biimintinif maattoB? Anyone who mmm to provide WRITTEN commented such as
rnfrnK, wi do so. I do not noed» fo I® • puMw meeting to hear -written comments tern
lirBliii English language persona. LSI*, sm tound in. P#»!ii,
1 any o • . s •. .• .1 . < i a. 'IHEMIMiiiitoMt#- ¦ ' r^r.i.h iwo-*ei»m«!
fraquett '> ¦ •¦> >• r ¦ i i i n :Ii (• ,i- \ Hi i - v | • > i-i*
But sine® none of yon -osi#® ulsoiit m#. or Niiittehu «r Pi*.* i *«¦ tam icmm •«. 1.1; 1'.n- .i frmvetifif Am»Wean taxiHiym from
0<»wantiii'~nt Spfvisiiiii .vi w.ir.ttfuil Carmaite.
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Eflnitf weo-M alow I* -iwtl commei^f, «t( ttw f.m 10 nwedng.
mm written mnetmm m mmnnm * a»i s m the DEA er not. . ¦ , f„
Oat* C
Ills Worn Kgferlli, ©
-------
WILSON OKAMOTO
COUP T t § II
10349-01
March 6, 2020
ref(11)
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment - September 28, 2018 1:21 p.m.
Dear Ms. Demoruelle:
Thank you for your September 28, 2018 1:21 p.m. comment message regarding the County of
Havvai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Community Large Capacity Cesspool Replacement project. Our responses follow:
This is not a comment pertinent to the content requirements of the Draft EA for the Pahala Large
Capacity Cesspool Replacement project.
Formal police presence was not requested for the October 10, 2018 community information
meeting.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
-------
Sill MattakaWMl
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Oe
I * . . , .w>, >..¦¦¦ <> ,« . I'M 'I
woe octl9-2018
»«f» mmmmtt pliant
: ¦ ' i erc^gcis to eteiift ihn ICiiy
iCta urn ftotftg Id be GWSItf loan funding, why wasitt liny study donn cit line uounw « rtuwfut
tmrnrnma Drowdea m mmmUmm me ucA. epeeiiilf »n ilftii «f #w (tiwiirilstiinf COW l§« tune, i®
m pttmmt mim of tan* tm *w projects.
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L . !* a LCC datum
propels with »»lfusion costs Mttietl will under m». psir of »fiar«tloi»
Ife to&mm is iJiwBft in ttiii QEAolcoi*l£le«liaii or the Const*"# pf®s«fii ana potential fewdan el
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3*
-------
WILSON OKAMOTO
COUP T t § II
10349-01
March 6, 2020
ref(12)
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment - September 28, 2018 1:43 p.m.
Dear Ms. Demoruelle:
Thank you for your September 28, 2018 1:43 p.m. comment message regarding the County of
Havvai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our response follows:
Havvai'i Administrative Rules (HAR) Title 11 Chapter 200-10 Contents of an environmental
assessment does not include a requirement for evaluating the fiscal impacts of a project on a
County's budget or ability to obtain funding.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
-------
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-------
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roifii»
-------
WILSON OKAMOTO
COUP T t § II
10349-01
March 6, 2020
ref 13)
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment - September 29, 2018 5:50 p.m.
Dear Ms. Demoruelle:
Thank you for your September 29, 2018 5:50 p.m. comment message regarding the County of
Havvai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our response follows:
On September 12, 2018, the Draft EA for the Pahala Large Capacity Cesspool Replacement
project was filed with the State of Hawaii Department of Health Office of Environmental Quality
Control (OEQC) under the filing dates schedule established by OEQC.
You have referenced an ElS-specific checklist. The most up-to-date guidance available for the
EA process is available for download at:
http://oeqc2.doh.havvaii.gov OEQCGuidance Forms A1 litems.aspx
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
-------
Suit October I, lilt 1039 Wil
Sootoifc, br*den.ia«citbHg0*fg.cam
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' ^ !|M 1 ® v 'J *i i m t ^ r 1 f1 1 i ^t ' "¦' 111 !'Mf p' ' it. *1 >" ' v.*
Aloha.
In si* of ft A Section f*» your MTO ffiifi en the AOC tm is meson %tm « i m wire not 13
*ww owifct «® '•'» >'•'> I' find any reason to »%r on the AO!' % • ' . s -wia
-k i ¦ „ , , . \v. , ¦ r, *• I)| K
Yeo said Ibaft **!»§ « MRS1*1$ compete Defendants to do rtiitwms* .Hi,in ten to makm the 6A
refcrrnt
|«» fejih statements tor avoid^io &ufcltcati&ft under MRS '343 and ©foftietefi el the taaijesigd
fi&MJ Ufiati UIFA »• uiiiru*, do you want to chimp four MTD te an snttMr to my ConplsKit?
OthtfwMi Ptanlifr* Qp(»sgtx» will scorch yen, IM tat iww '.»• !«•• f-.-» (.«- . ,
m»f.tmi»«P*" to »* of my p»*m. tff
But Sandm OwrnorwtMi
I ¦ i,. . > - i ¦, • , I • mmarni4m$mm€mmmmimWsm '»«< U.4WI*
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it
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ft, m$, Brmtm ««rf OM "Mtmrn-f" mmtimf - *# »»lr •JmMIr
r»i®aiili»
-------
WILSON OKAMOTO
COUP T t § II
10349-01
March 6, 2020
ref 14)
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment - October 1, 2018 10:29 a.m.
Dear Ms. Demoruelle:
Thank you for your October 1, 2018 10:29 a.m. comment message regarding the County of
Havvai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our response follows:
This is not a comment pertinent to the content requirements of the Draft EA for the Pahala Large
Capacity Cesspool Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
-------
ItmiiliiTlw»l» «im»[iuUn*n»yul mu.com»
mmirnrI, KM* t«Mi *M
Mm** Comment #TJ 1» f|H NMn Mtm
fc:h«Sf.r!l»IIS
M mammrn Mm naa s» OS. FaMn to ife so mmm mt Em and cohoem an
•«!*§ m EIS prat*** tor tha liflipi pr§f#ct til 1lh» Ku»i ICC ,
I, SQttfei NmMw, Htmaii
6/BmmSttmtmrn-
SANDRA 0EM0RUB1E
if tft »tt 01 «« m MST. mmm Tknta torn war
-pf ptfjS Wl® §8 Will -WW 5Wi|f m CSWtf IF?© l\Uy
IXCi ara going to {IB CWSRF Imn funding, why vnmnrt any naif dona or tha Cwwtty or t tawati
fKj*wT/i*Hi«ir»*i/* »NfisWii*''{aSuHt S# i rt.f ii%& RC A iiflA/'-talfc# .a IirtJUf <•»# »r*rtitfrv»rw* i** f\&rt law §», _
piPWW II f > If® WW MUM, HI U§JO% 05 1CT0 Q'«1 ISIbSIWI v J» I »«s*A *$»
#»e r«'iiT.atv rmm of fcin* I* #w projects,
In other wants, f»® EPA fflleiii has fatei to assists even tie slnffe impart «lthe
: ,¦ i • . i;.i «* <», .*> •. i >-3n^ financing, •Itsitfi' stmuedtoy
hmo Mam'* expanding mm, M tlon# tha omuMw* implicit of financing •• too Km ICC eteMir#
prr""5 v.,'if: costs, ixwwxi with una* one year «f separation.
Mb imMtMim is given in *m DBA o! noMgotfoa of «m Coi,«%-"si present and peteMM teirttoii ef
ww icnt mm wnp wwm iwowy ft w ^owwy i$»s iw p^eiUii © kwww #
iKarrewBt* o( tlwiw fivo fiieiegls
|kK V ITwiU- Ik ffi 'SjJ ^ * &.5if S~6^ 64 b s B B s ,1 V.'® •
Also, why irnt i*i carisitliinHfjH been given I® noft-lotal ftnanewn l»k««»» MiiiiMbiH Waalawaier
Cen*tociofi Grant of EPA?
m 8*n*» DamoKMift
SANDRA DEMORUELiE
Oft TuifiiBf, Suptiniwif as. -Mt 8 i2:aiMi» P*i m& I, immmu rr#ii» mfcrnr
pmm ^ ff^^1 if** liSljS' a w s.« n.^^, j> \*+. - - t. ^ ^ i* - '^¦'1^ |api
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, iiili is
if
-------
ATTACHMENT A
Sixyvv/Hrid Duniti Mclknvrtt pwnH tor hii S'mrlrku FJrtm'nlary Scktmi hinderjpirtrn
rfAlttiwrn h«fi4+ thtf&ut opf*t fvftwms propped by the County of Hawaii ai ihr April
!2t 29lit Brown artd Caldwrft "ra/kst&ry" mttrlng - the sck opportunity for "public
participation."
p^cis«ili
WILSON OKAMOTO
CORPORATION
IKNO* *fO< J « • tMQINtt"*
ref(15)
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - October 1, 2018 10:41 a.m.
Dear Ms. Demoruelle:
Thank you for your October 1, 2018 10:41 a.m. comment message regarding the County of
Hawai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our responses follow:
Hawaii Revised Statutes (HRS) Chapter 343 Section 5 (a)(9)(A), states as follows: "(a) Except as
otherwise provided, an environmental assessment (emphasis added) shall be required for actions
that:... (9) Propose any: (A) Wastewater treatment unit, except an individual wastewater system
or a wastewater treatment unit serving fewer than fifty single-family dwellings or the
equivalent.Hawaii Administrative Rules (HAR) Title 11, Chapter 200, which implements
HRS Chapter 343, however, differentiates between "agency actions" that utilize state or county
lands or funds and "applicant actions" for which an applicant must seek agency approval. Since
the proposed action will utilize county lands and funds, it is an "agency action" requiring
compliance with HRS Chapter 343 and HAR Title 11, Chapter 200, pursuant to which an
environmental assessment is being prepared and processed.
HRS 343-5 Applicability and requirements states under item (c) (4) "A(n environmental
impact) statement shall be required if the agency finds that the proposed action may have a
significant effect on the environment..." The criteria by which the proposing agency makes the
significance determination is provided in HAR 11- 200-12 (a) and (b) which states: "(a) In
considering the significance of potential environmental effects, agencies shall consider the sum
of the effects on the quality of the environment, and shall evaluate the overall and cumulative
effects of an action, (b) In determining whether an action may have a significant effect on the
environment, the agency shall consider every phase of a proposed action, the expected
consequences,... and the... effects of the action."
HAR 11-200-10 Contents of an environmental assessment includes "(9) Findings and reasons
supporting the agency determination or anticipated determination..." The Draft E A provides this
10349-01
March 6, 2020
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
-------
10349-01
Letter to Ms. Sandra Demoruelle
Page 2
March 6, 2020
information in Chapter 8 Findings and Determination. Neither HRS Chapter 343 nor HAR Title
11, Chapter 200 contain any requirement that all proposed wastewater systems require an EIS.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
f #16 1
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i!% .III' |ll»I gnd €,}»»» t«sjts»«%*
Pleas# note timwmnm Qualify Conwoi look BOTH WRITTEN AMB ORAL
(K MU|J|! MT*' ~»v (fk, mur- .•» itr-on nf.m ni
vVmlPCni Id w Iflf
Ttir-c rj ,w PIMTOA *0- i/UH buix ontractor §««¦ 3«rwlicy to state iMi « fiw uetcfisr 10th
Pilwf* WMCwwttr Syaftum OCA mattine: "no ivnr w> I tw ail^wl i«> ,pt^ ii# m- I.PA
• H iHkin UK tflMfet fit murfbuttw* Is* «y to •pM* up. Witt 9mm toHawaii Hn'irr m
Mnp «ra from
StrfCly,' ¦ ) ¦ > I 'It- s'.t ,» «)'1 f " I '| e>l'>i >'i Mm*- !- >• — >< . •• >¦ scnphcu. w
OEQC lilt *»«», llwt altovMng m FrWrtom at Spoach Kitmts to f®3»k ow i ranch?
Ariuall^, m HrA nbmi'rt 'jkr NtJPf I'tv hsm rro|rrf*, !<••;> than 11 unlet
jpdi'l ilijultl l:u (.eiiswiVtud tuyelliuf jnd tntmtfi ,i HEPA 343 3iit5UI|9|
•Wfll# Flft »
-------
This n
IP* I H fc» l'i»i I tvlJ /VI fc*?* WISm cU^L I t Ul'KI
FOR Till* DISTRICT OF HAWAII
CASE NO. CV JIMIMTl JKIS-KSC
sandra Life iliciliiw jle, h# &* j plaintiff's
I»I,A1«T1W J MEMORANDUM Of
| POINTS OF LAW AMD
«i 1 AllTIIMMfllS IK OPPOSITION
ANPHBW WIJEBt Jilt,«A » TO DEFENDANTS' MOTION
J TO MSMlSSs CIRT1IIC'ATE OP
»«WI»A«?8 I SfcllVIC*
[ >
I Hearing Ilife; Octlit*
) TIibk If;## w,
1 I Iitifis litel»*lS*»lrifli
PI AIKflPPS MEMORANDUM OP POINTS Of l,AW AND AI!Tif«R»TI» IS
i, introduction
; llainnlTSaudis tee OkhmAi, P«» St. ICa't. wmmmm mmmmrn flints f-W*'TI%~i
, Project Wat Plans Im> jmiMiliiig. m violation of MiMwiii (•nvimntnetrttl Fsrittsw Ml {"NF.PA")
: <12 use sue. «Z I« i«%- mmmj and w&umtt poutim 6*
submitted f« fwijlfeitfera m ««|»»fel % tic NEPA ami HtwsX wvit* mum
-------
|| A"5),, §lri»itii fevtsetf Sfsiiifes filK.§*l 1*13 «?# Wf. PIsiFitili cfiiMcdgo ihf tfeisicm by J
j },a\ '\, 1 M :u , n t ¦ r. 11 ,, {,i J i t v w tie ^ «*•»,»' r (
I , . X r - , ». M 1 , I' , . - , „ « , I . , • . , ~ . t „ , '.s , P
6 JOCJ tt mi-} applicable St# im project*' £s5 fGnml Agwenwnl ¥ 14 |
teerdlsf te lilt fMwJsili" Exhibit 5, wttkfi k mi aiiihtiiiiCMttl hy any MYidiivii I
!„ ,k V* i' V f " ' > i*rv „r \ , " c ;V k ! ; „ ^ p i 1 F ! / ,
|cq%®I|' aftlawi.fi Cifiiii 4at«t SeptrislKsr 2§,( 200St Scstis.ifi ilPI I
L K>, - ' • ' ' fi ' l' '1 > 'H i i '\[ ( '• I % ' ' \ p .r'1 < i' .1 t
lifiSKuitet^ feir the '"Ktu C&*sQt&I RepUi&ftttni Ptojotf" fee ifw "deft#;n wfct of I
¦' \ -if > »¦ ' 1 \»i> v \ - h E 1 •? jv t 1 ,i 111 1 s i „s t1 \\„ ;¦ i ,-s
1 As i&Atti hi III® wipaii Clfiril AgraenxBi (&C tin* S}. tte i£l*A-au&i£ffrd project I
I ml 5 fitfge ei§j»ci(y cesspools.1" f'fe Miiiltflio awl f%Imlii IX1X being gcogrtpKtcftlty [
v s : « I , n v j 1 , i i i i > v, i. s : i ui, ]ii *K, miii" i. ' i , s i ®
II::
I . * V h > ' | i IT . ^ I » 1,1. < < r, i II x ill ,
I'V.:. ! .1 1-. *'..v ¦¦¦ I
I \ * . <\ , i , . . Sl > • 4 t j ^ , , ;, ".u|, |r .ls. t }lS , ,,
1| Cqiviss^' -of I fa wall ftf Ki!WlfroMnf«tial itrtff «n j
|f'\4M:ili»e€ Amrnktma? IXP-WM3«W»?( tens to tlx Plaintiff % 'Hie tliiifiiifi
j I io&iliiafi felt#. NaaWtuf Its ms4 llw V$~A wldi ccsftaiiff M I
1{ NEPA.^ciW'^rwIiBig pfetifsttwm "mly to Hie ^i?Piiifiiicl«Mi*Wwf€m-iter1Vs»:liii€i!i *kI Dii|»sal I
|| Sf iftiii" list is fc fetalis Comnunily Lai"gt QvsKiiy Ccuspoolx ffcplaceittcAi Pnt3«i
; i '• ^ » ii.-m , . > f i i n j i i-i 1 ' ¦>.< i» ' • i i ' i. t ' » i
II Msistug sis® Plains® Tbc PtainiilTeteliiis iNai the llfA Ifefenflaifi's w?- I
1 ¦ • •¦' i i >' •• • i" • • , ¦ - 1. i-. .• i i ,, , ', , i i,. |
I required by MBfA mk! I t»«sii f«i»i»a»n«>stit c*vi*w slalet* rllEPil'l, HRS M3 ti setf.
ivils K»I»«EPA'J tespj.»i*iScOilictiil,ta»linfeciIiei*ily iop«»vitlt timimmmmal !
tmmw (40 CTli ft !*» of fie omMw tffiKtt of mt> Btw,t»mfcl ramnei,»,| m-wrftty
• i i'.- j ... , , l. ' • .WTt
I SfM,33 m, !*•]«:« •«<* further »«*'
-------
II, «6!»!i'f¥T
a,. Arfca*iMi*i«iiMi. <«v s »i iiMiint t rmmi AUqpiMa
Flsiintiff iritis ilisAiriiofj? and iiipificii re lelltf Iti protect MWfi itilijfigifi «l taw,
•BifHSietaliy lift iiisefffts iisit the EPA comply wMt the NEPA tail EPA reguliiierj- mqummttim
for jijlshe pmtipitKni in wlt»iUyi^»harwliv«to the mmimM project* (40 CFK IS0l..T|i.
Tl»i ftolBti If Mists tills lelfef by mpufing EPA to comply willi MRP* ts nvt -mkI
C^ilpICUIIf IIIC I U i. i 'us f i , *"1 < i, ,p . single sfecU! » 4 V
fe«tts the arid Hiafcljsi Wwl. Plaits fcefofc iny fiirllicr s s l w..ir.,;
oiflbwriag., iiJiAtgit aehfe* i.rclit|i.5i*ifk»t mmMm; m cf»5»«e»i«» «» titotie #1 «ii| jWBpxml site
in either Mtmfetat «x Palials,
II. i .rW lu.N.ik'n,•>,[«<
I tic I kJ(Uiihtvfi ihl?
j>l it.fi paint ii toptopw hmmm » f.Vl«S liligll
OHOEM
feMMiwcccwqr.
f"PlefeKtaMl sae*ff.» #iiftdi«tl»i. of (#*] challenge at finis print is inquvper
, Wc fell fi'lsiTitiiTf | lawsuit if n|H" for
»lj*4(C2ilii>« "* Cmmm*/ Bm-trmtrntrnd km Ctmr v US FermtSemc*. W>
<
A procedural dispute. ««eb mt the cue in fueak* ii ripe "a Ute timethe
{prt*«l«f»ll Imhm; ttifca pirn* " Wlwti # paly mifkm ft pnxreduntl injury, ii
I "may e&tt&ffl&irt fif ifcal fiiilmfi?M slic tltfss liivr Miles? infers fiiax, for lite cliiliii rail
never get riper."" ,S» <»*• f'mmvifyAimxkiitm %>:. Sierra I'lats ei «', IJJ U,S,
?2*. Til f !**(; jut mm~ Hie inmrownce of project-specific iBiplsKtitatkifi'!»
imsteviiM tn thefi)
«***¥>• r; CSIM. J4I f,J«1 %1»9?? (9* Of. 2i§3|»»cited in
ism ctmtf *«. us. #««,»«** «? r,ji wis »mi m hove weigBksl ilial «arel« eiMBftlknce with ils
{J if. it? fulfill llir jpa.ab»..-. ** Afpiw
framtm Socttty v. SrAfajjfec, 511 F.2d IM»{9* Citf. if75? p**«» Kttppt v.
Siermt'hith 42? VS, m, fills ««wi'» wis ammmrn ttat Ite
5
If is tiUKMttt tm &&6S, m this txstwy 4i> irrf ibal a^mcm Mfy
avokkxS nisFA l&t mmm fmt mmmMt M, 2005 v» pmrnm%. m
If C«ft ftc«fcs Uf fe i\k angiwl 19*11 C a/iTFf Vtf0s' Vmwifm^tiwg
II 1 ¦" i :::¦ . n ¦ » ^ .!... .......
"Flie UBf A «I§MMm m i,i«sfarci of c.cws|>11m!C^ iiMtwIiiliig
II " a partteisbf :»i1 of cirefwi and iftforawcl clc^isonftwking pp^rss Hfid
mmm |adfeWl? etsttmeMz daaeat... >. |l |f ite fagme^ 1 aaeWoR wm
II tmAM rn'iilifttti IwIK'tiij^iired €As%klef#iiAtt wm| Halnr^lf^
-------
tfltir itaaiJiiiiB,"stl 111!
l» "
l - " > " 1 I !¦ i .
£H-sm,h>& tlMrt w#sm* Wn»ag&isi«s^ m MMfciQ- g»-%. umuffiMyiw mtg.ip? iu--
ttquwM tl»t ©tlidirff t>f iltl pw|»ff
Si«A.tk of (he Bwwwnwtol«
•Wis pfo|t*«| wfetrfi wsB ilia flw
Ckifmthmtmivmm
uintaiiHy be mnOe.
imj»rt«»c«>,''''
t si |istfiaiiiif ion
mfcira.ti.fe- liulies. It* reviewing mm proiwNjr mmrnl reverse a
vutetgntkvc ileeWoii «ii m merits, imilft Seelitm fit, imiess it he shown
ilia lie Maw* c«f earn md liriiiiflis iiiii mm wmk mi aMta* «*
etenl}' p*« a*tilli««nl weight <» mmmmmmirnt wlw*. iM if *»e
decision was reached pwotaaNy witliout MMdalM eonikteBtkin
., < 1 v^Mtckfegtlifs i . , I . f .« it . ! * 1 .i ; „ it 1 i
H h fc? pe^amtliilily c€tte m&nm K?v***e
Tint i$mbm i*« Js wlelfct lift* Cmnmnokm is comet in ilikking iM ill
MIJ'A rof»m»t>jlriii|'» iwy *!*• earned twl * two outodc the hewing
fit, ¦ •!. ... •; •• i ".: , , l,t .! ,.,. p ,i Mtalilliiftt
! sin ii|^f ie-ifest fl* ptvtew lm*l
-fiCti-W: ft# ui. r^Wl rtS'f: », f=-« vUlJi:
¦M " " ¦¦ * 1 ¦¦¦ :0" i f " - ¦ '¦ ¦" :l" ¦¦¦ 1 ' " II1 .":¦!
cctliiiii Mm and p^eni? Whit posislbfc jxirpise c«ilt! fh* 1* in
die '"¦dfittsted.MMfiBCftt" to Im tslbfi lieaaftg btwdi, if ilw. fKwdls
1 i > s , • i'Ui Ml ¦ ' V '• \
t». ^twiJc «feo»«M»#ter< vrilh •« ct»»iBwiiitaihi!
dtKtecnre stiSlslcmly tieteilwl fenitl in iIk iatelsitliw fcaiit® wf*«het w
(ira££€il Willi Om ia light si' hi emKquiMsea, Ml (1)
mite i4t«bl>k ift it* pubtfe, Mmnmtkm of itw i*5f»wl pufca"*
i Blicf |WflR»jpiH®B Ml the tpwiCTl! ^jf
fhas IfifiwnijUK*." Tmmt ttmUmilaiv, Uimm, S» ¥M HT6, HM3 tfPCk.
7
-------
ll as iritpsifftiRl iirall ewwimawfilat tliElsiiesi?? h& |ite|sifai aiii'l
circulated fo* mmmrnt and fwniiilwl to the Council nsmrly * pambfe in
iie ajptiEj' review process ia order » permit agency isaikwisifa and
f-rvk-wro to fjw lo ll®
Issues wwiIwi. In particular* agencw* wbwifet k«p tn mintf fJwii wl*
Mi&BMBis lie Is mwm is she means el"ittl«sswi|; Ok: eiivifeiaMtfiilij impact
. f ¦ >, . . . .* .. ...a .. W . . i .. . ,
€»i F«mw tnait .a% ajiiMimiM.taii wr
¦., . ¦ "... •¦!' - . ¦ ¦ .
mrnimid for emmmi pirn la the first significant
point of tfcciiitin in ll* igriiey review (woeess. Sate vfCfttifaritfa *
tlw El'A fefctei. w mximt the Propowxt A«n
• '¦lA>nl» prkir to At. I. uppnrnwi • i . ¦• •••
pasted (;"!»}' refining m Asefa*; in Action unlit after nil eppMiMhy
i>r mmm ha* pamed, in «geney imaima im JesifhsMniiiiif, pram faun
jwlilie scrutiny. Sue* s result rcndm NUPA !'s procedures meaning less-") Sfclf of
iMifttmim v. Jfcl, «FP.Ai ?$J t9*C«i. MWJ). Therefor* wi,tli«u
lo permit -uiieaaiiigfiil aiiMMtialisif of the Susileha Work Project
under EPA review for «MI mwipitMm, fc Ka'u ccnmmnity and Hie jfsiiaai
psM* coofcl twi participate through intelligent tomment* before tlie Jinx If 16
j "f fjii-v ¦¦;,:¦¦¦»¦ ,v? irtc IBS-IftftmwsiiiM'HMi ilw Aetiss tiwte s!l tfie:
[Niilehi Vett niMMMi Inch*
1 " ™ >•• »¦!' ' " " i I 'I ..1 v , ... , . . (.
cnvtronrocnttl harm. CiTfie pmmm vftmk sto»« mm mere «i
US tortsStrrkx. 142 F.&#Jdl248( 12MKU. ld*h»2»0l)).
j tlie /lit*." Wtiris i'itiiw the SfVt provided ft* Bwiiwnt* in M»jr 3IM# falrf In
.
pruvkk lie pt»1»lie •ill» • nKMingfiil C|if*fliiBl5. » cmnmM flu the CCIHIMIM
Illlt. li ! <' 1 • ; r M n > It • W H t ..
by Ite mitimm tligiw »>f fc Immsti t«viroiiii»«Wl tflkls ©f lh* siting cl'lfc*
Pt83»|Mfc®«si j $#ic44:il,l lit* «I»p4# Or*
25. i lfl>K2l I At Biiniainia lltf mM afgmf wmk p'*® *mhmk:} "A
pWpMei MlwAife fat ftnMte ji*ifWft»nl«» iKlhitiei *» tapM «»jiftr ctecl»«,
liiefaiiBt OMiiiMiuiikw paims rei|»ns»Qie* suiMiasfiis will be.">
Bf liiling 1®efiitiis1 CtlIDEM iollewalcvfii the iiitiii'initj *fmjiifeof
u::- <:y-;r f ?:>.¦< wrsv
pwpcKWft-of tte |HEPA| Act itself/" Bmin iamlPem&im A%$rn v.
SiiVmmger% MS f .3d M ('/*" Or. 19? I)
%. fiaiimitlke m»i Jmsli§ Omtshm
-------
By waiting ounce n yiaiB to ewsn "m$. In pre piiitm «t any ewimiiiftwiiai
lift. IB* t.tK IfC l^s" ' Ulf^ illlij llld.l
M 776, ?R («•" C !r JW+HliiiefiisWiefatlafisafMl
fiiaaliena "Tliiis, #tata pmisigduml vMrfe« bM iBiie, ii plglntiiT
oust »»t 'ratsn |j n.H aoniiil sliiishn* It* mlmsstMitji mmI uiBimliiKj'."* iipiw
r Offender* mf WiUiik, U.S., SSS, $11 ii. ? 11 IS® M eilrf itt
fmmmmmmtitl tsar CV»(isr «. I/X F»isi ,%»»«.•«•„ ?S9 F.M 1075 {9* Cu» 201 S|.
(A plaiafi'titsil wo a Ikfctal 'sg«iKy juort .jilw that; 11), iss
wliiclt I? 4el!iifwl to ! laiiyw i#
iKf", lifiij 12} it "Mfcwi cWntr 'tttiiil wens' « •• »}•«>* ft*»f wiilits Ifce 'mme
ti' Itrntma'' lougfct i« be ftmmtii % the ««ibi« «*» wlfch JltiJ «»ia#.M« Is
Imx4," -We 1**< tiomil, of Kitiittllt
-------
11
interests nitif wniaili* 'tmtam injury," fcw m km* inwsat Qm 'flmnlWb cite
sal>- fiiifer a««#««« itftiifj if the Fs#e«f S*mce»., |ii.[ tuMfeflafcing m
iltfeiteuliif i» ami-make iitfiwtiei tiinl mm m threaten torn is lite pkiiliBs'
firt«ifiisj inter**!* "*i i'ewifrfiw Hiolam~"f fkw.ufy v 41. f f til \W,
S.iiSi? |Ci* Cif. M»i
Hi. CONCLUSION
tw flic slilttf dsiy lllc IHfciKlMdj ft)?
ifeiiwiial, 11k Uitfowjfcstfe tiifrishtmxj tiic Nitelfctre wjiBBiMitly will* #
Evwy day C.SBSC1 mate »!*?» me rtsiiiB?! mm net aaeaed communaiy.
ll "> 1 1 ¦ " "I • * «fercfe
end of IVwmlwjr. making, h .'iliwm impawiht* In »«li» rl» effeffs eifstest- iti-rowsnvctl piftifcrs-
If slit 1>«iis t'jjt.! r« ¦ ls<: ;i:siiiibbs ihe linutiii, Jaw much rnmm of* cunucne iiajuwy u tamfittg
out ll* t'tstjeet Wait. Schedule. in eimipiiinec w«!i to ACIC? I Jew vsiy i ivs; ihra n "i» aaw or
}(Is mmwf" Utaha VwmrwUm luttffie i« Mmmrn, f$6 F,2d M«» « IM6 (f* Vii. 1W2)
Hew* the wufatitjB »«f HI-FA ami tin
oaietilial fill*! ion I* had tin* tniiiBwlic effect*. iifsl ci
iapn, item generally ««ua item m injury wr vetoing SEifA mum.
To Its* *ef| «if»y, tf* EM ha* not f«t«inwt theCOHDEM to foltew It* MEM .
yf.i»4 f:m
fekfcti.iwtiaBtl. I Jttiiajs any eBviftaitiaoiiiri m-nim prtmm., COIIOJiM had no ttpf»ttuB>% lor
«if eu«wa«f»iiy input for giu'dancc. itailfiitf »the proposed fttt placed ¦ Ml-
jtiwf, m-wty b
ckmcnttuy school. an uiraitlfwl itlioti ilia COHDEM thought wits such m optima!
ufechiatis thai !ȴ ft&rl ia vi-slsficifi stifiirfs-WK
ffonwally, the County km mm -tma £OffiplI«d with the exccndbd time for pife
! pirtit'iprtuMi m lh«r l%t>|ert fititi FPA Ajprml ®«is 2tII Slit M»IpIhi Worfc
;¦< .I,in'(CJsisK.11».R4 the Cliiiti'fiisch fl#,C ^iwl l~«isiSlj!VX ».a$-!s> liavc ""lifiirficd""' by
| IMMiL with*-Tiii.il RmmtOMcacT 12» »a HOTIll So "mtmmVmmmt m smmw.'
II' lis il*,4 Is not 'ifjifMiiei, u I'bintilf to* fec|«esl«i ©I"ilia Cowt, to jmfvide NliPA
i pryvnlwrm ;:¦>!'= nt!oi'i.;i='!ai ufifc |Wtj {C«*» WWW fmtyxtx Ilic EfA will CTOiiwK: to wS
utKtecfctil with no ti»ns|»«fci»£:y fw eiiimti. Titus Court is to
-------
•00112 JfkfS-K.SC
CEiaiHCAllLBEJIEaCI
mv CWF1TV THAT, m tlsfc due and fey tlm. wiImkI of mmkts mmni Mumi;,.»mm «nd
copy of the PlaimitTi Oppwttkm iiwf Mcmonn
IIS. KPA Affmg Aimmiatamt
!J9t)«Pei»wyh"»nl»Aw,>
t*
>s
'
?*
US. K.m Region 4 Admmistnrtor
US. EPA Rej|i«i9»7S Kisitofite St, San Fiwkmco CA *1IBS
Hi S. P.tA SrfM* <). 7* Hmatmrn IB!, Sun FranciscoCA ~««
K«fc i».i
I (T P^weri C«*mftnairtr
v*v ' i s .'**j iriuior
Ivm-f .... I', ,* en Section (Wl'K 3-2)
<«.. fel»A feg.i«» 9.75 Hai»
-------
10349-01
Letter to Ms. Sandra Demoruelle
Page 2
March 6, 2020
343 and HAR Title 11, Chapter 200, pursuant to which an environmental assessment is being
prepared and processed.
HRS 343-5 Applicability and requirements states under (c) (4) A(n environmental impact)
statement shall be required if the agency finds that the proposed action may have a significant
effect on the environment..The criteria by which the proposing agency makes the significance
determination is provided in Hawaii Administrative Rules (HAR) Title 11 Section 200-12 (a)
and (b) which states:"(a) In considering the significance of potential environmental effects,
agencies shall consider the sum of the effects on the quality of the environment, and shall
evaluate the overall and cumulative effects of an action, (b) In determining whether an action
may have a significant effect on the environment, the agency shall consider every phase of a
proposed action, the expected consequences,... and the... effects of the action.
HAR 11-200-10 Contents of an environmental assessment includes "(9) Findings and reasons
supporting the agency determination or anticipated determination..." The Draft EA provides this
in Chapter 8 Findings and Determination. Neither HRS Chapter 343 nor HAR Title 11, Chapter
200 contain any requirement that all proposed wastewater systems require an EIS.
The reference to "twin projects less than 11 miles apart, should be considered together"
apparently refers to the proposed wastewater treatment plant to serve the Naalehu community.
HAR 11-200-7 Multiple or phased applicant or agency actions states that "A group of actions
proposed by an agency or an applicant shall be treated as a single action when (1) The
component actions are phases or increments of a larger total undertaking, (2) An individual
project is a necessary precedent for a larger project; (3) An individual project represents a
commitment to a larger project; or (4) The actions in question are essentially identical and a
single statement will adequately address the impacts of each individual action and those of the
group of actions as a whole." The wastewater projects at Pahala and Naalehu are not phases or
increments of a larger total undertaking, are not precedents or commitments for a larger project,
nor are they identical. Hence, there is no requirement to consider them in a single environmental
review document.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
10349-01
Letter to Ms. Sandra Demoruelle
Page 3
March 6, 2020
cc: W. Kucharski. COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
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sorn October III, SmfSiim
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lilt MMNkawK
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Contcactara cmca fin* haw iIbim i t ?« M .• . . «i > i>" > " v '|l -i .¦•"rfnf week of
1 I ' . « r'- - ' I 1 A lit- « , -I! ¦, i." ; .• II •• :,* ,> : .if >, : * ¦
¦V. ,',f y.1 I I a Mi ( i , , <1 ffl*fiiH*ti« $$,$»,8$ on-going pwiiiil Ifijufjf claim
ftifi§ tecauae you am »lotiwe mm %mti i* Ptlitu n*«iwit*H!
andnDflflMfuaM
Iliii ttmtage has tarn *a»fti»#d for w . . , .,,, M ,m I m U..I v, »,n ... h
t-t
LSOM OKAMOTO
RP0RAT4QN
?»4'0*5 **i «
10349-01 ref (17)
March 6, 2020
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - October 6, 2018 9:00 a.m.
Dear Ms. Demoruelle:
Thank you for your October 6, 2018 9:00 a.m. comment message regarding the County of
Hawai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our responses follows:
This is not a comment pertinent to the content requirements of the Draft EA for the Pahala Large
Capacity Cesspool Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 * Honolulu, Hawaii • 96826 • (808) 946-2277
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tsar fu« »«rg «»i* iiiii mm mm ma »»»ip1«» •
fill CCMOCHi «I1«. MUM m •«! ntf»»sl III a» goifif ts mm la KM» is m
fiA ami a^teafers.. l„yC 11.|C ftay «.## fmif pmp^W4 fxswi
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| M TI* CrilCWT COURT OF THIS THIRD CltCM?
j STATE Of* HAWAII
UMmU I!, MlMli , H 1 , ,. —)
! I
I «„AMWf ) MIliMlSASMIMflrLAW
i > isajr»rrorft,Ai»nprs
i - v.- 1 OrraSITION TO DEPENDANTS'
! i»tw iccK, we, «as. > mvnm to dismiss complaint}
! t CERTIFICATE Of SERVICE
t
j DEFENDANTS ) Ittiiriiig. Dates October 15, lilt
| I Time ftllijit,
I . . iMhtet t£. NfoUrtiM*
memorandum of law » support of fluntiivs imyostiiok to
PisiJliffpre «• Sandra l„ Ilcmonislle, risfsrtfiilljf »mlwiiils itt opposition In
IMeitls«i»«s" Motion to Kmum ike C\wij>fsii«t. "i'lis PJinmitTs Cemphmt not wily mms
Is* exce«ds tfw standards governing »h« fen® of si complain! as mptired If lim Hawaii
Sulci of CM l(t>r SiMtfieilly, ihh Court tan (x»i®iitf itiiiiiiaictB owr tint
Pcfancttnu, ii*l fee fotipliidi mfitiwnly jtlJfjti eausiifc* »n# harm. mm4rnt$iy»
i
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TABLE OF CONTENTS
(.. W1SIVOTCIION .S
a. argument..,,, s
A. .Standard M Review of COHDUM Oeeuion net to Publish fc Msakiia Of A...,.,. 5
B. Defesimili* Lack orJurimlictbn HRCP tl(hX 1J AltcpMon ...,,.6
I lit" Mmakhm Kwramrr 61 "m no# Am j»w " ft
ii ¦ >. 1 ! ...Ji .<» ...
J futum A'mklrnEd liarpwptat of i'OHDMMnuitmtlltosmtimml
C. Defendants' FailunMo Slate a Claim HRC? ISffcMfiJ'AlIeiiiliiJlt,II
1 melmim tmdtr vm a
2 Alkpttm tifptulmf m Sum Cimm m Cmmt **,. ......... 14
111. CONCLUSION.......... t«
TABLE Of AUTHORITIES
LAkEH
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MECIILATIOMS
MAR 1 l-JIMMIJ., IS
4#2.S(lf«T|,
«€»*ts«.:!Si:.M
OTHER AUTHORITIES
,?
IS
Cat I Eiwirowncnttl Management Comniiltc* Meeting MtwK*. «5" Notice (I B*j, ........................ t
Tflif Kit b Ofasfcr, JwwJOl*........................... T, 11
i. irrmoBucnoN
Wilkilia* dtovt* thai it# Cmmfy of Hawaii DcptrMMM ©fEiivi»»i»*oai
M#.i»3»§e»si» rCOHDEM"! lliwtitgfc te officer*. ttt»® Stock. PII. I'SAien Chwf of lie
Wmmwitt initl Direa upwcly m nof ftiei
% i tmn awiiicipil
School ill line Waritl «:>(*Ra'a, *», llifielete,, PliiMrff is itftliileil »o jiiig**: m a •sMtii# of
its ^llk*"
u J 11. AlllillMEHT
iat A-. mm*** *t Kiwle* mt COWNM KmMm m* tm MM lb* ffaiiteiiis. DEA
;.i
i, ii
II
Tlx Biiiiilii*. in Count 4, aiteiipsio me 0*1 U* iitwofiiijeiiijil Pmlcaimi Agenejr
fllf A-'liacl caillifcl wwpirel to evade National HwnmW I*Wk? Asi fNlilvn
applicability to »li< Snalefcn Adcnnvittraitye ttsfci on CottKttl ("AOC'"} Wodi .("Iiiii by
»t i J iMmferrwjt 111* M PPA-lriggfiiitf, funding I# lli« fulwl* ,%<*' Wnrft Wa« «»M*y SMI .itt.tr
i* J Minaiiff fifcd IIS IM Ctmii, rs.ifki ofMmimii filln">CV rt4»IT2 JMS-RKT An May 10.
"itw. Tic hid cv iMioiTi JM&.RSC w: Hs. 7 "* "
m NmMm to
n
v., | Ii«i iiliwiiilng »lic f'P'A. §jti¦-¦¦: • ¦
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tofiities, TIm FhMMTcMM lliai its Defealatfts «c proceeding in wolaiiai of MEM 41IJSC
S«s, . r in1" •: , . , , nft-m- •¦•i n i ¦ -i > •
\ I.-' ¦ • „• , n ' •- ¦ • f 1 '.CC"*) Closure t%«. ' ¦ -(**! add submitted its
ffijiiirrf rty Ml.l'A »ni iSjiisiEciwtottili^t te*iiiwstiliilK
fMenist il# COHPEM wtem lit&tim fc? iiie Nisiteftti AM" warn litis
involved • ftmtokl f«Ww« of NC PA the "rwwwMww" aiiiiliioJ apply
te liiis tf««y 4mmm. Km Makmltt Kohah iMmm Inc. v. COM *%*r Stypiy, Wi f ,4,1 #SS
ft* c:»r. 2IM2J; ftmkamt Kmiinmrnmiml Crimtr v. CfflclitMis, 1:3* I'M 667 if* Or, l«lfj
(wlifcli held that ike "reiifoisbltoiess" «nM Jtould •##% wfcete the agency Asiikii involved
: rf «»„% tiW»lwifctilyj.; «« Kem •>. f iXlft M. ,1*4 P 14 i OS?, i IITII f«l«» t'sr
Kl«ik« «<«.!%*.! IM rniftUmrhiKdAaatlatkmr. ISIM, If J P3.1 JSCS, t JIM f;9>» €5f
mils ii»i«wofif«uij' aaiism iawtMitjj, MB1 A; lint
iiAilrsiy and eipiei«i» slifidsiiJ iic pxtaniiuuiUy itciaiii et tccbiucal Jiipates mi Bit
fef pfiistttfity feifrf
It Lite It Jwi§4k„ iiiml • €mmy pmm ititm *f lnw
201! pMM »I*»* Ka h bourne (the Kusteki KA1 *'» not k be dwe
uii- I .; ; , I M ¦. • > 1 . , " .1 ¦ 1 • . . u;
in HIS J4.I compels Defendant* I® «fc» Mkemim::..IM, MTD McbioiiikIiiib Puge C
fltiFtfilTauuiM SFf* »|,i,iitisi 1h,»* awthisoiss- II11; AOC' (Itef <•'* A fttmgnj* U}
ititlf shilis ilisl, ~jc|oi«»pIii«((si! wilh lh»s ("ttiBeai (Met si*# not I® «tisii,e'rifiis Cmmly'i
p«rfcn«st »fei m and fatal# IIA/BS »*
ll» in tfcf, E-*. II. isikf I# »*i me4
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Thus. Defendant taw a muplaccd reliance on tkc AOC liiiidins.atcited in Ik Motion
1 s^«s* —^$.J! «'jjxUvS v!»W ss"» Ol
Treatment Unit AdiBiftiswitwe Qrtteron Ciiwaa* %'oil Plan*.™- .« i >.•"¦¦> . « »«¦
procedural environmental review provision* «t MRP* wrf WBf'A m tiekmimm hmte published
¦ i • ... A Piliiili Draft! . i > u . m t •£*") in Tht Bmirmmimat
*»w rtBT) 'September», 2»W, and »litlc in IWeiKfeiiS* MTD lhal they "iiiti? intend l«i
. . .». . .. . »**«'"'-!(* in » • » *!,«.,£* »»• .,1 ^..-.r......a "v ai.***, .it tkn f »v.t«Mi»,4
I: .:":IIV - VI « j 11 ¦ ¦ ' * .Villi. I ¦* ¦ * » H " !' I!- '¦ ¦¦ >"•¦¦«¦¦ --fit >.«..* 1 >li.f..i:.vt » IttltLU,.
lo alt Stale and CoBftly CfflfDEM is ia Ciftfew HHP A sM4nI®
S«,"l
•it silklletl; (I i U»ti prop©mi activity i.» .in **!»«>" wfct HK3 343-t (.21118|, I Jj the action
~»« » •*« «»" n«"f emgmm of Und itmi m »lf»*tts»at«e mis mwxmmi in
i» 1 ills .14J-St»| f»Ifjarf 0) the «lk» »1*1 tfe-J-rf pitrHjiiim to IBIS MMtiip)
" [plftlffj, SiiSktwClalitv 11$
Iff, J«, 16? P.Jd 212, 2® mm IS?W in Umtorgerttat. v »£#«, SCWC 1
(J6017), m CAAP-IJ-0O2I21 IIS i».« M
t .» j| "ffce mmmmmAff meml3te vafi*1' S4:ti'¥!:: 1 -¦' • v-';1,IH:Si " ef * "wibIwiit limtiiiBii unir J .iitfj#inin|
fc NmMw %*iih nil eiwtrutJiiwiiiil revirw p«*ilai«s.. (.%« CamjJaittf
diimiimrn /»illislRHifm ll»e jif(;.|iacs! thai it can anrv* ftimtitdif
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m m impoitii* t omribution»llie *ti»wn miking procc** turf will imps.
1st *1 to wUoMliK tit piti# faMituitiifcet# toot
CommMrc »¦ .ill Stmt, 14.) F.tcl ?M, 1!8 (0* Cil, I913} 40
u-RI »2,s |lit?!!, it farther fitted iirn Cedent »§«(»« ate required to
"integratetbtMEfPA pfoefcs&w» « * -r s -d ifi* nay
allowed; -'After nwjijf owciliwtil of
Mb time mi maaef. it is likely tliat mum environment*! hum w.iif lie
ls>Jeriiiem
m-n If Ciir. 1 c>l«l»{cilalmii omitted).
Set ,*>» Sterm Cii* v. I'mmm, II ? F 3d i4W, 1414 (D.C.Cir, 19SJ)
i'- • i 'i i . i , ,
environmental mkhMcs and wtera m»y I* gmm t/prnffim
t:oiBkfc.f*i.oo ill ilistash.tiM«i.kiitf,....,"* Ttwsfiifs, Hie qppraptiMe iibie for
preparing m EIS is prior lit a fciwoti,. mhett the l"o|H!4ti!.s."J CMma fer 0g:f*rMfeitM tftim Nmlk
Xokulu CmMlim t! a£ r. COH,9i 112®,
s t ,i.f, i M !
1 lint IMcalail, Colli*;!! Oiictlw William Kuehmfci,on
I'Vsill" EA « Et!i«» it* MiifcMi® iwxmm he etuwa-tetiiteon fcl« prefiH-risit «i«.
.Kiifclor KiittilSarsln prefer . , • I i » . . * t i , . . ' . !• • »>. , I
turn "j**f Imttoxa tkmimh'iijmtijkfiltim m m towjMwjprw thm »*e. Ms
j!..»K.y.; .....
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«iuh wttiii i»«wcif# vwtote MEPA iwiiies. "To lie «xi«w ih«i tie lW«ti (PI
#W future, il lf|lfe*BlS • €•»¦*'»'*i* Ikm |>l«nli)Is< maili, 1»1. rusm:. inivr ¦ t:!..ii
iliitlfefige.. Th»« p»liir.to mm * • « WW," |«nt|»tasis mliteiti tfdoho Cmmm-mlitm itrngm r
J.U«tai KlllC»*C5r Aamrnum v Sirr«
Cfafc, 52? 1 ?,§.. m |1 «*) lie SttfifenK ftsiin nmed: "llenee i». penm wi* MMding who it
ifijutwt by • fcifctie to eem& »i* im NEM fmmim «m Mm the limx
I Hie fti litre lite #•«. tor ifte on new m rtpif ."1
1 Faftiti* NmMm IMfm ftitfBM: tfammm MHmmKatHm mtjm&mltm
% fmm to mm (Wtfiiiiarbii. rflkt requisite
f tllXlilllfStS. ill® ^gC'KlCV lliil :fftikS!ittXW!§ Itl'sJ
tteeiik* which hi* leti iirf am Mieifily Win iiiiute wiilwu nay wBikfernwu
efkm,Isl v • m . . , • ,• ' i 1 > mkm
litws we -ptmmkimi" by €C»M,I'*,fct llinsliif KncliJifskl»clrteirith* ttoi Mi HA
eififK* «#II he Started ft* A* |ite-tle»e«i»li*ti wmmvmiif mmmm pf£#s«s umit iteCiaiaif
lias 4mm :*«e-s|>seiiic etwirafimeatt!. it«fie«, wfeiefi i» after llie I'iisl iMmmMmi.
mwil. IHreetor fc.w*fBll saitl: ";to m M pm mme »/' »«* m pr&mit «krmmthm, mml that
alfermtm* B wfmi imrifmMMiMi iituim ami im/mtiit iw emtt/mti mmind
haift i>u in to ha* you gM to tkut prtfenat tik. Ami that is
itrn/iii-m-at.." Biirsctiif KwdmU hMcmM w Uk County of H#»ibi liiwiRsiiiicnIii
MawigBwrm Cmmmm* n«« «»»»| ®f lui»; tf, 1M i (»|i|>ro»t.sl'm pmM kij 2A
#l*|. I'siiff 26
Hw ttefefctmu si»|tiitsi that .iit|iiilkaiiaii of the Baiitfltr* pMedtral eltallteisge m (tils
..,.! , ¦ ¦ .1 <¦ , , ' ' ; I I lv I , . 1 - i. i' ¦ t
MiiiiitifT Ins entluris im*nl I«3»A vkmm ami mOm
llllf i,innecrssir¥. f""|ffefosfi.isM| atl|i«Mcal.-kwi uf |il«| efailwi.gE al ife
(wiot bt Ifaftisfief bcowic taoc ptpo-sjsectllt caiisiilsniaiif fttight «*snl! in iiwigitiae m
eliiiiiaatiMirfiii}' ptiieBtisl liifin to (FWntUQ. ifctts Kinferitif *tl|aii«ilfijii HBiii;xi3*iy. *%¦
knww, it* il'laimiiFsI bwuil; »s fipe |)railptdii:*!*.*!."*I.
MuMnW L*« ft*" »¦ US fmrml ?» f. M MJIS19* C«. 3115)>
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A jmwiA.Mil. tisprte, m-ti«tl* w* in tpiwiwti, is -* .he lirtw il« |jt»acatetlf
»t . ¦ ¦ * - ¦. < i. i - -if • . i ...
Msim-iatkav Skrrm ('Ink el tif.. SB U 8. JJiS, ?H (l«l; si-etth
• il I I lih'W "i lift' ! ' .1 , il I II . I. I
f •iiimmfm ikuw fomttfr v. ISM, 311 ¥M »1. f771# Clr, 2tt»> nfilial ill Cmimmmd
fjnitmmiMial law Vtnttr v. US t-oral Srrricf, ?8f F.l«l »TS Ci r. 201S). "Tits ifcsft*
iKWls m addition#! fcickMl 4$*dapm*t* Ixwise •« f»r.*«Am»i injufy !«i Ulrwrfy
V
c, i .,im, i, Min ,i i.im urn i*
pwperty »tieg*J eaitsiuli*! and damage* and Ptabiiffsetls
f u pwisa. Rsliiti ffs Immi at law. especially its imeiwiis tJiai
*m 001 IDEM eeinpfj- wM» the HEM Kgalilei}' iSfBtreiwiiB, tfiwiaj Krwsci Sttlute 34J r*
>feM pttwitfe public te*«S»g to mm te ««<,*
*iiy pMx kirn! into any envi«i*MK«tal tm , MitiiiiSff mtbi«
dedanioty judgment, iBiiiiiieliir* Billet line »wiikI «f still rfiwit, all «1li«r sMirll relief »* tliii
Coun deems jtiii m pop#.
jt ** f $(&&(:{ ffy "* ffV rfV jft-c /{H fiiTf* ftt**?'i***?* f' t **
1 tixtrr llniftiBB luterfimii..,:.;:) rv^fi.-rs A.,'t tiK.'v WF «>f .irf. at May «, 3®tl, Pltfaiii#
i .... • , MM \. Mairi ®l" tfce Mmldw llftft litsii'irt . ..... , .
* th+ € Ollrw .(.waifs! J n :rt» wlurt* ..Mt,u,i:W
iftfMOf (lis iw-wmvI »»e*rd*t t»w t«s«d« mwii for tiw
tunny 'Wfi.iJ.tM ifcsyHs Vt iiif PlsittilT* rcqucnoi
ie»i bcoamctitey mmtmmfM mvim MRS «F.«{3S tiean* ifete
, •! > .n i . . . w i 1 ,i. t , . , *i i.i . bunder
ossiititMNji! in,' iiHon: jiecjuisifloft." SltMSi ilw; COliOfM hut belatedly Miitewfalfetl
|w Ucf. li* II) lliiil tliif)!'e«ld i»l '"»«|i«w"Uici > " » ' ¦' p. " •" -
safes fceiore ii» i(s hc^cMM*.. • l'' i tl mi. wtsjm to the "!«*J
ii£<|iililiioa"* flP-1? Bttif-iiiil
mmew nasals ilsii must be «Kfe liiiiBfiaresfff •viiiliiMe so isilik citeai, taUki
fc n»l«i»l I'luiBlilt CSi* HRS WW Im) PtfUk mts! mftor AH nmnih
-mid «4tei dciC'iiftWfils tf»» etMfFtef slail te niiJe
Jlimlhlit Sw insfXdkii by ihe ptiklicittriilg tiililliikliAil ffiffk* l«irt.J
n®t»jiiir»ii«»ei m count i fiiti m mtmrn m- wmxMm *»« °n»h«i» wm~ m«i
-------
record* as (he Defondama plead tfcsj ut "Immune Fwwii. Liability Rut Kciti-Clhclcwui's Of He
Of The Mpsfahu KA. hiraiitfiil t# UKS Sot, «'3f • 16," ijilst Mil) Pigs S, SikIksb li A,}.
Piiitrilift is —(tidfoSiiif €ttlgit,Wtt6Sl tMP'% I S| *1lkkl twm si* tfttr JlitW 5
wpwm (owmmero mmte
w
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I m ,v,v,.f „t i .V v<>. « ,« t,,,« 4
S targe cafiteity ce«(Mols4* Ttiii Naalthu *in> fiikllit 1 -CCs, Imrkg ge««||niflifcst1> locaial 11
nilti ipin wSix mimtt, spriel* populated (Mini «f Km.««»»<»¦«>- «*«{««$m§k
ptajmi willi »»M haviug tit sale n^Mliiily is mitpfy will MEWt •Mills* and HAR
- 'Mil^
,%ft« Bijiililt ftlrf. ia IS
; 2011* en Mm 30.201 lie
l>kirki Cmm, Dfeirto «f Hawaii fillDI Campt&m ott May
itmifMMFAtrnmlm
«PIMMiflThv *th& MW
i cMt.gM:i«s, "only m titi 4t MsiritcMoii-'Wastewiiir ImtimM
| ipf«¥sf falsi# Ccifsmwtily Luife Capwaly Cessjwofs Itcfli
1 flaittitfT ccwficr , t I , i j ' \,,i
inlnBiifaiiiilw agency, p«>£olnral .Bififiai* thai rauit ptihie acccu us ike ctfcliliiiiiiatif
AaiiMle «isroiiil>' enforcrf," i¥mmn «Iit Cite * im.M3 f 24 m, IIJI*"
By fintiBf !• life *e Miialehn OKA «Mi if* CHh* of Eiifni*.ii«i»I Qwl.tj
Cciwti'ol ptiKuttt! to HA R f !'-»»• i I. J, "tltwe was w» t!«(# ft©i» which to mmmim tfc» »hiit>
day Siifilailsa pmsattwi by See. JllWlb'liiinl llWiitt mapplkabk,.," Iktle ikm>
leans r. C'tfuaiff tsf flwtofttftt 125 it, l», SI t'M «J (JMCH,, V|»l,««|t*#|MRS
MS rc^mncMf to We ®*>« offc WhWw •*-»* *¦ *m clej»rw«i due Pltintiff «ni
®onl*i» of the ftiw» i i t ..i i !*v«w afftit
i • 1 ,i ¦ i \ 11 >- 1 - , i, ) i ,¦ •
OOHDfcM eBwroiimeniiile^il smftctiiiffFi^riiillBKl in c't, ^ r.«»»,!.i=««, «.>"¦ '.t,-. i.
fHsiroiiwiitiiisI: Si»e A«M8M(Mr (ESAi M Rigiuwirii R«(*w ami meiMpieie
Pliiii* I: ESA Sm Mmktm IXC closure p*f££i - mid iwifolng itaiie# ibi IM3I to
-------
111. C0WCLV5I0M
fot ll« raww Ml iitaw, this Cmmt sfmikf deny ti* fetmtons' maOm tm
dismissal. Hiwitttjt fititat their ctuiy w fellow HEI'A DM pwvtfRjt BW»»«»itet5(i§
review fctt Mmw yearn, bow line Defendwu lave tlweitetiitsi fc Miialifcii. community wirfc s
iIk proiwfly,
Eticy M', . > . I . i II. ,11-
SifM review procciii, COilDHM MM mflfpMUMqr ftwtit cwwtwnSy &P» ** ;
gntdMKC. siiiJii.; T! i»: uKKwpiMe jxvpmtthat pbc«d u fai-sked, mmi'bmiM municipal ;
i
j .iKiiifiilaiy jiew»||,e immib . m . i ¦ ¦ , •• • . ,• i ¦ •:! hHMauqr •
I I
j iietoel, an Micsainhiisl wtwn Ital ( • » , • •• ' > |, t I i •
fegim liirnl mnSmmt&9m i« *W»#«w «f ttmr »»** C
-------
I HBMilW Ct-ltTifY tUAf, wi (hit tl* rant by tin msHwl of mtops noted hbw.a tone ami
oiifTect t*)' o# Iks PltiitllTi O^mitiisti» IMeiiiiniJi1 Motion I® Dtatta wett mmi m the
Served vi» j»stt».g# U.S. M»«.
Don Iltcl, F.I'..
Division, chief. HMMtt WvWcw
CiMtstj1 irf Hawaii i.Jtpi?tiit€.tst tit Bswiwtfiicfital .iliiiBficfwut
I OS IlillisiJ a venue
MlbJW§*»
Fax: mi-mm
wifiani A Kaihwiiii
Oilmen*. t;«in«y ot Ham-iut . «, 1 Ivliiiiifeiiieist.
.MS Kel*»«i*i« Sltm-t, Stile 41
Hie, Hawaii WfM
fitcifl IN
1101 Aiipaii Stieel Hull 125
SiiMfr® tee Detaonieifc
po ilex Si#
.929-9244
Email;
IN fill. lIMTEti STATES B1ST8JCT COURT
POU. fill; III STRICT OF HAWAII
cast mo, cv is-aam jms-ksc
SASIill.* LEE ©BfORIJlUJl, J*w St I f fcAIWTIIT'S
MUAINTIW 1 MEMORANOUMOF
POINTS OF LAW AMI*
AUTiKMiimEs w opposition
ANDREW WHKFt.FR. el i»1 J TCI 0«rf;WOAWTS' MOtlON
TO DISMISS; CERTIFICATE IIP
IW6MWN1S ) Siltm*
'ftme: I*;## mm.
Ii«4c.\ Mm. J. iWitJaifl Stiiibflffit
PLAINTIFF'«S MEMORANDUM OF PIIWT5 OF LAW AMD AUTHORITIES IN
1. INTRODUCTION
' * ¦"> •»»•••""» ¦>¦><¦'
I*t • • V . > .1 • . . 1 it Ifie two- County of Bi.- > .• | t-
of EMewwnMd Mhmrmmm {""iTiHriFM"') XVn mumm* ttmiwtm ptiitiit fWWWJ
«v<%vi ttaft l*ta« **|WKie«ltn| In wettaiiwi of National Policy ,4a f*MEPA"'f
41IJSC S««, 4121 m .«•# Iwmw in &H«ng to falls** suautmy aissJ fs§iiliiioi>>' pec*tac fcr
A md Hawaii tftwiiuaoiisiitol tmim OOam
-------
f Bawiiii R«*4 Statute* fMIS'I»tt«j. !%blitT«i®!J««ig» the decision }>>•
K*te Rm>, il* Eft* ietpwirfble ftfllcial mkt «» CFR&20(1, imsmWmg ft* mi$ the ftihala
tatfe ttgnrity €*«!*»] ("ICC") CIosb* PKgect. Del". Ex. 1 \ anil Ik. #, »wIJ tie (s
fiEPA environmental review ptwltinfs nail -Witer «nvbmmanlttl amt-amm {«e 40 €f R
et setj.p aju'tlkmhie to (hi* project" Itx.S p«aM hgmmm PI.J.
Aciwdlnf »»ifce Dcftmbws' ilxliiliii 5, wfiidi fe m miisbmmsml hy my sllclivlt
[FRCPI.bI« 12(tf)PresentingMitlim.ilirI'taw • . . •" 1 • I r ,
t>kusf|i- .if I It wail Glial Apeewca XP-9f,«24#l dual Sepwihct 20. 200$, S«itea M
KtjiiKes tlisit, ever iiiiee 2®#5» Ok EC* mm Rwtipif with (WA "««l «hw environmental
I, " . ,!*KaH' v i1".,. , v.. IN !,.• ,
5 > \> i-i-i'i :• • .• " H' ¦ ' <• u • i' " , l.\ i . i i
- . - ... i, i'» ,. ¦ - ¦* i1 f .¦ ;¦ it ii' m u - ¦ ¦¦¦¦ «i ** e .. .ii . ;¦ .... *
I. s«w ifK r».iiyuM ami r«§»» k, jusui t i sy& ecw.1 prsi|i#34.« H-iwtmi-ta »
i Iiw»ii rnmrn mmrn CttEFA"!. UliS Mi m «».
IVfendttit. Ka.lt Km, BWt's ll,t«s^.nonMe Clilaul, he failed Iter to provide swiwawttl
»lew i<4f CF R 6.200) ef ibe ctumibli vc elfoss* of two new-twilil mtmictpaJ secondary
I wj«lCTs«f» imwimwmt nljuiis ulitfwwil ter^fvits? tsfKfcr t"I0 Itwtwiwiifk sfl cm-fi *«ife {-30 CFR
I *» We..*"*?* ™ 6. VJ'V ik^ n t- * *v mi%«r V Its#*? V^l -Ml V %
:
I SO*.3S (21, pajeets wfcfc1» imher itJt%« ili,e |e®fiiphfe ami «mmm limtaf, ikai re^uiie EPA
"Id tieU fl«n in a i.iiu$.fc mtfuKt mtleimmf" •! CFft I $08.25 i 3:)
'ill# fIillegt* I||»I II* Itei*lsiw» foiled t® «nnplj wuh the
• j*txe#ii»al mtfMtmrnmsijfm cm I'm 25 - fl«l,i€ Pa* rtCfPATIor* IN
' PftOCRAMS lIMftER fltE tl-SOUMCE CONSERVATItW AND
. llfirOVERV ACT. THE SAFE DITMKIMG WATER ACT, AND 11 IF. n.EAN
' WATER. ACT ft* public pftiei|»iiijii in mSivWo under ibe Clara Winei Art
(Pufc.I,...»S-2J7;>. I >'¦!' • t II ¦ '
: Alfcfsbiiis ^igfittsinied lite rigls! C.'sfl- of&mih
' V Stum\ 34 PSaff^ld 1106 {CJMLXL 1WX "'Wis# isteamw judfimais
•is BHiiMrilc# l® Iks Wiy Inwd diwrefton ®r«t wMmmt&m sgwicf.
. J|.' ¦" 1. ii ||," I# f|W f "fe
^ wifomrfy tifcel - «W,«3 P.J«W,«3 {«¦•
! CifJtlfj.
[ Ptttdwf, liielitft iib E'lS, ihete is»»tans'* fer »H ilm pm mi
I ciiiitwl €C)HJ>EM Jltnlie.il - mti «»§t»i|, rtatio wftlnsol «n B8 » -piwkfe «
isonnil fciiiiM fin imtfi&gmkm. Strm Clmit v. iHIJ (\. ,8i«pp, I Jl$,.13.31
-------
It ARGUMENT
A. Iiffcufcin** fuMmv •»• CUi FRCP IABiflMtm
el to promt HaiiiiiTs
a.:,! \ ivralrnmy iwpafiHi*i»ts
toll,. :»>t tStt'Ujt
The Ha'niiiraiiks this rtlief by ftqutrtng KPA to comply with KlilW
rafBtinisfKa-iiLtt;
it, is, lend .in',' ( luciK'tMit I N< l» J:l|fc|(l|*F|l| jilu i,.,11
aijititiei irmmmtai torn C'tttrtr * U.S. Fsmst Strviet, Wt
*
A pKK5ti£l«l»l cltlfMtf, Sick SS ll» CMC »B qitecriott. 13 irljin! "lit ltl«» lilt* iffcll
|pmcedut»l| litthne iiii.es pliceWlsia ¦ party nillem a gffWisfeiBil nipt}', H
r the ctiftfti
newer fill fiptf." S# Oil# Forestry dModtiUimt »> Sierra Quit #i at, S11 U.S.
Wk 737(I998); tm«rfm> "The imminence ofptqeci-sjmlfie * ii
irrelcnnt lo fc npcncsi of itij istow ni»B»§. »jxvcnhmit snjmjv™' tWtomM
|tofcr.fW*F,<. mm,M FJi*l,OT|9*€»r.. WI3.S«ii,«W,ti
'CtmtmMmJgMHttmmtamf Itm- Ctmr v US. f'mmi ?l» r.1,1 IIIJ5 C®*
• Or. 201S). "fltto dispute Missis no adhttiioMl fetus! .fa«ts»p»iMi tecaone the
'pwreiwil ttpttj Isib tlieiiif ewmwT M
1» »W#fl##FW -Wf
' ' >. ' > .1 ," ' 1 I.'1 ' - '5 HW, "'I > 1 ' ' "f
<9*Cir. WISis :«ivj -,vt ff;«®|frizei iIbii careful will* lis
pnmw If Ifcrilaiale's tmimmmtui Mm
PnHeatmSnrirty it SMi/ififr. 5!i Flili M»» (#* f%. 1»1SJ {S#i» tt-ffip r
Sierra Ciitk 427 U.S. .I'M, 4094 ID11*761 ClteiMlfs rtte is » eiMi* ttBI litt
.»|sn»C}' tm taltai. * HbsI to*"" si etw«w#»«»sl tmttq ucaco.)
It it smamsl lisr m ilea ccRt'tiry to Iisi4 ti§#! sg^EicicJ torv^ lally
avoided NRPA proeMfuws for lhi.rt««. f*m% |Sep|iffnlM* 30, JOW to (wt-lstnk m
; il€ Cmm Ii«s!i5 lo look ls*k »¦•> lliiiiil'lgMMl WT! CakrrlOifft * CmirtSmtling
-------
fmMm - conducted liUy mi in good fci* -it is If*
wiwnsiliity tt'fe w«i» I® The Own aw) aivirocwneml
tat** imisit I* HMto
JWWW, i*.«rt wcty vrtwsre >m %mnmM ol*er«4imiiiiia«t»l
anil ma^mmimrnxBisi Acton i» spjswpiitle and wferte aJieratieiii iriiglit
Kifimeaial seats. ""MEI'A,
111',I i:.' ;!ll, f.-l.li, !¦>, f r:.
"|l«s«j» fctferal iiffiicjl « «>«* W# iwwuttwl Wi ctiiitiiwliwl h» lite
1 , J ' . . > ,, , mat, !' ',v , r i, i ¦ -eeef
V I1 '• I 1 , . ,! . ! ,i \,. I I n , 1 <«I 1', I H I » . .
t,ws(airr«a»!WBti»'nta> mrnmrn jwl«lltej* wander itfiiet nswtera. willwti
i," ill 11K
Tut eson mm determine wtiettar ** «a«il #!'««¦ mi
(feu w»t sBwisti »i»s m cfarly gl»w immfftim* weight to
"To ens*lie tart the i»fe«ii»g mmiysi »twrtctf out at*! given M effect.
Section l#2f2ME) r offieMiefaM agencies ptpwe
i •«Jee»ifeJ aotemeu* m of jm«kwfaif aetioiu on the
alteinilh't wlsielt might *>ltcf the e«t-t-iei*fii equation. Ttie
apparent pmrpum of the -detailed «wmm> t* to aid lu Aeagmete' meg'ME)|
minim alt «je»eii?s specifically lit *st«j| c«ifa?s ef action in any
iiropiinl wMcti iiwohss mmmimsi amllkm mmmmag aiiaiiaih-e m
(sfiWiittahie 1 his fet|niretniriiH» like 111# 'detailed MuhI'
-that tjpfsc-y itewswp Misted km fccifeff
Mm a«l ate isito pm$at Mwmt ill possible apgMMches let a psjftsMtr
ii'f '.i-IJiM iT iiV.
environmental impact and the ttnl'bcneflit balance. Only in thai fisliwi is
il Hkdy itai itie 1**1 iiileilii* optinult> leiie&itl ctaisit* will
&iBi|»iial* wilh (c> ite folfcsl esleal, iinkss Slitrc sis # clew «»nkt ef '
I.wlwfclosiripAc,
tmfomMe itlttfe. The iwwittii mmm mmm r w* •
nitaiiRtiw fciilfi on iii Bieiiis.-BiMferSitiwi Jtl, niifcsi il be s!»»m
tlii! ilte attorn tM that •« stftiel mm. Mkteaqr or
cfciily fuse iiiSBlllcienl 'Wifltl. hi einriRHiHicaial ¥iliies. But il" tic
. . ¦ ... .. ¦ i¦ \. ji' ¦ .. ¦ . i # ..., ¦ si¦ .n, .. .V o . . j > .. ¦ s. . . ..
tSIOFl WSl pRM.AJSOKMIJ WIlKMM I IWIVKJt83U/i.t! v OrX>. 1CH. I Jit
mill lisiSaxiBig nf mtaMMMl fiiauts - e»»iMucii,ul ilillj ami in gwnt &I*
• i« » ii* nirs|*m«i«liihfy nf tk tmm M tmwr
Tlie tarn m »krit«s il*e Cammhmm is M m iiankn* Iftiil its
HifA Rsps»i*il®« inaj* *b» t»Ti«! t«l in Mo mmin lint Ikiiibi
ptcisw" - wbsitei ii il simBfh iitai «in»lnx»int«i;iJ temi tvaitBliocis
.H/f'nK!':!"-.!!'',';
rccetw n@ OTwtefalkii't wlaitw? Irent 1tie Isrwirig feifl
We Wiew ttuM Ite tmmmmimi't smMwi uiterprrtirtw# vf «t» itmlo
ii rtifiefctij' flCtlit A«.
il'l^ ^tvt^ §0
tw fee to ipiore eilirirlf llie cciff«ls irf ll« ^iiEfiMtnl? mis nicmiil
'Itif- fecsfft " Ift Sss;1 wi ifiist! wn he
aaigiwisltmsi bmmtimmmitmmmmt liettmi,*«sapll«linif*
11S4 |'B.f".Cir. Itli'l
iwpiiiliwi wfclsiiUMll;,' 11} jjbw-i* *n««w!iii;e
oi%! fw nci it sJ rtfipiMi I iKni i. p" is.1 'he tfc. wl
llati infonrattan " !>•»# IMmimiv Morton. SVi PM Mkttt'i (0* f'if,
WM>.
-------
It is twipertgal ilial M •emulval. Ift |«®rtiaiiSar^ w^pmim k»?ep In «im4 fhst .iBcli
sfafepiwn^s arc i» ww ffc weins- o-f wscsssri,® Itic-1fwiwiwHefttftf ttiipict
. .. <¦* .X ¦ .. 'II' - - ... M . »¦ - - ' . *¦¦ ¦ ..* * -... 01 - .¦. !¦¦ - . .
« ppsspsica &fft,si:j( aiiseia^ ratfief tans ill a jiimsjilihot for iieciM.c»jii
already made. Tlii'S, mcmb Am ifai.ll stifeiiimfe cm itcifcws
MM I* prepared m*Stiiratlif «l fiat comment prior«»fc lint! ilgnil«aiil
prim afAximm in the agency review fifeects, Siitmng CttJifiwm'a v.
Skitk. m f,1,1 m if rif. i«sj).
Tie EPA 4'
s 'I ¦; • s 1 - , H » ! I' . 'I • \i 1 • i It " . ; 1 • I >'i. • 1 I
piisdi. f% teitisini lu iliiKifoiie ii$ Proposed A«i«m *,„.»« #1|
, J-V :'::.|.| nft- 1-,:', Emit!?:
public scrutiny. Such • result rewist* NB»A'» pnccdurcs if
aipmma * Mm?*, m P,M 753 C*i*€ir. I9fl% Tlisiefwt. wnlxnit iiifiiclen
. ¦ ;; ¦¦ . ¦ >. ... ¦, , ¦ . .. ....'¦ ¦ „ » «». ... ¦«, in.. »
MIIUrokHRWI W gJUWIIf {flQttlHil.1111 Sfte iVifdlt mi V* Uf K linWJCM!
FPA levJ#w (m AOC cwtflk»ec» flf« fCa^i tlw geswril
jwbBe cmH aw j*«lctp« ihrwafh imeNgcN «mhm hefmt ite km 2014
Hi* tuA ««f US if»fai»n»»«i»tn m !hr Atlwn niaifc all llir
.Miialftiu W«rl, Man sscrirwri? iiis'i t PA tmsifmnlm disroSswed all. tl*
iailicil. wwitiwls wilhmit msy oTte «iirc w»i»n»iBg» of
I etiwwsifWRlii ^wrm f!| I |lw |f8¥iiiRii ©I iltf ir f Isiiti is list ilicre1 wai iisiitleifffl
Snfiiriniiilkiiu!» si'liis|ial#lj participate in the mmmml (»ncws " liisfct «• n)
titmfHimm %•. US Faroe/ Service, 142 F. Sii|»|»„2J I,HI, 124® fO IJ.shij
II The MX Worts Pltit #Ki fcl'A pt», 1 .: is,1 ' 1.1 2111ft liilfd W
Bui MWsik • 1 1 '!1 • • ;• •' " '¦ if . . t j ,il
hy (Sr t'itlfUM? clifgTO? luifiiiiii rrsvmwimcTtfa! fif ifei? 'Blwg i.if Ibi*
I'- 1 \ "• > 1 ¦ 1 , „ n j WWII* iwljusmsijji ia t'U-.,. . i i : 5 , 5
; ificrltetl i* the AtM," Mmleliti WoA Hail iiml in toiipalKifj «oinptiaace
."liileslenss,"* fTtie see#
fe »I«|wl, !>)• !|»S ,JepW Unit iliie cposuieiils l*« \ir» (I* cwmmmenM eflwts vl
. ^ *,«.«,' m tm ! <«« ! fM.o« W7) «si «i«i to Smif itfCiiiifm'tm
EPA Iti W ® iwiuiw #11 fflewiiii COIWEfct WWTP frn|cei»
cB»i:it»iniien,iil eiwaiaeils, reiiiBioits, iniJ npna wximpwiy i,l* p»ptB«l
ftfftjftte thiisugli es:i«ilit.f fi#»A fmitmt pmwtesM-M as thm lie EPA uftleisils eiuW
am. ilit MtMMi in ifsikiiif, 'Memtma,,. 4# C'S'R 1 l#S, l|<), fSt* «*«» CFII
211 HbM.2) I.Al fBininwBi ill* »ssi*«i iifeisrs wmk pisiB stall inclode: j "A
! 'NMkt ctmmBiUtiii. iseiiili wte« Kiipwweiies* nmmarics will t*."}
Ily fiiiliiti to mm COiitHIM fcll©*
-------
By waiting thirteen ftmm to s*o» begin pcpttttioA of tnj- etmrnsmtml
OetteBM »*«<* sat made without ssissiiferistaR ofihe owtiBWiiiieaial eflfeeu.
EPA 1 hat wmmt tows sir
J prociiStii.sritl b|s SL.CJII If jfI Jrrrx !or III « >m. ... .............«. ..
am wen btcWMd ft* lie pnMtmantMd wmw ommmmi pnslaca mull
the Count)' hits dune sits-ipsifc envirarnnaMa] slotlits, which is irttsf its lk;l
Bilwiiiliatiwsi. Wini*!** fcus-liiwli stml, "k rn M fvin-mm
twlJt a prrfimd itlUmMive, emt thai prefimml sthfrmMte h wimf till sf tht
tmtrmmrnd tftnitei ttmf mfimts« mmmt arvtmd And you km m»
« Jjijiftatfcji it* is ff» m ill** pimfefmi mt Jlmi dm Is iht;
I .fWiM&'BB,. Li m. i'U^WW
I twimiiissM fflriifffiiiflf; fttirmtes &t lunt 21, 20'it lis July 5&„
ii /I.-.!ill „,:t(
C, I ,.I.»| «fcgi»fi«»
l..i .i:»;>:.ll-;il..it!: .V"!t';:"'ii< 1
Siifcitsi Ml "injury In fief ftiii i« (a) wmttie i«f j»r!i«tiiviu:! .ay mmatsi <«
imminent. mm conjectural or iin»fiiieiic«I; O) the injwy ii iSrirtjr traceable t® the
aclibwt .of' the tkfeiidwS; ii i* I iifccii^ m &ppm^4 lo» rmr^f
I s|M3t&%¥€8 ilial Sr %ill be tiy t vi
Jill* Earth v. ijiiiimt limrirmimtmd Stniem (TOO, if*", S2I U.S. Iff, SIM I
1 i The PtoiBtitr* tacliwtiofl sufficiently e*al»l!s»i«s *'• geographic nexus
f !;
Hliawseiiilus i#A >¦ . ,-.i !•-, . i. 1 ii i . . ifafaftM
irawtanewMd impart" Wetftm r«mlM Project v. .Kn.Bj«:«lifi'at.. <>12 F.Jd
¦i ;
, ! 47}., 4IB (f* I"it 3#l IJ Cwileiniil i|ii»ili!ls*ii matk* Mirtiffisi:!;; *o- mhm mUrnmwt
Int. P. *r».» mOil I2SI, f:2Si{9»€i(- 2010). In the pcMtil e*«, Ihe
r " t i , "i - '"i i ¦ »11 i -ri ¦ •> t i ti
; kamtimj "
iaMl thai ilfe&ie' ititefe&ts &1I widito the: of iaifffMS fey ite -aiilyfc M
aimr mm- c. JmO, 749 mi 7J% 713 .
fA pl,ni»*il¥lint *iue»ii feeler*! iiiftucy mm »Im> i|«.*»afiraic*al: (I) ftt
compUMM •*wlii»f|st to Mummf ailk*i," wliieli Is faint*! to Ir#e(»tle 'fciiui* m
dci"; Mi<2j it "miens! silw *fes«l mmm' at m mm Mllus wtiiio il* •b*
.orif«c»e*ti* iioBifct to be pmrnwi isy the mnmu mt which liw| eom|)l»m».»
based " "We taw e tic, m*fwiioBil» mHTKntifk
-------
tt
;.K l.Ki
S snlj wl'fci: * wjjietcte mfmj it «* Riftsl Service |i*J aptfertiifaiiii {"y'.
ii ill, tAMMAMSitm.
jf rtjc *ci liteis t -OBp^ "ftij tfcfftj t-fe^s' I ^ ^
dismissal. The MMmi haw riMwnatf 4m Mfiifefcti Bummtinfty wlii a fcaisfeiltMii ««ii|p
. r i I ' if ea taken action to • , i . I, . : ,
fcwety thif mmms mm mjfmjr to Ac PfanntJ tncl l»i iHM mnnmmmtf.
II* COHIlill tat« awnfittlii'iiait to cmnpteting ftt
aid ©f Decanter. ifiiliiig. il alififieil »i«|m»iMi of public psnleipulwi iftt In! more nwiiiwic cflfecw. mi critically tmnxdinc
impart, tltin gciciallj" cieeani (mm the inj«y of %iwliii.itig 'XlffA sluliilei.
To ilite very slij, i'i > . . i ¦;•> i. I » ' > i'iifcl n:» « i • ¦ .
itaiiilie.i %fftiie.li. re(|»i.lie mi BIS lie ifewfcij®il early instil iicmnapisy the COH.OEM. ami EPA
ffccBaon-iwiknig, lacking any environmental review pixem (XIHI)liMl tat no oppiarttiiiifj' for
IfltWWWtT KQpSft Il* TTTiwitltH; IR lllg lll-Si # 111!Is J
siwil, iwwly tatll siissiMiiifj«, s riglil teatle j
j m tkmemrn>• mlmA, m mmmrimi tmim il*i COHDEM lS«*#l mm weh m optMiwI
iteisk* tl*i Aey IiibI begun tamhmnwfam In vifltotienofiheJr«WB Comait refulaifcrns
; In»kan>-. the C«ub1j Jits m mi h««iei»« with «.te* «aenM tiii* fijr pitltlic
• i -i > . ' ' ' HflgwedtomJiawMlg. TVNtalehu ft'inl
I iBial Oilisacli. ift€ iiiii Comas'" »» to bavi **f iiitislirf* by ,
wiih i "r»*l Reiiasl iliifctdr 12/33 lo 'limm.
If tliif lifV\ i'Kil cis|s>sti€*l® ® Hisfitiff li|g| roi|»::"" 'ii"'" ii f " 'I'.'^ii iii» iwwirfi* Nill^,
| |>fe«i*«j»ir.ji! eiwirooiwntel review of Uw »•» ¥L*\t WWII1, lite SI* will to act
I-
I imelK«kecl with iks lTa.fwpaffe.fScy for ei?l;?.«ls. Tbe Crtiiel Is Jo gtlfRMf? tht-
-------
CV(8.00t72JMS-KSC
IHERBBY CtttlFV 11 «*rf: Mm.»I
I wiTlxl frf ^*.3a| I" " ' '
^ S FPA. Acfis|| AclteiiiLflFilos1
»« fcnnishgiB Atc, W, Wii»liin||.wi UC 2tJ4#fJ
fAMl«
»¦ SSL, Ssii fit oessctt CA W&5
« ||SCt«tp»4.M«
:¦¦ / 1 V .A
... ^ " " * * ^ ^
"Room fp-m, J00 Ala »»«Boukvari. Honolulu III »»$#
" I>A1I:I>: fMitlixt 2,2018 in NuMw, lltwiii;
::
''StiiKiii iff ftmwcllf
^ SANDRA LEE BEfclOlltfElAB, f'mSe
Samta Etenxwueifc
P.O. Bm m
Niiii!el*!11*??2-«l«
CASE SO. CVUMM7S JMS-KCS
IB THE UNITED STATES DISTRICT COURT
»» flit DISTRICT (it HAWAII
PLAINTIFF
Al JCIK STRAUSS, i® hti offktat fajiwly 1
r »1 the t'nuleii ;
Region 9, KATItLREN II. J
«I» tor officii) opacity IB OiKrtflMlf lis
United SIMM, Ell
SWPOWII JlMIPMP
COMPLAINT FOR
DECLARATORY AND
INJUNCTIVE RELIEF:
ATTACHMENT A{
CERTIFICATE OF
SERVICE
-n OSli >{I MH EM rntf'l \!M I'Olt 1>l'« t.%fi Uom \M» IN.il s» im
lil I li i
11 PJiiisliff SANDRA I, EE DKMORUELLE J*n< Sr., respectfully tiles litis »«bk ! v :i mce-ir.;;!
M • matter of righ» mtn F.R .C1* 1 %*) »'i«h» "31 Acp »fte« *u vk* of* tmxkm
-amiit Hols! 13(b)." Ob Sepumher 14, 201 . Rtan»», Ilia. Mo,
25, imtrulm ~mkfH»k KtW(«I a., "OkuNo. 2S-I P. 12, flmmim
.*\fTK RCKTu L CWipiiSSW IS IJ1I51,JJjr IHl-i.l OC-ICWT 1,.1^'lfWCT .3, I&..
-------
» Wdimiff brw«*i»iM ' WHEELER in his II. '¦ Jiv
um! in eoiMnlnmitfe MC «J.rl *
4J47; 40 CHt W01 15-iJ, 1504.1 50$, ISO# «wt t»J'J mi EPA neguSMww (40CFR .»««*.,
40 am Oil« «¦#.,' •» cri tm.«#,46 CTR 25 ami.
JJ fhAiim ictillentE* l|«e'ti!C|*H*« hy Rilii; fatj,, tl»f RJ»A Responsible IMliAil umlw 40
•|,rc";i Oasati! Prnfissf,
i)tf. Ii», 1 -A and lis, *, w#»M fee stitfsti to NEPA mmtmamml reviw pwwdwCT «mJ "other
cnvtnwmeml mma-mMem Isw 40 CP* h JII) el wf«j.) applies!*- to ihii prtfret * !** J
4) Awecclinp te llie IMfertifctils' Exhibit wbisti if not mubeiriKMcd t>> nay iiliaii»'H
ff'RCf* Ryle 12|»1): Pprlralifif f4stfcc5 ttetficfe' fSc Ptcijdiioii.sf, froipoEVxt to fcv the t#ii.|§iiwl tl'A*
Cwmy Section PI
fffiifceiil* ew ikiice 2005. iif EPA most aitipiif *4* Nil** "iiil oitief ciwiftmiiiiiiitl
«*t* I'mm'fm ihe "design «i«i tiMntrwikw of
waste*-*-!sj* » • ,¦ i • !> » i ' ••
51 As tmt* »f» the ®ri»w»l Gnwi Agreement fPef Ex. Sf, «tt« prefect
"kimtvts i&mmm of sewer lto»...»ioattliiilei* af eammmriiy sepit tank «ysi:e«* ami
eliwitistien of 5 tiffs Gitpsrily crsspiiolf " I lie taiifcfiij ana ftitato Llti being gragispMeal^
f t ^bliSTa^Si..® < «* i i*,,rv i, -v tt>*a « *i I * IS I,. -,4;^ i,1* ,^,,1 H, b I *< »•;.*. I J
IHlilUU 1 & 151 Jw "> i3| kH i IH it® 18, IKT1K »«f, . "V|ht* '•& r * ¦¦.¦¦..... ¦ - ¦ ' ¦¦ ¦¦ f» i*l I. 'Vh* 11 11 f"i tl W lif*
. ,.,.;.'il l| I -i,i ,|. ,i! , 'Alillis-tlllliltf
!S'| Aftwl1 1.1 ' 1 , . !' < 10!t, mi: May 30.7M$, Ctefetsfculsatttl
Cmimf of HmmB ntpunsai sf Rnvhomnwari Mhm§mmm C"f'Wiri5fciwl mmm4 fcw» mi
IXI'-We#!-?! lh« ottnrf liiiin w *c '"ite iliilling J «f
l*»jert f»wu Niiitebii» hlak" mill »1I®o«ib| the El'A ikailmg, will eonmicM
NHPA/ti1 .',i , • .. i • 1 1 ¦ 1 1 ' .'ii in. H ,• . > • it . . 1 1 M , . 1
' 1 , p > , . i, . i,ii»it*riip»e«ty Cesspool* K< 1 r ftojetl
'f uwwli«isny SI •' \ r l> •. r
7) I Be riiiiifititt MM till ¦« tl'A. iMsfiilinit lit (tmmiaig m. I'lftliittoo. i»f SE1*A #2
ll$C Sw, 4)21 ee;io*- mr mrnmmmmil impact sniiwnenl for If* »biS Piluila
1.C t t, 1 <0{*sXt |ji®$ p?il S3 *r*J KtI'A
eftvircwtiwisl turnex C'l'IEPAl,. MRS M> *t*tf. 0>el«rf»Bt, R«»„ H»A*s
fcjpsiif pftwkfc si!iVi»«fli»£i»!*l mnm (40 CfR 6.100) ofilM
oimalniiw etfeoi trnw pie»*-!*iil«l imiiiiieifal secoiicitry wumum imam pttHtt phmetf »
iimfcr J It kniKlwlis m «aeb »te ( ! " ,s 11 ,'( , v, s ' .• > . 4)
CFR IS0S.2S ii}.
-------
:») Tlic fiiiioti B" ml® *l|«|o lit* His 0tfcmkm WW » comply with it* pi«cvtorat
trnitMcmtm ®f40 Of ft Part 25 • PUBLIC PARTICIPATION IN PtfMAMS UNDi:R THE
KSCWtCi CCWSt-RVATICiS A*ff> »B»¥«¥ ACT, TUB SAFE OMMICJK; WATER
ACT. AND HIE CLEAN WA11* ACT for public participation intttfeiiiti under theCieiiit
ArUi;'l!> i. ^-V"\
f| This Cmnpfattm "Mis dec litsaowj- aunt iisjiiiieliws relief i«s|iitriaf SPA m eonijiij' with
10 1'* ! I'l'v.i-, i i«>r, -»*
iltsitis; eiififciifiiitf J»ob)f,le mitoi mtimtolofkd sliifcMw mmtrntkm ktkmM
p.*in ha
1®| PtAtNTCIIT SANDRA LI3? tiltfuslJiiiied States
of America, is and, * aH timet ttJevsail. wm areiitfe* of**.i 513 Kiisinslu Rent m
the District of Kau in lite ¦ elf seeking
rcmcdte* far ifce ftitim canned % the failure «» f*e%-itfc any wwrnniiwisi*!' nwt fmm S9#S «»ji
• . •!>,). I • I >• I1 • '»• r. .! »I.cc
Replacement Propel with an tiiniisijisfBl} Finding of His Significant Impact ("DF-ATONST") on
Septerebei li. mt m The IWmrnmemi Mmtct r«W"l rftlte Hawaii Cfc»f
Eli.-; IJiail,; V. IlillMli CtKCJC"),
111 To mmmtamt, her msSa% *w* upon her an§mg «m m Ptaiwnir * ttqm Rsr
"•fstrtfii .It •«.»-> Pndv" ,«i -wiij# '*
I' J,,'.. ' "-v. IV. V. ' .... |. :¦ "'»• « T . ¦¦ - 1 ««
wit c«ifii*pf »«~ in iilf«(ol |i> EWemfcnt*' ariionv
Dear Ms R*»
1 mm at homeowner and M ytat ituMnii afKaafcta In the ititiwie dinrtet
•:!K«U
Tfe Mastefeu f SdK'srf it tiiiciJ sti ibf pf
k Flaws!w I have tn »ai*e mtsmi m lie Hwlcliii Worli Mm msasbi
Ml !i*i% Section lOfr mmmiltmim, m m be* ,;!«* for li* Piliabi Wort P!m '
« ' 1 1 ¦ • «¦ • < ¦. • !
r (r»«
Th» EI*A s«*l CotiBif 1
- (i'ij.iwy vmmti testimony
m Ra.
Te ieiiMias# wt» aid |Mili« io my
M#y 9,»» M»A«W!40 lfllj.142; «,ONO ICOMA SEWAC* PROIBCT
111
«»22.2t?Wispelil Uiiifte!IleirinilRKMRDIMG BILi, ill:NAALEHU
AMD PAIMLA WASTEWATER SYSTEMS COilDIM CIP XHWO SilptJST
PRIORITIES #2 AND« TOTAtttNO $4WW**,
Jwie <», mt, mmsi Iiiijgis Hannil W4MWJWO MIX 1! 1: NAAtKJIU
AND PAIiAlA WASWWATCR SYSfflMS COIIDI-M C«> WW BUOGfcT
PtlORitlliS «: AND « TOTAIUNO $41.05 LOW.
I' ¦ ,Kr. >!l ! V < , t , , MMlfMiTT
RKQUISStr FOR AUDIT OF Cli»IRE PROJECT'S FROM NOVCMBRR
S,?(i!M?C>»»W6Sll,
r«* 5 ¦»« If
-------
k i" ' " ¦¦ - 'v, < g.
V ll
rwysM-
May », »l«1W«M CwwriiWn will. «,?>« of IS it* WwWh. WW
CW5IIF Pawling Iftwfi showing JU pains ¦skits il Prwuy 2) the OEM CJP
Jliitlfel ttajtifis* W» n» Ml#; J J ACM:, Nitikki Wi»* Main Attachment H, Mid
EPA Rcjkhkc W community comitietils;4) iJwmwiwfc v. EPA « at.. CV II-
h re ,i! " « .. •' • IV,,, ill article «€«*«)'
jTftwtnfc ijefn«lit»»'8!&m Sow® ®»f*% i,«MtetsJ*ji ef JAsiiMiftt jiwftierlj' siiita? t%»|,
1.1 ' «•••. .. .. • I., ... ' few. • I 1 . ,1
EA is jiiIS Step MS to te 4am AFtM the COHWM Sins teiiol on «!»•
[¦ i i i 'i 1HII1EM i . i " i • , 1 "i • « ;;¦ nefcl
r«iite$i«. fat lbs; two ICai'ii WlAx ffilts rnti ItSA Wiilite 1,
My 27, »lt RE; ITEM I>} DIRECTOR'S INFORMATIONAL UPDATE -
SijTia eftbi tmixamf mmltkii wmf ©»»%•!« cijuitiiMiam »Hlc«fW»f
the CCS1ID6M Extension OwnpluitKc R«p»«t letter Ami J am M, 201* to BfMi;
article about &"t<> Jtefai Hawaiian Oeii* turfs Tea l.¥ mi its Uwl manage*, Jot*
Cm
Inly 21. 2011 REr ITEM 4. A. Pfrliey mcmmmmMM ait efwtf«*®efiliii mmmm,
Tl»€«fare, 1 mm iaimiily KfBMtaR "ssnaailtii* pany* nam osrier
«i»A, rtfA»«miitil»
informed of all IIP* and COM historic property iienlttfeiiiiwi awl
of effect for li* Maaiirlitii Wo* lsh» project, and ft* Bm Kiiiiiiitag
enwtrraivrtM n*vifw iMkw*. KftSiJ ifeiifciCHIS fai iw. I. ....» ,. .• •. !'». .
¦W„ii «.
HI DEFCtDAKi AHMtEV VilBBjBI i» Acting MnWMM««* KPA. 11*
Asfininistntsf b charged wilh iinpfanemUBf aidoifarcing iheNKPA,
i)| OW1FNOANT *|.:("XfS STRAUSS fc Acitafc RsglftrMl MtirffuflfJiitif oflis# FPA Mttlkm
A AMnfewwer,tMeiirtxff*ll (Mo II. 1®% m
isike atilinw m da* the Ki'ii l,CC».
I S| DEHWOANT KATI? RAO is EPA ltep«i f UX Pn:}ixl Cwniisilor »ho liisfcriraiy
tw-v i1 it filiif I P A i!ix.ii.i!4W-l,viSM.kH 11® F.•. ¦. i .I ftiRifi- wi y ^ <
Sit I, Kale Rao iipfttwei Uis jw>nwni of il of COH mem Robin DaiMiaii's 12tlT,IWi
411,8, tl'A 1-iynsBl Hcquot rtf Nrate J». 2«».
16! Dtfesltnt t», in l»e» capnity ts EPA fiegkia ® l*ft C«pj»ctt$ Cefsfujol I'fojea
ii »ho HEI»A -f««jwotfMe Oflfei*r u»»fe* •« fft«»ICO t-i ««|, »!»» «
thereby rtfuiwi to perfonn to it*ii*te»j JbiIc* *» -mmm iliii ilie CtHOIM-iP A gnnt fundi
lie iitfi in e««pl»*e w* it* Witjontl B ;~W Itl'A") (42 USC
4»l 4M?;40CfR IS#J, im ISIM.ISOS. ISWIwtl ISIITJ¦*!EPA wgulmiows(40CFR JSet
«.,!. 4IHTE 6.100 , mCFR lS0I.J(Jj; 40CFii 15
iASis t'Oit JiiiisDttr'now and %,t;s«iK
17) Tfiri® WKtiiM mm* mnifcif (he tarn of llw llnffcil SI*# and involve* Itic Utitle-tl Slaisj « «
4efesliist TlKtitfeft, lliis Ceiifi te ovei' Ite ciiiiftt In lliia €mmpktmt>
pumiMt» 2S 0 S,C Set*. I ?J1 Jfeitwl «4 Hil (•««.-«
offlcw or Hfs-wj ten pwftmi •» Ib»|' «mi to ft* Wr»l«itii?I|,
" ' 'I( J ( -^»|| •£¦ _ 1 -A ,i.« i' , I In-,® Sl'a'v:! — ^ ."4 Ir ^ j> £ S J L,1'
I *-» ^ fliO- ® i^ I^ !*• BlU "X% * - y ^ c I \^5*. ( T ^ ^ ..
ftft 101
May 30.301S. BtkadmM md COHDEM «Mmd into At "AMiawiM AiMnd»m> fXI^
7 mm
-------
"%aly 4® the Treatment «arf D»ipc>*»t Syrtw#' til* in the *pptowhi
ftiM* targe fjift»£% fessphili Pt«[t« ».*k jstiiiiif rtee.lt av(.«iliof|
mm MEM/c-Kiaeiitiing fwoaedtiKS fist the Kiisfcliy Project mk) Musing the Plulniilf concrete
A puf*Mt suffering legal •«»% bccauae «f .iigetMf action. or ftdvetsefy tBeetal or
% iffiiey «ii«» wiiiiiii the mmtag of it itSc»»»i Saw*, »s »§
judlcbl tmiim* tbtreof. ^ >,,>11-. .• . >•• > ¦ .ief Oilier
limit I»»iaej damage* titici Ailing it thin Ihtl am agwy ¦* Ml olli-ce or irtm>!oy«
iwt'of n«e*l of 611W «? m 1b *» official «p*iiy or until* «i,lot irf"h*»l authority
stall mi 1* «mM »*» mikftmmm he tfcutel m illc pmrni that i( ».«gali« (lie
tiiitlrt $mm-m litu iIk Uurted $<»!« 11 »• iKisip«»We putty. Tit«¦ United State*
inif 'I* nmned 111 a defendant is my tsicli aeiiofi, tmd a judgment at decree may he
1 -,| I ,1 ¦ .III, ; • • „r, . Ml' ..I • . -I'll
"¦ ¦ ' -¦ ¦ ¦¦.. . ¦' ¦ ¦ ¦ U ¦¦ ¦. - ¦«.
stall specify the Paleal officer 0* wHfow 0? mm m by tUfe*. and their *»e«s*»rs in
fiffe, (KtMMily KSfsansIfclc fat mmpKumt,
JO) I'lainti trims suffered precedent inpitisi basal €t« a pftti&Jutsi ttflil lea where itie
tlecklBiniiiilug liiiltire 10 follow NEf A/I (EPA wis * fitilitkiiicflierpficEcliiiai irifhe. w-Jtr I IRS
.14J, 111 w pweis feenwf liiiefc ji«ittei|paliaB
as rfw "tufijirltls *H parties . > • ' • t - . '•» . I. «*«*' atsv, MRS
21 f fmximBf, the fc'I'A i» llts ~mmm mtttititiy" ftir the two tin LCC C'fcww Projects'
N.| {n-:.ivc,iMwsn»tlwfllA stirtetl m J»!t« 7.20IS: "Tills project trigger#Ik#
Mattoml KiititisBBieiiiil Mtey Ao (tlEPilji iinl mmmmm fafcai e»tMifiiiB|i iii*fci«fckf
iJKluiliug file Iliiiliifiimti: Species Aenf-SAj."
22) Till! rutin l«*|iB"fcafk»k«# in ibis dsini llwati* even si ptifttfrttifj' review of reinctfcl
avalbbie id itus PlajniitTflw "coRtiee iet|yiri. ',.1 11 ¦ ' v •,.> s ind lists
to repiii It* MEf A vlstata, "To Ac ma Am tfci JWoii ; the fi«l«re» it
•refiKfCiiSi 1 toficrrtr wpwr*' »cuf*f »i wqK pcwf-sl4- to i-hnif#-r»^c
Tint pow! k «r « m nmm," tliftste Onmm !.«»«i* *. *#•»~*»,
«S#> P-Jd ! $ftt M IS ti« I1#" c>r. 1 WJ*)K *«l IB Ohio #•»«»>• * Stilrra t *fci, S23
U'.S, ?2t» 11 #1) the SvifwiK C«»t "Ifciice »i**«i wftlt jawing.»,!«i# h%j«,re««,• mi* me (te fca«w
l®kc^ (^DCf, it "i . ' „« 'i • |: jf'
21) Fiat ita ferne# for niwiti!** p«ioii«l tii|«inei ir««i enwliowl cliilisi, •!«»§ witli
^vihrj 'if^n tnl K * 8 ifiikI He m ifc Sisilis fe. wlitrfi
n4ife"s?s 1'istefal i^sjutrv
Z4> West, the rcoifcitniiKe si ll»e Cvsatt si Mwwmt Department of la:i«»rt»in»cnli»f
tiBi tamd it R'pc fitat mmtmBmrnl iwtew h»» mt
"p««lBr».i;" mrtwfe K»«e»i#f Koctartkl m HAc««s te mmi
fee ita jmvttoiBiMff immewmet iw tpedfic
t'ii t„" iflfi the fact, iilitniiiIiaifioiL 'ii'mMis-mint,
PireCltW i%|IC.f®IR-k.i illill" ^ /if ii<4 I tunr it$t with upreff7r1km prowlimns, foltewiiij ti* NEPA sttlite EPA
•ckttowWgtt »i -ulliiiMlely llieit Kt|x»»l»i)jly- Vwm ?, 201» fe*« t© f* W$k l*it (be Coumy
-------
€»fci¥i0Kl4f the twi wi|yi:wtl
'i'l's fltmiil Herein *n»iWf«s »iiAwatiiii lifcrliiiewl iliat ji* jiacii
is directed attli» illejpt *#€>» «iill hiiv® Ac effect ofreducing PNMff* oagoiiiij
ir.iit ,
2*) " rnia2$US.€AimmW«l AsttlisitiiilmipsirHsffc
mm ®iiJ mmmkm giving use M lfca» etinw wswrwt n» thr Stole wf Hwww.
2§ j Wliea f»c«l w-iifc I PA enforced cfof wt of K#'w LCC* owned lif lfc« COM, is. complnacc
sritli HEP*,» Final Fjafcaairn'miil AmimmiMt Willi Finding at Ma. 5i|piSeJiBi Impact
f-fEAfffiiMSr) mm. published in ile Augutt 2.J, SWT Hi*- l-mimmmmni Mmim
JO) No mMke of-wltjiilrawil" of#* 50O7 LCC* CtsMrw fSAffWSI las teen ptiUtthedl
as. fey llittvuii siiimk sud fcgulntiiwki.
Jl I emmm an -'mmmiml fx* N««W>n
WiKltwiii* Tmmmmhm, Tmammmt and Dfepwal %««»" "wis imad in »1 ,¥"* iwl "iliiiw »
isiitiifccr (>{ coiKnii mmI urni 'tint CStt Cpytsty m>»kf ms4- espesid adslsAiuial tin**
t 'rt »o achieve s#Bii»iiii% Kccptaacc til" net -on I i" . > .i . |c
type of wiitcwfltiw IiviiIsfkhI ifespps-tl
IS) No IiJmIeIim Pfisjtitl "iiJiiienial DfiA" has evtsr hueti puhlklieil in TgM lut rif«|ai»eil tsy
WfifA Ifawmi Revised Siiluiei rHfW}34}<5{M(tXA)** • Wo
. t g « jfj ; v * ,1,1 ft .I.,.i 1 Sk *\^'W-V ^^ , i ' - . , f os, . . , VII 7 »fi ii y Hth \ ¦ ^ i
| I!. \IV 0 I i" * f H liTl'* h.. »I?T fy T i I, i * \ ' i -f i i,-.b - *.^^11
ii fMtnihn si EJ& siiiS ftilijwjlii.sfc- lis >
III H*C'0I!IJI ' Maya's Office Is > • I ¦ 1 i , > '« i
lclBf«K»l Nitafclm lilt* m tmm m riiiiilifr» t® the tati fniblie lihfariEi, mMh
eommuukliy »«•»»;««* smamttm mmm,
J4) The EPA Utpm t Esfofc«e*iit r>n.isioii Ins «l« been deteikl in ensuring «fc»f is*
- '¦ - ' t I, ,n. I ¦ p. Jl ¦ . , i .. . r ¦ i'
r Willi 40 era 1 SOIi.%) tsmiwinj the |*hie to (Sfeiwijif, aai
inipleiBfiilinii MEPA pHieetluies) sail 40 CFsS V^n :>* OHMmi Tmmp,slim m under...
tide Safe Driiiinip, Watrr Art ...4 »l«« the Hsileliiili'iilwlji 1 ,*rgt.f,»piaciiy resspMil f*l
>- p , ,, , ¦ i i i 1 , - i i ••• , i'. • , - i i
IS) MMmb* ftm-tiei ECA pmt. Isial»i»| few tf« Kii.ii 1.CC Cl«»ure in 301 i wjfksul ua
LtWiniHSiUCBlbii SiFipstl f~ fe-lS | iff th( Nf UNtjI
AaS«:Jt)S(l),42ilS,C;.Ste,41J2«lj.#f. wliktirfti >!,« j I i,,. , •• • , ¦
elite #ills P«sj««l l»sfcis any •(«*>• Mm i« made.
U'l Pfufctift*n*kt.ifcfltlirillijifv ii„i,Bi.;:iv: r..-! i,:-f fr, £soiled MafmiflPs 'kitrntnH •! law,
,»• " x som^rw»AeSP»A», t. 'm • • ¦. i . .
few piihlle pitl p i - if r'-'!,. .-mis. i-:.- vonmended imjacn <40 CFR 1JCH..7)
'L«.- U IV
-------
mil tlis iiiliirs h» psijiiks anmmmmmmrni, nwir« -i'lre-Rc;.': im-is i1 irEDEM t# gufcli
ttA yllRials iswfetot si|pisSic®i^-^B*"l'0(Wii *ith NEPA ami then %ima 40 C'if IS: i 5 to mfsmt pMm
3»> 1 i • .... ... i ;
tli&crclsiMi lw3M« Nl»;iP#Vfi i-Miulttiy l\|$ i:v ^
40) flasel ©si the EPA filters m mmim the msmud ageney's fubtit §wmmpmkm leading tit-
Mm » www* •¦»¥ pii'Be input into iwlopiieot of the Rail l,CC" Cleaite ftejosls, BaiiililT
attfcsa ffaliiiilcs J JuJpiMitii injunctive relief, the amanl trfwsts ofiiili, «»«J aikar sn«l» relief ax
41J Herein Hit Awi'taJ actual 4MkI »b(«*ii caused by the l)rfen«laeli" failure»»
•fonijslj!s j ukl EI»A to pKigmit- Mw
¦ " U ' VI
a,tlnifc t\» «•» I.* I SI "...mimm.
Iifftia? tlf IP \ M. »|,!*» "K«"a
Ktpfafeaiaii Plii'ijeef"itilligHiot ftuiiing |*XP-fiS*4I4tHI MgltsilmmiXP NMKM4) totafifif
11 .Wfclit) in EPA faiiilliis wilfc a 4S% ©OH iiittteliiuf fiitnting,
/HWr— i'1 1 •••!••• > «CWliteflic
hmm ®i MiJ.isJ «5 us iiiiil taattMHO.
taiiwan itxiisw in ^isiilcd
,;n ;!!¦>: f !'¦' :\ feputl 9 wi» WCTlrtjgisf c,»f fg€W¥l:f ^p-iryaoiftltll #$K!OT3t!3t
<>€ ¦&& Warb PlaBs &mdm il'l "1.^ ft i h k' 1 "¦ i h. .|.1J t i !£•? hJQl felifej
U r V>
-------
«;t Tine Responsible Oflleiiil Med to ifisiiMns fc scope of line iwiNMtRd revkw for
Uis Kmiletai and km taken »tcp» m • mn4 vqr NtWaowtwttmg w*ww by lite "ilull at
pr> >11 • .'-.1,1. , .1 ¦ ;, 1 •, u,
#i| Williol.sl wfucfc Iftdusiki kopftl'^WRliaillf'K
«§il«*f is amply <««%«« the LCCi » teptie »ys6ew» that ha* « Final iivliiinitieiiial
Aiiesiiwiit witlt« Finding of So Significant topic! thai w w 20f?» WA and
¦¦¦ / ! .11 L...1 ... . : <¦ !. : ; (. :k ¦" ¦, ( „ ...<
«k. 1,?CH.«!•?% I wWw? fM.I-f Utile *M JffsliM; mf< UfjijtrTO, !W/V->S>IaWv|" «liflHl.li PR C'lily |,4!3»
(Jaim I: The f!*i«i«ff prvmhmil injur* timmm-w Mw «w» COUKN W»»ltwittfr
I f ihi I.. ¦ vinrt« •<> it w<, tnil i>- M
review it.i»t«»te f IlBWi"), if IS M ft wf.
m PI*itstlf¥'l»e#iehy InoMpft ¦ , „ » ' i , . 1 i •
51) No mm #r-wlMrewjr of flue 2007 tCC Conwrswn f EA/fOMSl hut teen fwliisiwi
u fequrnd by
Ml Wtt Ballet of an KA t* 115 ft# the Nailtihii i,4T Cham Ptajert It* Im>»« publish&thit
TEN its fcf HEPA >mmms mi cei»iatk»,
- * - f * tnv}tn(uiB. nii ni. rw • $m. c*,*iTt|>».viK <.> iix ivsu 4..®...--*,.- ¦. iwifi i rojes. I silt >
Arwifli i;pa sbkI CfM! ikxMm*mmh:mg from J !».{¦ Mt4»./'../,*if l«» «"« • I <• 4»
Cf* l.*W.I|i),
Si) 4 I M . .1 : •! 1 ' (.!•!> , , lllll I '.'
I BilifiitieBtl decision fcj rnimmmi two riall-«« MtcMuiary iMstmmm; tmmm
m. and Patala was in iuwt coiiinsiiisiioii»lie weeweeted mrnm ®f sislien
Mcpn Ifcfsiigti B*r Aapisl J1. HXM *B»e deemed lirnelinal»Imlli
-------
(A) Adjudge mi dec tare ihu the EPA 4aMm *» wjeei ftfcwinii MP.PA pnxrfinwl
statute* li« enmwitaiealal review of the original Ijbi IL1.C Cloture Project mii the
cijfrgtii Nwstettu Pr>jk:| if sun sbi?^ ¦-''¦¦wwls?
(«tu mmtOmm; «i:Si law u»*tef APA mii NEPA ,
(B) J5nj»ft tte ftttetis] Defcndim* fttrn aiitkiriwiii «oj eletnetw of use IC#« C.CC
Project in Mdn er ftihufti pending iheir hi i compliance «i» NWA:
K i M. » :> It I. w , > .1! . - . . " I
Cfifioetrtfig,. feietf>gie i»#&r iitcfitedfegissJ siatiiet; ©r cefisliiistioa #eii%Bri.R$ Order Dcfcodorns w »k* ftminms to oillipits the adverse tttsm <:«f tie
OXftJEM"* Mm (mm »t» * meet the puttie piiiftfeifsiiiiai mf/ttemm In ii«is«*ii-
BaiTiigj l 1 . ' i ¦;! i' }« > avoid pn&licuipiu in the ftilure;
mm »<* »
|F> iitfcr siier mfametm »fc( to mmm that the Ifefcitdante comply "•Ah
fc-.f" A i%,I A ibihS p* v ^cnt ^s iS-tlc li,® tfpc I jm^j ttic
"'.i-s fi
(CI) Iciitin, jiitsliaisiii tsf Ike gats until (tefatdM* lia%« ftiifillcd ilrif legal in*! Court-
CM) A»wil(%iiitiI?ei«issiiiIi«»ifOii»tjteal*ifii • < c • ,
(in I Jntlet Ikdemi fcfleofCi'rtl Pmedhm I i, by fcktw, I e««I»V «t;> the he* of my
ii»wi«tgc infonn> (IJ i* i»t M| presented fat m imptip-r
jMTprew. SIR* Its to Itamm ran* mmtxeswmj M»%, or iw«!fc*sly incmue flw curat ~jriilipiliiju:
(2) i< supported by fiisling law or by nrw-frivoJci,-, i;>f extending or
reversing exisitog Iw; (J) (fat factual owiaaiens taw «¥l4ei«ii»f aifpcai and it* compiautt
tillnTWi* csiiipliEi with ll»e Kn)iiii'«nsnli olRule i I,
ill I ,igre« » provide the (W "s Dilce whh sny clwiijits io my address
Pl*« in? be «fnci: i undcrtuuMl tint s%" tillu® i§ let# • cwtmh »*tre« on lit *lifc tbc
AMI,. n«... . . ¦». I 1 . I,...p'l..
Owed- I*, 3MI m NmUm, Hawaii
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ATTACHMENT A
,\c> v,- i I I U, /> i > "'/ vi'' '. (ii V -.n'kV'i / /-^'N'wVfv V. A. i".'. ' * /. * .M
«' nr.,v.'r>> »S'»r Mi," ?< iv" »v '¦< ' '„v *' s^M'n, ^"vir w ^ >* t fhs t ^*/*».*<( «s a tew liftiS
coma »p* «r •« PiiMBiifi Second Aincatat Cmmpiam •»» *rot en ihc (oil mmg 11 ilietf
¦nr. .iirtii-vn'
fewWi 11 "t M.«l S
«,. .:»,V ..... .; |?
Andrew Wheeler, U.S. lil'A Aettng AMww
W'fl#re»»5f»v«AiA«.8\%'
U.S. EPA .Aeliflf. i.egi«i.f AdBiiBislrslor
75 HMMttw Su Stan fMEEiiCO CA 'MJttS
ICuhfeEH It Mmmm
Baeetof, f»fcf£Kl*Bl Division
U.S. EPA Region t
- , . > ¦ , ¦ • %94105
ivjs; M;«
LCC Proicci Coonfcmiw
Drinking W*w (.«•€» SWiun 4!
ii.s. imsfftaf
n Himlhotnt St.. Sua PoineiKoCA W05
Mitel" II Wood
Acting Ammmm Allow** General
Kmi IIIiiii
Tritl Attorney
fmrnimmmrni &xii«»t
Environment and Hsliiiit; KeMtircc* lliwsioti
U.S. IJepntsBEtt! of Justice
Mil HuwtwiSf.SlfcHiSI
San FnneiMO, CA94I0S
ifatifl M. fcit*
MM Sliitei Atiofiiey, iJiMiiet ©flliwwit
»,<, 1 | .1}
AsssIiiiH US, Altwncy
Italia 6.10ft, M Ate Miliaria Ilaaifmsnl
il.wihtluMI «|!ft
DATED. September 26,2#1I
.« . . ¦ . 'k .. 'i.. . t, .1 .,
)<• ' i
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fMjTICE Of" QTtittN SUIT liMJlX THE IKMJAMIMIt® SPttJICS MPT,
U imc, 1511 |i)CI*A| »imJ12MAI©
PERSON GIVING NOTICE.
Pfcwioi iiiBfsssti 94-1 SI5 Road. Naahhti HI M7TO
Majtiftg. address: PO Be* 581, Naakfaii Ml 96772.05**
Telephone: I -808-929.9244
Email:
NOTICE:
Location; Naaleira mini l»jiliatii„ llirtritl of Ka«, C*iinly of Hawaii, State of
Ilsiwiill, IJ.8.A,
D.»k- .if x-iMRKiwcmeat ofongoing ISA Sec. ? consultation violation:
title: September III, KMI5 per U.S. Knviranmentai Protection Agency Grant
County of i !»¦«», Assistance ID Number MMMif 4240141 for
pmjtti period OOOIfiOOS - 1M1/3007.
COM Pfojw Manager: Dora Beck
ERA, Project Officer: Limirt »<.%.• {l«in.iiMlilr C»lhnwl 4«< f t l< ft, }«»<»*<.»>
(&»'Exhibit 5,Case I;1 l-cv-00172-IMS-KS« u ; J d • <•»•!- I'-'Ik
r , iv 11.
Hi# nteipim {Cmtuy of Hawaii) ttgntm mm m leill is*
wqmml rwh*kw*mmit fam MM fur any amis
mmxiiimiwUi thedetlgH aramtracrton ofrfmpnt/eei
[KamCesspoc fi< '!• ' ' tMtmMuami
I'alMiki in Kaaf fttadmiby rhit grant... mmdtEPA km
• «I Itk t>H rnummfit Bmim-mmmi PelkpAct
iiwl n/ktr mrtrummmtol tntst-cm/ftm (mm 49 CP.It
&#•# #1 JWfl ft» fill projttf. fU, State* PL)
rtmimt
I. K;' i- : I1 1 I .'II-' 8 I I I 1 S i ,1', . i >!;••. i..„.l P i ,n - A,, . il.tn.
\, -o- "1 v "!> » . .. ll.-'A " , \" . J ,v !l> \ I", I V !' •<.<¦« I 1 us • [,,(
1 I", !u». I f •<; '),!!• VI 'l,
<, »>"•: i'i i iv, M.i'i.-",- n,, ,s h>-i
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i \ I • i.'i • ' I 1 'U''! "P" t\|s It. .11-. , I H > : ;| ,1 t
Til u
«t » < t,« .< in;; ilurin" pencil nl 11ran! i umliinwi l"l. Ii»»m djtc
M .nil H'>.'Jl!i Ihi iHiiih i, «r i till I »• ,t(H !\i i>nt mitiiiK Kiiitc (1? V>i 2ll !¦%
I I' \ IHS( Hi i HiWin \t I H t\ IN \ H >1 V I ltl\ I S \-
i . 1 PS ! \I| I I ; n I \M 1 S !> I "i • \ h' M I ! ¦« fk I M' t '¦! PhTH f | \
ss ki «.,ii ?ki ii :s> m p\ wm >, \*'i up; \ n \ i sn s n i> u u\;i"; ^
\v! I H j S \
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, I- ci >, ! . >u!!k''~ n Iikii'i.'it" | S \ So1..' . u .'i: \>
• \ I M>'. . '-.'A I I', n " , III" I r I '"nl ! , I'I ,1 ,> 'v. , I'll I li' p.i.l, 5', -|'!h
r, ¦ .in p ¦ \t i" S - .i'i i" I "i,\ t" > • ' u- r I ,1 11 . >' •>.' i. •, si.*
ii.i!I !' S V. U IP 'A.iii i 1! n-., .-.i'l\ h':,1.'.: *.s ! |.J, • i! :; I i I N \
>,¦, I'i 7 . PI. -¦ ' i I'i": j \ -'i'i " ' •" f'> ''r< \ J1 • «dl I \\ S. I'ti; i -;jt If i
"¦'.'.i.L-hu I \>\ \ >¦ II t,s 1 i I, '.i .... i,;, I •, !',r i.i s| i
.V, ,'A I ».I.i! ti\in:»;ii.!l:i.' 'iu- i P)¦. ;n,T't:v •• Pi!
.'i 'i. i, >t" ,'ni t ,'.i ,',-f i .',i i--_, ' ,51, ;i i !>.' i ¦" ,ti ,t. ,. \K' I",. I i'P ,'IPi'. i •' t
. 11 •" r' ,!¦ !'ii'd 'ii o r P i i \( i i . si' i I ,i._ - - t.'i: :ii' in
, i. ,i'> ii ¦ "I,,. •> ,,i • <:i '."l,i. '<•¦,, ii. i.m, -,i:i, .a i ii.ii .Mi' 1
1 ; I j .i: ,i , r v ¦ Is i; ,ii.i,"i. iJv.i • " ; i!., i P -1. .i i! i'».' ;• ,'l> k mj
i. lA'i1,, ¦¦ ^ "ii",si, ii ,P \t ill!' t ¦!. " ¦' ,1 s. m'. r,iu : 1 'tij,',.'.: I'v'it'.f.
. i,'., - h i' "i >iP ,• i;i" ' "i-• i" "i' 1 i i '!. |'ii" ,¦ I-,..I p'."ii, '|.
i ,\",.|.'i,', '.".i'-u . . ' i, i t ;¦ ". lit.- I" 'in: lit ,"i.i iMiui. i>, !» '! I P Pi',
l . , "i ,! ,imP',"i t " sh't s '!l''' I l , ¦>, ! ,r, : l'i ^ '. ".r.l SPI ; s P„- ¦ P^
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2') EPA HAS SEPARATED THE JC, I GRANT XP-
9694240lf As Amended 0 through 7| INTO TWO SEPARATE PROJECTS AMD
REFUSED TO FOLLOW NEPAi'ISA PROCEDURES THAT Ef A FOLLOWED
FORTHEPAHALAi^'". t u> \ \s|mk Ih; WWTP WORK
PLAN
Via NBPA environmental review lave i*«ii followed sine* Urn
original project- the LCC conversion I# xptfc ft*" all of the illegal Kau LCCs -
provided Notice of the FEA/FONSI in % i 1 • .<• T'! '* V. .i . ¦<«.•
2007 FEA/FONSI i* both the ftiwli nil Nontehu LCC clow
gi,r,- , p., Ha, V>• i, jui1-. shed loaccount in theobviouschange* tothe iiriglnsil
Kiln Cewpc»l Project
Further since this VmMm/f tltla 2®§? FEA/FONSI never ktri
Supplemented or Withdrawn ai N»M in HW, it « inappropriate lo piubltsli tine
TEN Pahala DBA/A FNSI Notice on Sepfe r« of the
NEPA/KEPA requisite procedural review.
"To mile an informed decision about itow or whether to proceed with the
propoMai pMijseis iiiil hi cumpty with MEMs,, an agency must identify ifewr
potential combined environmental impacts and ... .i..a «
(lie public " Kfomath'Siskivov v. Bureau of land Memtgtmmi, 317 f ,31 989 (t®
Or: ittCMj,
These I-i In > \ !•, i , ' I • • Ill*l M , i posed Niialcliu WWS EA
mi the pmpitmi Mails WWS ElSfllD ste legally twasM,. being tw>
separate itofiisi and documents prepared il ifiifewiii points in lime, fait to consider
mutative effects orthe connected actions of the proposed
wastewater sewage treatment projects on the human environment in tie isolated
and j||iiifstitj^ populitcd Uisii Set of K i y.
...ii
'connected actions" »mJ 'cumulative aciiws* -wiilin a single gj m ®y,» mrimto
Actum Network v. IM Arntv t. r>nw •«> '.v Vi>\\ iipteifiefiiiiigi'sgnliiiiiwiiiis
impa mi fieettvlroiimeBi wtiicb mmtni ftwi* il* ine'eueaiai impKi of i»e iictiim
wheal added to filter past, present, and tmmmMy f«ti«ta|»le ftmirt ....
ijurmuiitiw bib result flow inihrMMjr mhor Iji*i «tHeeim% stpiBcMl
actions taking place over n jksrisjil aflime," 40 CPR tSIJS.I,
fat \tmaetttoi* mi "cmimltili «f* iietiora, 1 it "sfcfwH"
latly* them in t single impel statement, which the •* Circuit imetpretcti i«s
manddtoty reqairemcirt. Sec Eagle Mamt fmtitote i-, ISfS.JSi FJd 1291 Cf*
Cir. 2003) w c.»l«t in KiWttaih-SkUymu v. Sttrmu Mafmgemmi, 317 ¥34
I) fcl'A HAS PUBLISHED NOTICE OF AVAILABILITY OF THE PAUALA
DEA PUBLIC COMMENT PERIOD WITHOUT CONSIDERING TOE
CUMUIjITIVE EFFECTS Of THE AOC TWIN WWTP WORK PLANS
WHICH SPECIFY BUILDING TWO SECONDARY SEWAGE TREATMENT
PLANTS IUST 11 MILES APART IN REMOTE, RURAL tCAO BEFORE
APRIL 17,2022
Bmpiw Kate Rao tpprowni EPA SAAP funding for the origins! Ka'u LCC
to LCSS eeiveriKiti pro|«is, «lic; foet penailiei the Ktaleiu Wort PIib lu be
implemented im of'WBPA^ mi AMI to etm« USA Section f camMm
FW8, as rite iliil fatalif, ilesifiwliiif ERCI itnto 1t«is MSA in tf* Jui* J,
2011 letter. By allowing mMmh of ciiiisMeralltw rfamUMC ini|«»c».!i. mitl
n « 1 . • ^ ! r \ . >-.11 <* \ •<» Us, la# hat lint i-efwratteis rf(toe Iw®
Ka'u new-build WWTPa will no ¦ffisfilifin of impactt on is# ntunerous affiscted
endangered plana mt wiHH fc and tppmmty i«»wn ,• NEPA
cmimlilive impicl mt)rsk. f*|T|lieilIslrii'l amtl pwjperly .lielcnnimi tliaf llic
foi'isi Stfvic* vi©te«• m.i .i "i.i. ¦ \ • i 1 is .
action ... «»U docutneni the cumulative wipicCs ofihat action and til previous
actions," i tic -iaiiih isclevei "lhal contaemlkin ofcumulati w iitwiaa ancr the
road has tlpeaiy been approved is insiillcfeat» fulfill the mandate of NEPA. A
cental purpose of the EIS k la force the coraidtTat wn o! rnvtranmental inipacti in
the deciakmmafcing poem. See, e.g., Columbia Bm§» Land Cmtmfim 4st "n v.
SfMstmggr, m F.2I SiS {f* Cir. if II); City afDuw w, Colmmn, 521 F.2d 4»lil
(9* Cir. I *75); imkwt v. Brbitgor. 506 VM tfljm (9» Cif. 1974) <«. Ikwej;
-------
CWwn 0# • CmtrttiiMMiag Commitm v. A/iC, 449 Mil f 1!», 11 H-I114
(D.C.Cir. i«l). That purpose requires thai the NEPA process he integrated with
agency planning "it the earliest possible time,* AO CJP.R. 1501.2, and the purpose
miiiiim be fully served ifc«isii«#tit»tt of the cumulative effects of successive.
1%. „ i ¦ i< ,, i ... jyesil until i' i* >. i- • .,!¦• » . I A... .
ftfwsm 153 R2d 744, till (V* Cif. «S5),
Because the EPA has taken specific slept to change the EPA-COH Grant
Assistance Amendments fir XP-WW2401. as demonstrated by the May 30.201*
amendment #"?, whichmull ineffectively ¦ . 'tin,, • . ¦, M 1 A « v\
procedures on I* Naalchu WWTP Project by simply moving the EPA statutory
obligation? 11 aiites away t v. -m IV. n i * v. I r i"i iject. I hereby giveNotice
of u pending citizen m.m tmcm- ine ISA,
Hereto 1 «bie« » fl» EPA failure to implement the ESA See. 7 consultation
ft* K#ateln» as Kate Rao dvd for Ptlali and rawest ilia t*fore tee 1$ tiy
decisions on either Project, •! «i I l'.\ i ' ?'! -¦ r. • .• n r .»v,> ~»
ISA Section 7 consultation #rvd issuance of a lioi«^pc*l Opinion coverir® Ihe
cumulative action* thisi will "jettpwittc llie conl'myeJ ciustumw" of multiple
Hawaiian Butmgimi creatures awl plants for both the iPsimto and the MaaJeltu
WW 11*' Projects.
I t'itM'Ure under penally of perjuty ll»a! line ftagoiitg is true and correct
Elated: September 24, 2© 11 it Na«l#liii» Hawaii
$/Sarufot Demoruetle
s \MHi \ Ii i ! I
PillfillW
SANDRA BfJMOItUBI.l.t:
P.O. am Si!
-mmm. mmm
Email: iKMltl>iitl»aiffi(glyah;B.tMifB
CiiiBflfc
EltMll'i'lliR'MUl ' «UI i
IN Till CIRCUIT COURT Of Till THIRD CIRCUIT
STATE Cir HAWAII
kaktiit
- », -
IIOH \ IIH h, IM ..
PEMW1MST5
ft,AIKTIPrS MOTION It*
PRELIMINARY INJUNCTION
WITH MEMORANDUM OP UM*.
PLAINTIFFS' MOTION FPU PHRIJM1NARY WJtWCTTlCW
COMES WOW PlnimifFprii se. Saiulm L, DemorwHlc, who moves for «
Pfelimirtaty Inunction hatting all County of Hawaii ipinent
activities on lie Naaiehu mi Pahata Wastewater Treatment Plant Projects until
the Environiiieiita! Assessments, with the Finding of No Significant Impact
("FEAJPGNSO or Final Environmental Impel Statement are accepted.
PlainlilT als# seeks release of the Naalchu
f'OEA")urnier Infcii'iiiiliBii Pmclicca Acl {'"U1PA®| Ifjiwiii Revised
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Statutes t2f># xeq. and immediate publication of notice for both IliA* in
(Mice of Environmental vuanty Control's The Emmrmmmtmi Noticeon
In support a! mi Motion far Prelitiiiiiaiy Injunction, Plaintiff relies upon
it*. accompanying Memorandum orUw. fext»»®»B I through 23, and her
Declaration in I.feu ofaw Affidavit
Plaintiff mov» for a Prcliroi^ Wwtctio «n,-l i,.i' i. t o !, >
of Hawaii Department of Environmental Marts
Beck. ML, Division Chief of the Wastewater Division and Pi-rector William A.
Kuchar&ki, has "(pjurposely 01 m*"4 failed I® take "» hard IbcA '"
proposals for building two Utilized seeondaiy sewage treatment plants, with
one sited adjoining the Miiafcha Elementary School, in Ihe District of Ka'u, go,
it.v!. r.t . ni«;i'.rn- entitle,, •. t law.
I l»M' I I SJllN
i fn in her pleading* that lilts iillk-cri of the
County el" Hawaii Department of Environmental Management rCOMDEM")
liavc violated HIS 341 irfftf, and the Hawaii tilWi site respectfully reqwsb
• urns cm • Oeimmmv of tawm it»t r.M Mi, J» 1MI
<¦ M. Stwif % Otoyu*. mm. trnrn.m hwm. »L,Mr..lI n* HolM
thai the Court Order the Preliminary injunction that will lilt *11 COHflDf-M
activities anti expenditures m any and all Implementation actions and
consultant and sub-consultant contracts. 001I shall provide the sta.IT to
complete the EA on both projects, ml. if significant impacts m determined, in
pnxlutH! ariiil publish the Final Ril iurameplmms by li»eClavemur,
Further, as relief to life Plaintiffs injuries because the COHDEM failed
to,-,. !)•,.mi tivkle ilic Plaintiff and the two Ka'u libraries with
«w« i1'1! ''«•'« Dli Ass, il is niw ordered that fXIMilKM ttuhmit lite IJKA* to
Hawaii Office of Environmental Quality Control by September 12®!!* TEN
publication on September 21V'4,2011, ;ly provide iIk document is
flic Plii.In.tiiTand die ICa'u libraries mulct the ill PA requeaits.
Tfce Fiabtiff, ea behalf «f the whole Ka'u community, wjiieas that the
Caen order that until the FEiS for both tie Naalehu and Piilsta Wastewater
Tientment Plants have been accepted by the appropriate MRS Mi accepting
authorit' ¦ VI ' tHDEM is to take no fiiriher a< . i» ->•' ¦ site these
sewage treatment pJittti projects under Otist of this Court.
IMti; Augait 21 _ 2111 i it Naiefcii, 1 tawai i
Hatntiffi.
Sandra L« Dtmofticlte, #*«• St
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WILSON OKAMOTO
COUP T t § II
10349-01
March 6, 2020
ref(18)
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment - October 10, 2018 10:50 p.m.
Dear Ms. Demoruelle:
Thank you for your October 10, 2018 10:50 p.m. comment message regarding the County of
Havvai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our responses follow:
There is no requirement under Chapter 343, Hawaii Revised Statutes, as amended, or Hawaii
Administrative Rules (HAR), Title 11, Chapter 200 that proposed wastewater treatment plants
must be reviewed through an environmental impact statement (EIS). Pursuant to Section 11-
200-11.1, "(a) After preparing an environmental assessment and reviewing public and agency
comments, if any, applying the significance criteria in section 11-200-12, if the proposing
agency... anticipates that the proposed action is not likely to have a significant effect, it shall
issue a notice of determination which shall be an anticipated negative declaration subject to the
public review provisions of section 11-200-9.1." As stated in the Pahala Large Capacity
Cesspool Replacement Draft EA Preface, this Draft EA was published in compliance with HAR
11-200.
HAR 11-200-10, Contents of an environmental assessment, does not specify a number of pages
for an EA.
Other references are not comments to content requirements of the Draft EA for the Pahala Large
Capacity Cesspool Replacement project.
We appreciate your participation in the Draft EA process.
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
10349-01
Letter to Ms. Sandra Demoruelle
Page 2
March 6, 2020
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski. COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
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RPORATIOK
'»i'OS5 .*i «
10349-01 ref (19)
March 6, 2020
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - October 12, 2018 10:20 a.m.
Dear Ms. Demoruelle:
Thank you for your October 12, 2018 10:20 a.m. comment message regarding the County of
Hawai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our response follows:
This is not a comment to content requirements of the Draft EA for the Pahala Large Capacity
Cesspool Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 * Honolulu, Hawaii • 96826 • (808) 946-2277
-------
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-------
WILSON OKAMOTO
COUP T t § II
10349-01
March 6, 2020
ref (20)
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment - October 13, 2018 8:51 a.m.
Dear Ms. Demoruelle:
Thank you for your October 13, 2018 8:51 a.m. comment message regarding the County of
Havvai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our response follows:
This is not a comment to the content requirements of the Draft EA for the Pahala Large Capacity
Cesspool Replacement project
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski. COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
-------
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IS THE CIRCUIT COURT W THE TIM® CIRCUIT
STATE: OF IIAWAIt
SANDRA I*. I'm &
plaintiff
DORA BKCk CI WILLIAM A,
KUCHARSK1,
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will i Finding of M# Significant iiilpitt f'FEA/FOSttn piiMJiiest in The
Noiitt Cim "} on August 23,2007 ami «l bus newer hcoi withdrawn «
«ppleiw*«l mime ifwi tJme,
B. I*: SMSMUfe
' fusfiifioiiiil ii*umeiil»ila '
iMlep,Alt)" (Dtf.Memo of Off*. Ex. A.P. S,Sec. J. 1.2).
C. Def. Memo of ©pp. iaikia Service Arm of tIMI parcels
cwage flow rue eg I #!,,«» (jalloim per «h* Mi si* NUi Sm\im
fl iiisifciy I 17,300 gitfto '
0,
E.
leifcilf tttiifi the ettiti for eoiwrnokf ind ofei»!aig cttcb
t OH IlejaMltSKM frft«isiiird!i Kill! Oe
wliomJ ihe mm! Hi Kitimltar costs of fit project: "«i, The operctkm and mrnmmsim costs
rf tin pttfxwMl tcptic ifiteint should he lifts!ffctolij' tower ftaii the apaitlaii in!
..s.i' .. l . , - « , » ! II t I >. r . I ! i »¦¦ vv;f.^i: i f »' ,, I. 1 > , ¦¦. .1 !' , > I . M(
(he wiiiiewMei ireiliiwiti. f?i»i in iltfo. Therefore, the mor fees ftw the resliritts- #1
Maifefcit ftfii Ratal* iteiii fee iigfiifleaislf t&mt iliwi ifte current CounQ? mm,m M
0. The COHȣM rapta the cliisp fktii the f EA/fTOSI wnwd Kin LCT Ckwure
l'i- ' i. >'• i., t,, i-i i; 11 i' ,, v.t i i i. , ..i j.. . i .
tiiil »fsuK*' fix II* ct»i|«'istil the higp csn*»«»ty seflist s-ystefii ®ai determined lo
not Iw b nMk apt** C«ne|Beiilly, fc OMHgr feepttt ia|ioriBf o»J*f ta*l B|»tiafii.
J 1 . i , i 1 >r . ,« i < . , , . r i i, 1 > • ii i.
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te' teth III# MvMt,
m.m* ei«
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wmnwiwly,- »I!B !;K«-WH2 JMS**SCD««*iil2J4'oi%fe4,,fc *1 mm-
Work Pbii on April 21, MMl),
"fc »eii faiB IbhsiiifJe^liCC c^ik prjea wiii^ FIWPOWS Utmmmm-
' ' ipiwjwelowthcUVfwIw"
i ant» kmc COIIOI* (alel» mpitmmi tic FEiVFONSI
| ' tT W ^i jj, C j'j j' jSj|
, Urge CiijsMlf Cmfwoli fIXC") m Kihi, which wwild kmt l*xa
1 by am iitti acitei J.2,4 «f" Pel". Ci»p, Memo. a.. D Out
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' ¦ -¦¦¦¦: - - ¦¦ - 1 ¦ - - n I - - , , '' ¦- V '
not aclcl.
il, UK Hmlfim {¥eimmtMt tfmwei m Ssmm. S,l «»t "«IRS 343 EA ftwii" in
th« iM. Opp Memo. Ex.. IX »%ti%l«irf ,wi Option e« p«ge J, ttot
WW, km iifKh, Be ¦Miiif! mm held * «quW bv «te At* i
ill, ARGUMENT
A. TliifjIiH,. :,,:v. it.'-tcs' AOC for Relief
I ftt h ¦ » .¦• ¦:".in¦. ¦¦ n lunifUiancv ioi issu mksi.1
i# «tqr iietkms oxwiwnwct pn»a»iit m »f«plie.«Ht; l,»»s, ngMem. or pmtti. ner 4mt if
mmaimm i, retaie.** If h wen mkumlM:, ifc« COHORtl iwifhial itiwimii t^iilring
«t" the County"* prefcifrt fiio :i» cwipletal wmM
w.pl. H«vc fwccfal tin* m^rprxivrxt ill f fccf fc.K. H. alii to If? swcfel to iccoffWTKx!11c the f IffcS
1«, . I, -I .. I,, i t i ; i i ii1 m i ., | ' i • is
-------
11 OOitOEM Fiii led lo Wilhimw or StipplaiMii HIA/I-OKSI
ftiiiMifflas iokt Defendant, William KtielarsAi,.iihm ixMBfM M* MM »
proved IXC convcnkw »• iwa upttut aitamSxiy
wa»itc*rdi,cr tfeitlsiral plants, The MM miisalei- efi* fume 2"?, IMS, CQH Eiwiramwo®!
MtiBfetnei* ("KMC") iisstttftf itatunieiil the following
llisiatSislsiiili;. .."In 'lit inWi.1 mm. the [IOC coevtaioo toseptkl option
wm tfccniglit to be ae«^»»l>fc, kiwmr wlwrs llity *. "wi. Yml I.. .Mli^,; rtl
Ippnl,s We're in (he situation mow. We know the technology. Who* me tie
gotiij: m put»! is mm fix skilmmunl W<"»« kwfesf««»w 3® sites in HnMm
Ms, UhwwihIk: in«re hn new* bom • • *"!»»< Ik's nMciqg it site xMm
; i. •,, ; , i ? >«,< • , t i«mvimnui«iutlytreviewed.Tl . '.i.. . «
«*» '"-IS m v • >
»«»*' f«k«# «lf lb# MWsiff! fceilniCi* .sjsleiii.
They went from ilie LOC to sepluc, mti tlieii »U «f » sudden. wok m ¦
H,!ji mac*a(fsi:v [COtiDBMI said ifs mm suitable for the silt that ibej* went going
la put the septic - tliiiy jiot suddeaty •tnf to two laew-ittiiililj iMHMMttt
" ' ..' >t«i •?' i1 ,-»!•< .?.< h-1.
,, (UJ,..!.!,, J,,;,,
,.. You don't «te EAs after lite {falj. I etm cite ym Ike tow. EIS* mtt Awe early n«
the puixw, ewifpl Aoi rt* *«««« i»i *» * m £!S «i (l»s»f ww p«»jikb mt
'J. fin I', li«>1 lw;f=- [<;.
iJiwriiss iMs. with us 1*J 0|ect,
fc sewage Kpiic eafmendm, wWdiwjf«r«Mf not be {usetofj,. Imcmk
«fcs Thfty won't $hx mi the
» *ta«| 10 Nftv MVHM11 JBl.«*i at m% paii'E i-i-.i r w i cmocM am pnMM% ropimd ki mm-
or Ihf' I® ^ l|A..
, «hm $m$ » fa f«« &» why ..
[Vtficrwoft ftiiiil jsfeipBi'S- itjiil (JiS "wJ fi
j ........... ... ..H HfCfllRff,. BlfCCICtf KlfCitiiiSisi Will iitsfKlly
liiiifif of the seeoodiry t
i mm "off tie iible.- Hie June »« EMCmiBiite i
»»if* mbmil stt efftl* mWc «r w
[ SJ { , |t«^1| T|*T|f Mf ^ . | "fKt* | I k,,n
Otreetef fciictinnltK When fm 4o m EIS or to EA, fim mm » pmm stumum
*•«» Si k |w»'!re m do. So until Hw t:A, line EIS,
£ ^ ^ . . | I -j • < * t; . . fa . ft . i"|| ' .. j, . - | . i/ .* !
mki- mm w,-y i.ws ms»> iw«h 'iwsi.wn.t usifMciai, aixs » (Willi put uut, osi uiv
tSSJiC
Diteefor MM tm minis «leir ¦ aitier EMC nisaiiiigs tisti iht EAMS h t» jmsii%,
bWlfARII-mi.' f~mmr
ISHCl M r«iK*Vll«/*!R»l III tKc 3C;S.lt.M,
I i '> "k I., "till , V > .!•«• WlllllHB Klicllifi' .»•!, i' 1.11. » C . ,,
"c«r!y" E/\. E!S tm ?bc :
Dlr«.f#r Kiifkiifskt »s stutii. beo
M..I • , ..I aMi»e, and fiicmat s .. , »> COHOBM ha* kwlswi ti ,!»»sites
witiKiet decWag^pMH AemAte m Ac Kadcfe* RkwentMy Seloal life. As IMMm
Kacfiiii*! siys: ",vwr Imm- m $v thmwgk aimsfiflmtim at is turn <,m got m that miiimnf
" slicwinglie is in «bUon ®f is..1
l>«|eSeff
-------
By wiiBiBg thirteen yew* » even bejpn ffep»i*k*«lili« RtjiBitfe "ttOf
tmmmmarnl m* ?eij> ntMtsttziiig s*1 jiiittfytiif 9m
imisiem wis rsli«» of |[*
«ii>'«roim»iii3it effect*. EPA liiii afeown that it MM to it« ita ravte*
tw »« "pfwsedwwJ" by allowing CUHDEM Oirccltw Riaeliifski to tletenawctlat an EA
. , , • iswal i. i, i ,1 , . , ,'i ¦ i. ,'i • |. i i , , .in :. i ...
h ' .. '• , .WfWlf»l«i»l *l»SllSS» »!' 1. . ! i ' . • 'A. i.l •
wwsl, Dtreclor Rwfeiiretu »«!; "in mm Eftfvsmme upvltii a prt/errtd alttrnen(w, ami thai
fwrfirn-J tiitrmMm: u wife* «8f .ifliie mvtnmmtewkii xw&ts amt imports art mtflwmf smmmi,
dmtpmknviogathmrxkmfmuifb > . ' . .. V ¦fietrmi file, /tafttel it*
the (Mk-ta:" Diteaar Iiieitosiki mmmmm in Ac Cmmtf #f I Immmii fimimmmtimmi
I# 11 hwwri *» pKiMeiltilif 24
r^aWj.MISS tK'ill !!.•'«•? * .." .ll.il
I'tiiinliirreaditkwl.fcf-. i , . ¦ ,. •! i¦¦ I. mUtm WWS
W tfoi nleise
111" Ka B tahmbr, Jlilic MM Hun, fi*. 1?| 11 B
13.!! ";.!iX mtwiil Itial ii llliitfcf mi*A,
IX !>tfcifcbrifef • ,i ¦ >. H.,. ii- ¦ iv* • •' • ii . "tmnf
it* ornmmf tawetsffieral wbcwk iftjine? from DeRattatr meodietty in teUmj the com
itial thej aw offering any to fMnsiciptfe16
IV, PRELIMINARY INJUNCTION:: COHDKM Cmetmm MIS fmrntmrn WMhm
Cuirt! »rl»n.®»l»-wiilr««[sn
FlaiitifT lest,* t# fctwt ill® current Camnetun«ni Sub-caninKtwt, wto tot wotsgitJ
t 1 . I i i , il | ('i: ' " . s * , , \ 1 , j, ' «> 1 i^1 ^
tfe«ei«jf»:t!n*Bl: md *iSm* srti»itics.. Pltiniil MM fc»n
cooiiai«i«i|t ike mivii he cwiigioal, siiifle LCC nktmie pejm f®
coflittfcr otlict iBrriulintctiiie opimm, esjKdtlly ta ligla of improved mmmmm mmmm
wfciwlogf i*l Atl IJI-W,:"
Pliuni >• tatjayefs are paying natHaM af iIbHihis fc*
CeaB»ler«»Sii!»-i!«BiBic*sr» wtto mt ¦ •«, at km *m
COMPUM a t»»sl|sl»ii( • etapet mm.
The exist aicf BiiiiiiilTiiiels llifotifh He MMMiy IbIiiiMIsmi:
II D&mdmm Smim;tbmljr m IHimtiigilte Maalekt WrnmwKrfymm
tfr0 Smtrmmmt Ammmn ("DBA "j as «fsrs»frf Hmkr Urnfimm
Information ProaScet Act II1S».?#"«.mtdimmeSmtfymlmii.mJpuUiih
mm erflfcr hlimtcku trnJ the f'mlmh Wtntemmr fftiM fi£4t lit Hmwm <#?«* tjf
EmimmmMI t'omre? 't" Tift emtfrmtmmM Xetkse"" fa «4i» Itis
2) fiMsinpi- a/fiamttt iMmnikmiy m em* f»,r mi mil ("mmay eMfitmikures im
t€r ,'i 1 . . .... ... 1 .' i r. , < ¦ em
actMirs m tht Kmkkn md i'almbi Wwuwottr Treatment Mmt f WWW) Prajtea
ilwittg ffm smmitmy ofiim ittiimi or iaftltk> nttimmte MS M fmst
A K*rrf%iwc*tat uitk l**e vf Ho If
rrmmmn or flmt Hwlnmmmmi tsffmsrSmitmenr f"FElS"fete mminmt
iiteiwiiw ocean fit Mi, as lit* ixlermi mi t»mg Iikim* mi the lla "m St'lfTf
rnmfimtti ¦iiasiiei'1 mtif ttai, immmr, m mm i» mmt
-------
!»»#«•!* wll fmemmi fc>> flit tmrimmMt immmmm in fmmttbm mt
aur mling and planning aeimlirs. Further, tmlii At fimal Cmtrt dxismm <»¦ fkr
F'£A/Pf.}M$i <*" &rc ttctrptttf, JiWf4? the prtMTtn i.#«
itm Cmmff sf
ilmmii will me im mm permmm'l to amy mn ffte fUS )4} mrmmary «»»,»»*ttfriJ
ref*w fmxwAwrt, mtipmmtk the mfMiMfe piift pemkfptHkm for thiw U'C
lta» ?«/«*» •* «f «>»^ % & * t'DP a*f HBPA IMS Hi m s*9.
For (im: wawww giwisi in lis pfe»«li#gs» l%hliaV«p«elfeIijj iwpesls (he Court
order * frelitiliiiff lujttiWMH »asioii and winiii Dtfcndantt Aifitif sis of
litis irtitw, Mf for public iswmct fKMmcnc Ht«
Draft MNMRtf Assessment dwumrms,
fisie* (Mcr 21, Kklt m Umkirn, Hawaii.
I^aiet tiff
I ll!:;RI;i¥ CSIIIirt' IliAT.wi iliiidafc mi fcyll*
following «i lhe.tr l*sl Imtrnti nAkiSi:
Mail
a>i*»ecl,p,i,
: • - ¦ v' • , ¦
County of Hawaii Dcpntoent of Eiwif«nii»eiiBl MmafcnKiK
1S.& Avenue
IBfa, Itiiwwi 46730
Rise »MM»
William A tti»rti*iA«
Diieetw, CmuMy of llmmrn Dspiitiiisiil ef Environmcnul Management
MS Eekiiitratia Street, S*i»41
tfilo, Kits'sit WQil
fa*; 961*8086
Corporation Cwnsct
JIM Aiiftini Slittl Unit 325
ftufctof*
-------
WILSON OKAMOTO
COUP T t § II
10349-01
March 6, 2020
ref (21)
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment - October 21, 2018 4:12 p.m.
Dear Ms. Demoruelle:
Thank you for your October 21, 2018 4:12 p.m. comment message regarding the County of
Havvai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our response follows:
This is not a comment to the content requirements of the Draft EA for the Pahala Large Capacity
Cesspool Replacement project
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
-------
Earl Matsukawa
rzr\
Sent:
To:
Cc:
Subject:
Attachments:
Naalehu Theatre woe oct25-2l08
Wednesday, October 24, 2018 4:03 PM
Public Comment; Earl Matsukawa; Kate Rao; Dora Beck
dekven@brwncald.com; kim.wagoner@erg.com; Patrick Goodwin;
braden.rosenberg@erg.com; Maile David; Rep. Richard Creagan;
iconstantinescu@brwncald.com; John Sakaguchi; TESSA BERMAN; eplan1@aol.com; Bob
Martin; David Albright; Linda Morgan; Ka'u Calendar News; The Ka'u Calendar
Newspaper and Daily News Briefs; Nancy Cook Lauer; mail@environrnent-hawaii.org;
Shannon Rudolph; Senator Hirono (imailagent); Senator Hirono's Office;
sengreen@capitol.hawaii.gov; HI Office of Environmental Quality Control;
tnapeahi@yahoo.com; Solali Hanoa
Re: The Ka'u Community's Request to Extend the date for Pahala DEA/AFNSI comments
Pahala.Hwy! 1_Culvert.zip
Dear Mr. Matsukawa,
Because we in Ka'u have so many concerns that we have not been able to write into comments as yet -1 myself
have not even started on my concerns with the costs in the PER -1 know a request has gone out for more time to
comment.
With that in mind, I will continue to submit comments.
Like so many other people, I am concerned with the ACTUAL flooding potential of the water that flows
through the culvert from the mac nut orchard where you want to place the four open sewage lagoons. All you
COHDEM Contractors and Sub-contractors seemed totally unaware that this culvert even exists, so I am
attaching pictures of it to prove it does exist.
I will continue submitting Pahala DEA comments because I have not had time to write up all my comments as
yet - and we all deserve a chance to have our concerns fully heard on the two WWTPs in Kau - even if you are
illegally making us do it one project at a time.
We will be suing on this forever! And maybe tomorrow the snotty attitude of Corporate Counsel will make
the Judge sympathetic to this old lady!
To my Friends - pray that tomorrow in Hilo Courtroom 3E, I can speak truth to power, successfully. Aloha
pumehana, Sandy Demoruellc
On Tuesday, October 23, 2018 02:47:36 PM HST, Naalehu Theatre cnaalehuiheatreitt yahoo.com> wrote:
I have not received any confirmation as was said would occur. Sandra Demoruellc
On Wednesday, October 10, 2018 10:50:05 PM HST, Naalehu Theatre wrote:
I
Dear Mr. Matsukawa,
The Pahala DEA meeting tonight was held without the aforementioned DEA volume present to consult.
It was like having a Bible study class without any Bibles!
Was I the only person in the room who has actually read the meager DEA offerings? I mean 21 blank pages
and untold repetition makes about 50 real pages to read. But to read it, you have to have a real live volume of
the DEA to read. None were present at the DEA meeting???!!!
But not to worry! You will have hundreds of pages of comments to add bulk to your FEA - which will have yet
another law suit since you did not go direct to EIS like ALL HAWAII WWTPS DO. Name one project without
an HIS?!!!
And you could very well lose your prelim inj. and no one will be paid for the meeting I so enjoyed tonight. But
then, I didn't get paid, either.
Best, Sandra Demoruelle
On Monday, October 1, 2018 10:40:37 AM HST, Naalehu Theatre wrote:
All wastewater systems have had an EIS. Failure to do so means that EPA and COHDEM are intentionally
evading an EIS process for the single project of the Kau LCC replacements.
Dated October 1, 2018 in Naalehu, Hawaii
S/ Sandra Demoruelle
SANDRA DEMORUELLE
On Friday, September 28, 2018 01:42:46 PM HST, Naalehu Theatre
-------
SANDRA DEMORUELLE
On Tuesday, September 25, 2018 12:39:08 PM HST, Naalehu Theatre wrote:
Page 1-3 of the Pahala DEA lists as a consulted "Elected Official" Councilmember Maile Medeiro, when her name is listed on the
COH website as "Maile Mcdciros David."
/s Sandra Demoruelle Dated September 25,2018 at Naalehu, Hawaii
SANDRA DEMORUELLE
On Tuesday, September 25. 2018 09:38:47 AM HST, Naalehu Theatre wrote:
The transparent efforts of the Contractors-EPA-COHDEM to evade LUC approval by stating "14.9 acres" are for naught because the
Site 7 is on ITJ PAG Designated Important Ag. Lands per Figure 6.1 Page 6-17, so under 205-6(d) "Special permits or land the area of
which is greater that 15 acres or for lands designated as important agricultural lands shall be subject to approval by the land use
commission. The land use commission may impose additional restrictions as may be necessary or appropriate in granting the
approval, including the adherence to representations made by the applicant."
Anyhow, anyone who can do geometry can see from the project footprint and the Scale in Feet, that the project covers a minimum of
667,500 sq.ft. [15.3 acres] plus the utility access must be considered as part of the project impacts no matter WHO will own it, so that
is another 37,500 sq.ft.. bring total acreage at Site 7 as 16.1 acres.
Your just saying it is 14.9 acres and will never a fleet a larger area is disingenuous and does not portend well for accuracy in the rest of
the DEA information.
The COI1DEM et al. would be well advised that they are going to have to "adhere to the representations" they make in the EA and
Special Permit application, under LUC supervision. LUC may see through your purported factual information to the false claims that
underlie claiming 14.9 acres, for instance.
Finally, your minutes from the joint May 2018 meeting talk about evading LUC scrutiny by keeping the project footprint under 15
acres.
»'s Sandra Demoruelle
SANDRA DEMORUELLE Dated September 25, 2018 at Naalehu, Hawaii
On Tuesday, September 25,2018 08:32:17 AM HST. Naalehu Theatre wrote:
This message has been scanned for viruses and dangerous content using Worrv-Free Mail Security, and is
believed to be clean. Click here to report this message as spam.
-------
-------
WILSON OKAMOTO
COUP T t § II
10349-01
March 6, 2020
ref (22)
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment - October 24, 2018 4:03 p.m.
Dear Ms. Demoruelle:
Thank you for your October 24, 2018 4:03 p.m. comment message regarding the County of
Havvai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our responses follow:
The County is aware of two existing culverts that allow stormwater to flow across the
Mamalahoa Highway in the vicinity of the project. The first is a box culvert located at the
intersection with Maile Street that conveys stormwater under the highway. The second culvert is
located approximately 600 feet east of the Maile Street intersection and was used to convey
sugar mill flume water across the highway for disposal.
The Draft EA Section 3.9.1 (a) states:
"The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM),
Community Panel No. 155166 1800F, effective date September 29, 2017 shows that most of
the Pahala area is located in Zone A', which designates areas determined to be outside the 0.2-
percent annual chance (500-vear) floodplain. A small portion of the community of Pahala,
including some land within the collection system project site, is located within Zone X—
Other Flood Areas, indicating areas within the 0.2-percent annual chance (500-year)
floodplain, or areas with a 1-percent annual chance of flooding with average flood depths
less than 1 foot.
According to the FIRM, both existing LCCs are also located within ZoneX. However, LCC-1
is very close to the edge of the 500-year floodplain.
On April 16, 2018, in response to the pre-assessment notification, the State of Havvai'i
Department of Land and Natural Resources Engineering Division stated the responsibility for
conducting research as to the flood hazard designation for the project site lies with the project
proponent. Also on April 16, 2018 and in response to the pre-assessment notification, the
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
10349-01
Letter to Ms. Sandra Demoruelle
Page 2
March 6, 2020
County of Havvai'i Department of Public Works confirmed that the proposed treatment and
disposal project site at Site 7 is designated as Zone X on the FIRM and is outside the 500-
year floodplain."
The relevant FIRM panel is reproduced in Appendix B as Figure 4-13.
This information will be repeated in the Final EA.
The Draft EA Section 3.23.2 (a), states:
"The proposed wastewater treatment and disposal facility would include an on-site drainage
system to address stormwater surface runoff created by new impervious surfaces within the
facility. The site would include a system to collect runoff via grated inlets or swales, and
flows would be conveyed to on-site drainage detention systems, such as subsurface linear
infiltration or depressed detention basins."
This information will be repeated in the Final EA.
The preferred alternative (Site 7) slopes from approximately north to south (mauka to makai)
such that, during rain events, surface flows pass through the existing orchard to the southern
(makai) end where the flows eventually drain through the culvert located at the Maile Street-
Mamalahoa Highway intersection to the areas below (makai) the highway. Most of the land
surface area below the existing macadamia nut orchard contains little to no vegetation to absorb
or slow these flows. The gradient of Site 7 and surrounding area results in this natural pattern of
surface flows which also existed when the area was planted in sugar cane and is not considered
flooding.
Based on the roadway flooding concerns expressed by the community during the Pahala public
meetings held in December 2017 and October 2018, the State of Havvai'i Department of
Transportation (DOT) Havvai'i District office was contacted to discuss drainage at the treatment
and disposal facility project site and the culvert at the Maile Street and Mamalahoa Highway
intersection. On February 20, 2019, the District office confirmed via telephone that the DOT
owns and maintains the culvert at the Maile Street intersection, and that they have no record of
the roadway being inundated by stormwater drainage during precipitation events at that location.
Stormwater runoff generated mauka of the treatment and disposal facility project site will be
directed around the perimeter of the site via diversion swales that will convey flow back to the
existing drainage pattern that flows to the existing culvert at Maile Street. During heavy rain
events, stormwater may temporarily back up behind the culvert. There will be no changes to this
culvert and the proposed treatment and disposal facility will not be located within the area of the
culvert.
-------
10349-01
Letter to Ms. Sandra Demoruelle
Page 3
March 6, 2020
As stated in the Draft EA, the on-site stormvvater management system would meet the
requirements of Havvai'i County Code (HCC), Chapter 27 Floodplain Management, Section 20,
Standards for subdivisions and other developments (e) which mandates a site drainage plan to
"comply with sections 27-20(a) and (b) and section 27-24, and shall include a storm water
disposal system to contain run-off caused by the proposed development, within the site
boundaries, up to the expected [design] storm event, as shown in the department of public works
"Storm Drainage Standards"."
To meet the requirements of HCC, Chapter 27, Section 20 (f), the project "shall not alter the
general drainage pattern above or below the development". Thus, for the design storm event, no
increase in flow amount will be directed to either of the culverts at the highway as a result of the
site development. A drainage study will be prepared during the design process to evaluate the
improvements necessary to comply with HCC Chapter 27 requirements.
The wastewater treatment processes will be designed to accommodate the associated peak flows,
including precipitation that falls on the area occupied by the aerated lagoon treatment system.
The Draft EA Appendix B, Section 2.2 outlines the anticipated peak wastewater flows from the
community, based on the applicable flow standard. The Draft EA Section 2.3.1, states the
aerated lagoons will be lined to prevent water seepage through the bottom and sides of the
lagoons. The Draft EA Appendix B, Section 5.3 shows the operational freeboard that will be
available to contain and to equalize lagoon flows. In addition, the slow-rate land application
groves will be designed to completely contain both peak effluent flows and precipitation from a
100-vear, 24-hour storm event. A geotechnical engineering assessment of berm stability will be
conducted during the design process. The tree groves will be designed in accordance with the
EPA's "Process Design Manual, Land Treatment of Municipal Wastewater Effluents". Effluent
will be applied at a hydraulic loading rate that is a small percentage of the percolation rate of the
soil, ensuring sufficient capacity for assimilation of peak effluent flow rates and precipitation
from the design storm event.
This information will be included in the Final EA
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
10349-01
Letter to Ms. Sandra Demoruelle
Page 4
March 6, 2020
cc: W. Kucharski. COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
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LSOM OKAMOTO
BPORATIQK
:> * t o s ;s . * i * *, *«* * % « t *, <. , H ! I *
10349-01 ref (39)
March 6, 2020
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - October 23, 2018 2:48 p.m.
Dear Ms. Demoruelle:
Thank you for your October 23, 2018 2:48 p.m. comment message regarding the County of
Hawai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our responses follow:
This is not a comment to the content requirements of the Draft EA for the Pahala Large Capacity
Cesspool Replacement project.
The attachment comments will be addressed under a separate cover.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 * Honolulu, Hawaii • 96826 • (808) 946-2277
-------
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RPORATiQN
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10349-01 ref (46)
March 6, 2020
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - October 31, 2018 8:03 p.m.
Dear Ms. Demoruelle:
Thank youfor your October 31, 2018 8:03 p.m. comment message regarding the County of
Hawai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our response follows:
This is not a comment pertinent to the content requirements of the Draft Environmental
Assessment (EA) for the Pahala Large Capacity Cesspool Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 * Honolulu, Hawaii • 96826 • (808) 946-2277
-------
E3
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LSOM OKAMOTO
BPORATIQK
jMiH i k *¦„• 8.. t o 3 ;s . * i *«* * % « t *, <. , ^ ! I *
10349-01 ref (45)
March 6, 2020
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - October 31, 2018 8:13 p.m.
Dear Ms. Demoruelle:
Thank you for your October 31, 2018 8:13 p.m. comment message regarding the County of
Hawaii Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our response follows:
Hawai'i Administrative Rules (HAR) Title 11 Chapter 200-10 Contents of an environmental
assessment does not include a requirement for evaluating the fiscal impacts of a project on a
County's budget or ability to obtain funding.
The Na'alehu project is not the subject of the Draft EA for the Pahala Large Capacity Cesspool
Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Earl Matsukawa, AICP
Project Manager
cc: W. Kucharski. COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
B. Rosenberg, ERG
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
-------
Kate Rao : Dora Beck
Cc: Sara Kamibayasbi : Maelerse Kaaparsa
: Linda Morgan : Bob Martin
: Maile David : Ka'u Calendar News
Sent: Wednesday, October 31, 2018 11:39:24 AM HST
Subject: Naalehu PER in Naalehu/Pahala Libraries?
Since this Naalehu Preliminary Engineering Report (PER) is a very important document
that could potentially remove some of the terror that people have felt with the Naalehu
School as a site for the sewage plant, has it been placed in the local libraries?
Attentive as i am to this issue, I did not know the Naalehu PER had been published Oct
28 because the Task 5,1 two meetings had not been held between August 27 and
October 25, 2018 and the PER document isn't readily available at our libraries.
I remain extremely concerned as this property, like property #1 (Weatherford), is PONC
land (see HCC Res. 850-13) under care of the Ala Kahakai group.
Sincerely, Sandra Demoruelle
—— Forwarded Message —
From: Horowitz. Kaena
To: Naalehu Theatre
Cc: Hirayama. Emily
Sent: Monday. October 29. 2018 10:19:03 AM HST
Subject; RE: I have to cancel tomorrow's meeting
Ms. Demoruelle,
The below link went up on 10/26/18 and is available for public comment.
http://records.co.hawaii.hi.us/weblink/l/edoc/96399/Preiiminarv Engineering Report (Naalehu WWTP)
October 2018.pdf
As you can see from Section 8 in the link (pdf pages 75 and 84), the recommended site to
develop is TMK (3) 9-5-007:018, a parcel of land that is well away from the school that your
grandson attends,
if I can be frank, Ms. Demoruelle, what is it that you're looking for? How can we resolve this
matter?
Please advise,
Mahalo,
D. Kaena Horowitz
Deputy Corporation Counsel
County of Hawaii
From: Naalehu Theatre
Sent: Monday, October 29, 2018 9:25 AM
To: Horowitz.. Kaena
Subject: Re: I have to cancel tomorrow's meeting
Thank you so much I put it on my calendar. Best, Sandra Demoruelle
On Monday, October 29, 2018 09 23 39 AM HST Horowitz, Kaena
wrote.
Ms. Demoruelle,
! hope you feel better soon.
-------
November 7 @ 1:30pm works for me.
Mahalo,
Kaena
From: Naalehu Theatre (mailtQ:naalehutheatre@vahoo.coml
Sent: Monday, October 29, 2018 9:19 AM
To: Horowitz. Kaena
Subject: I have to cancel tomorrow's meeting
Aloha, I am so sorry but I have been sick all weekend and will not be coming to Hilo tomorrow Can I re-
schedule for any time on November 7 or any day the week of Nov. 12 Mon. -16 Fri?
Again, I apologize for the inconvenience this may cause you Best, Sand
-------
WILSON OKAMOTO
COUP T t § II
10349-01
March 6, 2020
ref (48)
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment - October 31, 2018 11:39 a.m.
Dear Ms. Demoruelle:
Thank you for your October 31, 2018 11:39 a.m. comment message regarding the County of
Havvai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our response follows:
This is not a comment pertinent to the content requirements of the Draft EA for the Pahala Large
Capacity Cesspool Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
-------
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LSOM OKAMOT©
RP0RAT4QN
'»i'OS5 .*i «
10349-01 ref (47)
March 6, 2020
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - October 31, 2018 12:41 p.m.
Dear Ms. Demoruelle:
Thank you for your October 31, 2018 12:41 p.m. comment message regarding the County of
Hawai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our response follows:
This is not a comment pertinent to the content requirements of the Draft EA for the Pahala Large
Capacity Cesspool Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 * Honolulu, Hawaii • 96826 • (808) 946-2277
-------
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LSOM OKAMOTO
RP0RAT4QN
'»i'OS5 .*i «
10349-01 ref (49)
March 6, 2020
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - October 26, 2018 11:12 a.m.
Dear Ms. Demoruelle:
Thank you for your October 26, 2018 11:12 a.m. comment message regarding the County of
Hawai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our response follows:
This is not a comment pertinent to the content requirements Draft EA for the Pahala Large
Capacity Cesspool Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 * Honolulu, Hawaii • 96826 • (808) 946-2277
-------
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-------
Ms. Denwraclk-.
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Krai: Monday. Octotwr 2V. 201S 9:19 AM
1ft; lionmitz. K«m» ii/'ir havtaikoimlv ,gtrt>
Subject: I have to ean«i BIIWHW^I meeting
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beloved lo be e lean
%
-------
WILSON OKAMOTO
COUP T t § II
10349-01
March 6, 2020
ref (50)
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment - November 2, 2018 12:22 p.m.
Dear Ms. Demoruelle:
Thank you for your November 2, 2018 12:22 p.m. comment message regarding the County
Havvai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our response follows:
This is not a comment pertinent to the content requirements of the Draft Environmental
Assessment (EA) for the Pahala Large Capacity Cesspool Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski. COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
-------
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I H M T I 0 S
:> „• * t o s ;s . * i * *, *«* * % « t *, <. , H ! I *
10349-01 ref (51)
March 6, 2020
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - November 5, 2018 9:26 a.m.
Dear Ms. Demoruelle:
Thank you for your November 5, 2018 9:26 a.m. comment message regarding the County of
Hawai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project.
The Draft EA Appendix B Section 5.5 and Table 5.3 provides a conceptual planning level
construction cost estimate of about $14.6 million for the secondary wastewater treatment and
disposal facility only. Table 5.3 does not reflect the total cost of the Proposed Action and does not
include planning, design, land acquisition, the collection system or past project costs. As stated in
the Draft EA Section 2.1.2, the project may be funded by the State of Hawai'i Department of
Health Clean Water State Revolving Fund which authorizes low interest loans for the construction
of publicly owned wastewater treatment works and an EPA Special Appropriation Grant. This
information will be included in the Final EA.
Hawai'i Administrative Rules (HAR) Title 11 Chapter 200-10 Contents of an environmental
assessment does not include a requirement for evaluating the fiscal impacts of a project on a
County's budget or ability to obtain funding.
The cost estimate for the Na'alehu project is not pertinent to the content requirements for the
Draft EA for the Pahala Large Capacity Cesspool Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii • 96826 • (808) 946-2277
-------
10349-01
Letter to Ms. Sandra Demoruelle
Page 2
March 6, 2020
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
.H
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-------
;\j /t f\ I I;- i i „• * t o s ;s . * i * *, *« * * % « t *, <. , H ! I *
10349-01 ref (52)
March 6, 2020
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - November 6, 2018 11:51 a.m.
Dear Ms. Demoruelle:
Thank you for your November 6, 2018 11:51 a.m. comment message regarding the County of
Hawai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our response follows:
This is not a comment pertinent to the content requirements of the Draft Environmental
Assessment (EA) for the Pahala Large Capacity Cesspool Replacement project.
The Draft EA Section 2.4 to 2.8 provides an evaluation of siting, treatment, and effluent
management alternatives
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
-------
!^<££SL,
Maae NnMw Qmam n°vls"2Clls
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-------
, «til h
LSOM OKAMOTO
RP0RAT4QN
10349-01 ref (53)
March 6, 2020
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - November 8, 2018 11:52 a.m.
Dear Ms. Demoruelle:
Thank you for your November 8, 2018 11:52 a.m. comment message regarding the County
Hawai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project.
The Office of Environmental Quality Control The Environmental Notice dated November 8,
2018 indicated under status that the proponent is republishing the draft EA originally published
September 23, 2018 and provided the following project description:
The County of Hawai'i Department of Environmental Management proposes to construct
wastewater system improvements replacing the large capacity cesspools (LCCs) currently
serving Pahala, in order to comply with U.S. Environmental Protection Agency (EPA)
regulations. The project improvements would include a new wastewater collection
system located primarily within public streets in the Pahala community, and a treatment
and disposal system on land to be acquired by the County (TMK: 9-6-002: 018). The
project would be partially funded by an EPA grant and by the Clean Water State
Revolving Fund loan program. The proposed wastewater collection system is described
in the Draft EA, and the existing LCCs and associated collection system would be
abandoned.
A link was provided in the November 8 2018 TEN to the Draft
EA: http://oeqc2.doh.hawaii.gov/EA EIS _Librarv/2018-l1-08-HA-Republished-DEA-Pahala-
Communitv-Large-Capacitv-Cesspool-Replacement.pdf. Section 2 of the Draft EA is the project
description.
The Office of Environmental Quality Control The Environmental Notice dated September 23,
2018 provided the following project description:
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii • 96826 • (808) 946-2277
-------
10349-01
Letter to Ms. Sandra Demoruelle
Page 2
March 6, 2020
The project improvements would include a new wastewater collection system located
primarily within public streets in the Pahala community, and a treatment and disposal system
on land to be acquired by the County (TMK: 9-6-002: 018). The project would be partially
funded by an EPA grant and by the Clean Water State Revolving Fund loan program.
The collection system would consist of approximately 12,120 linear feet of 8 to 12-inch
diameter underground gravity flow piping in Maile, Tlima, Huapala, Hlnano, Ha la, Puahala
and Pikake Streets. The treatment and disposal facility would occupy about 14.9 acres and
consist of a headworks and an odor control unit, an operations building, four lined aerated
lagoons, a subsurface flow constructed wetland to remove nitrogen with an adjacent
disinfection system to remove pathogens, and four slowrate land treatment basins for further
treatment and disposal of the treated effluent. A perimeter security fence would enclose the
entire facility. The existing LCCs and associated wastewater collection system would be
abandoned.
The Purpose and Need for Action is included in the Draft EA Section 2.2.
Hawai'i Revised Statutes (HRS) Chapter 343 Section 5 (a)(9)(A), states as follows: "(a) "Except
as otherwise provided, an environmental assessment shall be required for actions that: (1)
Propose the use of state or county lands or the use of state or county funds..." as well as, "(9)
Propose any: (A) Wastewater treatment unit..."
The County of Hawai'i is the Proposing Agency for the Pahala Large Capacity Cesspool
Replacement Project.
Hawai'i Revised Statutes (HRS) Section 343-5 Applicability and requirements states under item
(c) (4) "A(n environmental impact) statement shall be required if the agency finds that the
proposed action may have a significant effect on the environment..." The criteria by which the
proposing agency makes the significance determination is provided in Hawai'i Administrative
Rules (HAR) Title 11 Section 200-12 (a) and (b) which states: "(a) In considering the
significance of potential environmental effects, agencies shall consider the sum of the effects on
the quality of the environment, and shall evaluate the overall and cumulative effects of an action,
(b) In determining whether an action may have a significant effect on the environment, the
agency shall consider every phase of a proposed action, the expected consequences,... and
the... effects of the action."
HAR Section 11-200-10 Contents of an environmental assessment includes "(9) Findings and
reasons supporting the agency determination or anticipated determination..." The Draft EA
provides this in Chapter 8 Findings and Determination. Neither HRS Chapter 343 nor HAR Title
11, Chapter 200 contain any requirement that all proposed wastewater systems require an
Environmental Impact Statement (EIS).
10349-01
Letter to Ms. Sandra Demoruelle
Page 3
March 6, 2020
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
ff.jiw MmMm B*m» woc novlS-2018
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-------
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j
-------
WILSON OKAMOTO
COUP T t § II
10349-01
March 6, 2020
ref (54)
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment - November 13, 2018 12:40 p.m.
Dear Ms. Demoruelle:
Thank you for your November 13, 2018 12:40 p.m. comment message regarding the County of
Havvai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our responses follow:
This is not a comment pertinent to the content requirements of the Draft EA for the Pahala Large
Capacity Cesspool Replacement project.
The Na'alehu project PER is not part of the Draft EA for the Pahala Large Capacity Cesspool
Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
-------
mm I'liilefcs llsfMfe
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document
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Endangered Specie* Ac)} on boih tit* Pmtt»M WWTP Prajact and «wt NaoMw WWTP fropct • most
notably mmMkI oa t» fkwtfclw Project became if* £8* had mm appMd to am Nnnu v*Wff»
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LSOM OKAMOTO
RPORATIQN
10349-01 ref (57)
March 6, 2020
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment - November 16, 2018 10:03 a.m.
Dear Ms. Demoruelle:
Thank you for your November 16, 2018 10:03 a.m. comment message regarding the County of
Hawai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our response follows:
The Draft EA Section 3.13.2 states:
"On April 23, 2018, as part of the pre-assessment consultation process, the FWS provided
a letter (01EPIF00-2018-TA-0275) with information on various avoidance and
minimization measures to avoid adverse impacts to listed species (see Appendix A)."
"Prior to finalization of this EA and initiation of the Proposed Action, EPA and the
County of Hawai'i will conclude consultation with FWS in accordance with Section 7 of
the Endangered Species Act and will incorporate additional impact avoidance and
minimization measures as necessary to result in a finding of Not Likely to Adversely
Affect (NLAA) protected species."
On December 21, 2018, the designated non-Federal representative for consultations under
Section 7 of the Endangered Species Act, on behalf of the United States Environmental
Protection Agency (EPA) and the County of Hawai'i, requested concurrence from the U.S. Fish
and Wildlife Service (FWS) that the Pahala Community Large Capacity Cesspool Replacement
project is not likely to adversely affect federally-listed threatened and endangered species or
critical habitat.
On February 19, 2019, the FWS provided a letter (REF 01EPIF00-2018-TA-0275; 01EPIF00-
2019-1-0153) that concluded: "The Service has analyzed potential impacts to listed species due to
the implementation of [the] project. Based on the inclusion of the avoidance and minimization
measures listed above, the Service anticipates that any potential impacts will be discountable or
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
-------
10349-01
Letter to Ms. Sandra Demoruelle
Page 2
March 6, 2020
insignificant and therefore we concur that the Paha la Large Capacity Cesspool Replacement
Project may affect, but is not likely to adversely affect the endangered Hawaiian hoary bat,
Hawaiian Hawk, Hawaiian goose, Hawaiian Petrel, Band-rumped Storm-Petrel, Hawaiian Stilt,
and Hawaiian Coot, and the threatened Newell's Shearwater."
This information will be included in the Final EA Section 3.13.2 and Appendix C.
The Na'alehu wastewater treatment plant PER is not a part of the Draft EA for the Paha la Large
Capacity Cesspool Replacement project. Comments related to that document are not pertinent to
the content requirements of the Draft EA for the Pahala Large Capacity Cesspool Replacement
project.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
#58 , ^
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%ui,r • if Ml. Re|H.M«*ion Mailt* te# Oh* bttmrnm# hsmammv'fmimfmmi ft«l®} al
Bo Sifsificasl tmp*t tat Mills Cciu*i*if»«l|* tiff* €«*% Ctttpoof tepWtt'&e*
I hope s«!» Mills! ibe "9* wiBte».»s« v.w (nggetf
II iwimlsl 1* ipteiHifOiiirtty l#t tit' n, - toll J't -PI ••.hi," |>- |. < M >' I,.,
t.tti tmiay, mm*M 7. an* w.M-f r tM miAwMMmmr- %*mw,
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-------
WILSON OKAMOTO
COUP T t § II
10349-01
March 6, 2020
ref (58)
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment - November 2, 2018 12:14 p.m.
Dear Ms. Demoruelle:
Thank you for your November 2, 2018 12:14 p.m. comment message regarding the County
Havvai'i Department of Environmental Management's (DEM) Draft Environmental Assessment
(EA) for the Pahala Large Capacity Cesspool Replacement project. Our responses follow:
Hawaii Revised Statutes (HRS) Section 343-5 Applicability and requirements (a) states "Except
as otherwise provided, an environmental assessment shall be required for actions that: (1)
Propose the use of state or county lands or the use of state or county funds..." as well as, "(9)
Propose any: (A) Wastewater treatment unit..."
However, Hawaii Administrative Rules (HAR) Title 11, Chapter 200, which implements HRS
Chapter 343, differentiates between "agency actions" - those proposed by an agency to utilize
state or county lands or funds; and, "applicant" actions" - those for which an applicant requires
approval from an agency.
The Pahala Large Capacity Cesspool Replacement project is a proposal by an agency (DEM) to
use County funding, thereby "triggering" the need for an EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
10349-01
Letter to Ms. Sandra Demoruelle
Page 2
March 6, 2020
cc: W. Kucharski. COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
f#64 i
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Piliili wimtffwiitiic liBisiffiiittt Ite €fet€®..
Sinoli a pictaifS' plant fh*t >m*M t» ndnqunte le etow it*» Pnhti# iOCi would cost srouotf *• bwhim
(in 2012 tiefiiiis) p»t tta nhMw »bwmb* WMmaiw imtmsntantf DapoU!
System > ^ » jPFK .i I - 20131, fcl» ttplioin sh. ,• I,".- i,v». I'M' I. .*<».
alternative. i aft© *»©uM require ftr itis lani an*| woiiicf w t*mm » ¦»» <»«t«ntr»g ICC#.
Sines- paciap# plans am modular, capacity could m aaaly expauad fcf future www nv in* junkm?
iww units,
Th# a***! «*t to# aludga removal and tteetftely would f* far «•-#«, by tha s»in# el $10 mMm in
borrowed 8RF funds,
9m mm*M mkummkm m the Maiislhu WWIP PER.. TMmk ywi for eewftiitinf tin#
packigatl plant options m »ow upcommg its,
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-------
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LSOM OKAMOTO
BPORATIQK
:> „• 4 t o 3 ;s . * i « t N i H ! I *
10349-01 ref (64)
March 6, 2020
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment-December 10, 2018 2:36 p.m.
Dear Ms. Demoruelle:
Thank you for your December 10, 2018 2:36 p.m. comment message regarding the County of
Hawai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our responses follow:
Hawaii Administrative Rules (HAR) 11-62-24 (b) requires County wastewater treatment works
to be designed in accordance with County standards. If a county does not have design standards,
then the design standards for the City and County of Honolulu shall be used. The County of
Hawaii does not have design standards; therefore, the City and County of Honolulu standards are
applicable to the Pahala WWTP. The Draft EA Section 2.3.1 states that wastewater flow
projections were developed for the treatment and disposal facility using the City and County of
Honolulu wastewater standards, most recently updated during 2017. Based on these standards,
the Pahala treatment and disposal facility would be designed to provide an average dry weather
flow capacity of 190,000 gallons per day (gpd), which would be sufficient capacity to allow
closure of the two LCCs. The Draft EA Appendix B contains additional detail on the flow
projections. The corresponding design peak day wet weather flow is 650,000 gpd. Future sewer
main extensions and subdivisions will be accommodated, as capacity allows, on a first come,
first served basis. Further, the wastewater treatment plant (WWTP) design will be expandable to
not preclude treating future average dry weather flows up to 360,000 gpd (with a corresponding
peak day wet weather flow of 1,260,000 gpd) to meet the future needs of the community in
accordance with the requirements established in the Ka'u Community Development Plan Policy
120. Tliis information will be repeated in the Final EA.
It should be noted that wastewater flows from a community are highly variable, and peak flow
rates from small community wastewater collection systems are typically three to five times
higher than the average flow rates. The City and County of Honolulu standards take this
variability into account, and application of the standards results in conservatively-designed
facilities that are protective of human health and the environment in anticipated operational
conditions.
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii • 96826 • (808) 946-2277
-------
10349-01
Letter to Ms. Sandra Demoruelle
Page 2
March 6, 2020
This information will be added to the Final EA.
Package plants are pre-manufactured treatment facilities that may be used to treat wastewater in
small communities, or on individual properties. Typical flows for this technology range between
10,000 and 250,000 gallons per day (Metcalf and Eddy, 1991). Although they have the
advantage of a small footprint and associated capital cost, these plants have limited storage and
equalization capacity, require the addition of chemicals, and are operationally complex. They
are energy intensive, and the solids produced must be properly handled and disposed. Package
plants do not commonly achieve denitrification or phosphorus removal without supplemental
unit processes. Often, package plants utilize proprietary equipment adding to operational costs
and equipment availability issues when replacements are unavailable or the equipment becomes
obsolete.
Because of the need for daily operations and maintenance, on-site chemical storage and chemical
addition, mechanical complexity, lack of operational flexibility under changing conditions,
energy consumption, and sludge handling concerns, package plants were removed from
consideration for the Proposed Action.
The above information will be included in the Final EA, Section 2.8.2
Regardless of the treatment process, the proposed treatment facility will require a method to
dispose of the treated effluent. As outlined in the Draft EA section 2.3.1, the Proposed
Alternative will utilize a land application system. As stated in the Draft EA Section 2.8.3,
several effluent management options were evaluated for feasibility as an alternative to land
application. Options removed from consideration included ocean discharge, injection wells,
water recycling, and drain (leach) field. Additional detail can be found in the Draft EA
Appendix B, Section 3.1.6.
The Naalehu PER is not the subject of the Draft EA for the Pahala Large Capacity Cesspool
Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
10349-01
Letter to Ms. Sandra Demoruelle
Page 3
March 6, 2020
cc: W. Kucharski. COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
Earn
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m rnrnm mm *m ***** to wepa ma nhpa/esa mm m » m », 2011. *»»*» m
1 > ,' i' I H'1, 'I M . I'.i ' i , • 11* > It 1 ' >i d the EPA Grant'if tl> \ % i,'
torn the iteilijhij Prqject to evade II* tows (see May20 ti amendtoem i ji.uicfwrt).
I ¦ i.""t«rs»*din»'. I'i, I L-i L. ,i[. 1 I NEPA/HEPA/NHPAfESAforthebvki
NadWiw/Parate wastewater treatment plants tlai Or exceed «»taxable value of •« housetoto being
ilisicirtriisetiCi from Ills ICC*
for example. the lis hewselate Mart « the KagMw Revised PfR (Sum 2MI> thaw a mm* vatee
,'M- J : : V w I, l .I»ul«i*!f tiiiOH '-U . .rd«rS» million - and the COHDLM »W,» to
lajuottd $40 & ns'lliuh (and tHi'isbiripl uu
ftp' .t: W .Si v'i tU n h'l, , | . , | • >* . JH
taxpayer ahetw M.«ck *#t Those e*i»i»n*-te«*iefftes. ittat m one mm even prepefty comment
- « 1 l \ n » * > > - "Ui S " * ^ :» ! . rK' r- tn <•
The mhpa e»u»»ti€« en she Prc»j«t wm done t»st% ««J wWkmc »i. > . on 11 j ' !. 'tsiilling party, 1 could fwiti sdviwd II* COH
ma EPA cm prepef mfxxSmm m* helped »»«i •«¦»» resiiiwis so the ten! HmlM imfciiiah and
groups, as mm •mm mm lietort m *m*t 9m. 1« was Mowed » tomm
Hewew. i» ®ne Iwm EPA. COIIOEII or any of lh« ©emteelw fcas «m asfc«l to e^tfen er my
i'' «m* in any t«i|ptii. it * .< • • »«> i" >i " 1 t " 1 " »• n 1 • mtfoammm
!>.< I i i. 'ii,\ c »*ij who should have been I n i >, CL'I-IJEI*
had totaled (he CDP Bialiites ft* &% and «oughi «ir help uplrw!
Sinwrwly, Sandra
OB Monday. Ownmtm* ia P« HIST, NmWwIImmM «».»»»itt«®»*€#pliaee®ii» ««•
At the October 10.2#11 Mute 06*. n*s<»g, I $|»««fcsit!f «sh«^ the Brawn ma engiiww,
'"¦I i L "f •, i'" *( I-,D<» , ji ti^ ,• N. " i> V •' % v . '¦.ft I i wnicipir flaw, and h» >> } • t
Ihsii: ii wits.
II- ,s .( \< i,- >! V'.' ... I « I It - SIMH W«tt..¥4»f fiMMS irai'.-Wl ' „ .,1
"fi . r-v1 •" I'm: 1 • « «!'. •!¦.. ."I. 'tptanttuMFe
dlunit1 tttilim ¦ * ••: ¦! '1 t'l i' . • ¦ 1"!. i- I ' , < I ,v ¦ ' I I-. I v ' ' I {.5 — ,li .•'
|sn 2©tk IIk VViii»Mt*di«i34 I ifid t)*ipowl
Revised PiR tMm 2®13), 9m ®p«on timm m &*m mi ecwii«f«#en its a cost ©»©«i«
iiBtsriiiifii, It alto would <«!•• v ' i «> a I .v • 'U •« Mir.- •> JSCs.
S^paekapM^MiramocMar.ca^e^roeRil. - .t . « t • mm i .v,i *• i m p -
niiiw iini«.
Th® athM co$t ft* si«l®e romnwu mm mUV he tor by the ®i»»'inf off to ifiiiitin in
tiemMHKl SWF tanlti.
See attached nfotmafton m •» Ma«#»u VWVTP Rev«ed PER, Thank yw» lew sensxli.' .i'kj m
commg BC.
9mm Denwnme
brtirved to Ik clean.
-------
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34?
-------
WILSON OKAMOTO
COUP T t § II
10349-01
March 6, 2020
ref (65)
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment - December 10, 2018 3:01 p.m.
Dear Ms. Demoruelle:
Thank you for your December 10, 2018 3:01 p.m. comment message regarding the County of
Havvai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our response follows:
The Draft EA Section 3.15 states, on March 29, 2018, consultation was initiated for the project
under the National Historic Preservation Act. The Draft EA Section 10 provides a list of the
consulted parties. The Final EA Section 3.15 will include that the list of Native Hawaiian
Organizations (NHO) was generated by the EPA from the U.S. Department of the Interior,
Office of Native Hawaiian Relations, Native Hawaiian Organization (NHO) Notification List for
NHPA Section 106 and HRS Chapter 6E compliance. Letters were sent to 14 NHOs during the
pre-assessment consultation. No responses were received from these organizations.
On March 13, 2019, the HRS Chapter 6E determination and Section 106 review packet were
submitted to SHPD along with a draft Archeological Inventory Survey (AIS). The SHPD
response is pending. The Draft EA Section 3.15.2 states that prior to finalization of this EA and
initiation of the Proposed Action, the Environmental Protection Agency (EPA) and the County of
Hawai'i will conclude consultation with SHPD in accordance with Section 106 of the NHPA and
will incorporate additional impact avoidance and minimization measures as necessary to result in
a finding of no adverse effects to historic properties.
The Final EA Section 7 will include that on September 26, 2018, a public notice was published
in the Hawaii Tribune Herald and West Hawaii Today newspapers. The public notice was to
advertise the October 10, 2018, public information meeting conducted by the County in the
Pahala at the Ka'u Gym Multi-Purpose Conference Room to discuss the availability of the Draft
EA and process for submitting comments. The notice stated the second part of the meeting
would address Section 106 of the National Historic Preservation Act of 1966, as amended (2006)
involving consultation with Native Hawaiian Organizations and the Native Hawaiian
descendants with ancestral lineal or cultural ties to, cultural knowledge or concerns for, and
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
10349-01
Letter to Ms. Sandra Demoruelle
Page 2
March 6, 2020
cultural religious attachment to the proposed project area. Eight persons placed their names on a
sign in sheet at the October 10, 2018 public meeting to contribute during the second part of the
meeting dedicated to the Section 106 consultation. No comments or information were
forthcoming during the Section 106 portion of the meeting.
The Naalehu projects are not the subject of the Pahala Large Capacity Cesspool Replacement
Project Draft EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
C #66 J
J*-™- woe 12-12-2018
ws Mo.xU-,, Btawwbw fix 2§1I IJf f*M
• _ ¦¦ ¦ II jj
CC SMMHMM^nmSMCVMWmC ItSSAKRMAMtOWW
I«ls»»}hi;: c«»lf Wwwi
s . t. >.» • !»»*#!• WM9* Itaw MtH not (fctiiliixl
The engine* fall to justify tn Bxtnwwfy tiig~ P.tm1 '¦ rates «Mch sfcrcmiltl hn.r }• i> •.
teMdortCty *nd County «r Hi**.'1 ,,m»>h.h ,vk, » Fiowra».of 32®
flMparM(tfH*»' . > »a ? • j ' it 1 i 1/).
Th» LCC ctwur* onfy #nwoimmMb Iran* arounda hundred iwutsnonJi, ao m now Mt it*
tCC ciuuit i . 1 ,<• ... lutitf 32.000 fjM .1 >. . n 'm.1- • ay eriiiw lwo»m»I
packaged plant*. a*wij|lt%' modular lo accommodate § rmm, m% a vary snal footprint el land wilti m
nOKiiCMf «i«S. I lit Dec, 3, 201* TEW Ihiwrt .1 (.oitiiO unit 4 flow rate t>f rt.OSQ yhi handltd
bf * ranawnia pacnagad plant w*».imKU f <¦ -utter i »r i of ihi-sv> The« wt*.tv .«t.J
Ka'u taxpaywa »m notftlCM Now can *» afowl your grandkM* plane I# tpand 111 mlUm on
two $21 will dollar tewm?
Plus, it i» susiiietoiii ' ' n *• r l I ..- I t ' r\ ' . 4 " '! 'I .1. .1 . * . n I , it" i Mil 'i " " •>. >!,
Council Ax* not care afcoul spending to c»« tor* liflsMfcit audft
Unforhmalefy. with tha twin WWTP projecte lr» Ka'u, •» money ta» tamrM mam firwitif ItaR If*
Smdfa Oenimete
i
LSOM OKAMOT©
ItPORATIOK
:> 4 t o s ;s . * i ^ t « t N i H ! I *
10349-01 ref (66)
March 6, 2020
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Hawai'i
Response to Comment-December 10, 2018 3:29p.m.
Dear Ms. Demoruelle:
Thank you for your December 10, 2018 3:29 p.m. comment message regarding the County of
Hawai'i Department of Environmental Management Draft Environmental Assessment (EA) for
the Pahala Large Capacity Cesspool Replacement project. Our responses follow:
Hawaii Administrative Rules (HAR) 11-62-24 (b) requires County wastewater treatment works
to be designed in accordance with County standards. If a county does not have design standards,
then the design standards for the City and County of Honolulu shall be used. The County of
Hawaii does not have design standards; therefore, the City and County of Honolulu standards are
applicable to the Pahala WWTP. The Draft EA Section 2.3.1 states that wastewater flow
projections were developed for the treatment and disposal facility using the City and County of
Honolulu wastewater standards, most recently updated in 2017. Based on these standards, the
Pahala treatment and disposal facility would be designed to provide an average dry weather flow
capacity of 190,000 gallons per day (gpd) which would be sufficient capacity to allow closure of
the two LCCs. The Draft EA Appendix B contains additional detail on the flow projections.
The corresponding design peak day wet weather flow is 650,000 gpd. Future sewer main
extensions and subdivisions will be accommodated, as capacity allows, on a first come, first
served basis. Further,, the wastewater treatment plant (WWTP) design will be expandable to not
preclude treating future average dry weather flows up to 360,000 gpd (with a corresponding peak
day wet weather flow of 1,260,000 gpd) to meet the future needs of the, in accordance with the
requirements established in the Ka'u Community Development Plan Policy 120.
Further, The Draft EA, Appendix B states the proposed treatment facility will accommodate
modification within the proposed 14.9-acre site for the future expansion of the service area.
It should be noted that wastewater flows from a community are highly variable, and peak flow
rates from small community wastewater collection systems are typically three to five times
higher than the average flow rates. The City and County of Honolulu standards take this
variability into account and application of the standards results in conserv atively-designed
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
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10349-01
Letter to Ms. Sandra Demoruelle
Page 2
March 6, 2020
facilities that are protective of human health and the environment in anticipated operational
conditions. This information will be added to the Final EA.
Package plants are pre-manufactured treatment facilities that may be used to treat wastewater in
small communities or on individual properties. Typical flows for this technology range between
10,000 and 250,000 gallons per day (Metcalf and Eddy, 1991). Although they have the
advantage of a small footprint and associated capital cost, these plants have limited storage and
equalization capacity, require the addition of chemicals, and are operationally complex. They
are energy intensive, and the solids produced must be properly handled and disposed. Package
plants do not commonly achieve denitrification or phosphorus removal without additional unit
processes. Often, package plants utilize proprietary equipment adding to operational costs and
equipment availability issues when replacements are unavailable or the equipment becomes
obsolete.
Because of the need for daily operations and maintenance, on-site chemical storage and chemical
addition, mechanical complexity, lack of operational flexibility under changing conditions,
energy consumption and sludge handling concerns, packaged plants were removed from
consideration for the Proposed Action.
The above information will be included in the Final EA, Section 2.8.2
Regardless of the treatment process, the proposed treatment facility will require a method to
dispose of the treated effluent. As outlined in the Draft EA section 2.3.1, the Proposed
Alternative will utilize a land application system. As stated in the Draft EA Section 2.8.3,
several effluent management options were evaluated for feasibility as an alternative to land
application. Options removed from consideration included ocean discharge, injection wells,
water recycling, and drain (leach) field. Additional detail can be found in the Draft EA
Appendix B, Section 3.1.6.
The Naalehu project is not the subject of the Pahala Large Capacity Cesspool Replacement
Project Draft EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
10349-01
Letter to Ms. Sandra Demoruelle
Page 3
March 6, 2020
cc: W. Kucharski. COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
[ " t 2
yi+-
woe 12-12-2018
pec-ia*2eio o«is« joe. iiieno«ueLf.e *¦••!
ro; va^r^TOl&SCTI,u'c°t"'."1°". '
TtiP fallowing <*JC prtrvid^the Con I pictured in Figure 5-1)
Ij Lritl iCoflH hwsehoidt o" UX*h B^twggnjjB,il7,..
i3X.059.53a
j) Omorue/fe v. 8rrk evidence of misconduct in following NFPA/HIPA
i. Original joint Naalehu/Pahala EPA grant funding tiwrlng NIPA/HEPA |s«
Section Pi)
b. EPA grant payment of $133,853 on 1/6/2011
C. Dora Beci signed Federal Financial Report for Joint grant on 11/7/201J
leaving grant fund balance of Sl.7iS.297 j! of that date
d. Naalehu ICC ConvcraHw Schedule of Del I* wables for E PA rant payment of
5133,853
e. "Pahala Grant Work Plan" dated Apt«l 21,3017 that does not show the
S133.&53 payment made In 2011, showinga continuing original grant funds
payable balance of $1,842,150 jftd stating that all Six grant amendments
were for the Naaletiu protect with the separation of project* to only
Naalehu 0*' Dora OttMfi May 2009 Work Man
-------
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-------
WILSON OKAMOTO
COUP T t § II
10349-01
March 6, 2020
ref(75)
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment - December 10, 2018 4:38 p.m.
Dear Ms. Demoruelle:
Thank you for your December 10, 2018 4:30 p.m. facsimile comment message regarding the
County of Havvai'i Department of Environmental Management Draft Environmental Assessment
(EA) for the Pahala Large Capacity Cesspool Replacement project. Our responses follow:
Pages 1 to 13
This is not a comment pertinent to the contents of the Draft EA for the Pahala Large Capacity
Cesspool Replacement project.
Page 14
The treatment and disposal facility for the Pahala Large Capacity Cesspool Replacement project
will not provide treated effluent to reuse quality which could be used to irrigate macadamia nut
trees. This information will be repeated in the Final EA.
Pages 15 to 19
This is not a comment pertinent to the contents of the Draft EA for the Pahala Large Capacity
Cesspool Replacement project.
Project information, including US Environmental Protection Agency (USEPA) compliance
dates, project updates, schedules and milestones can be found on the USEPA website
at: https://www.epa,gov/uic/coutity-hawaii-admitiistrative-order-consent-closure-cesspools-
pahala-and-naalehu.
We appreciate your participation in the Draft EA process.
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
10349-01
Letter to Ms. Sandra Demoruelle
Page 2
March 6, 2020
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski, COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
-------
prrrr^)
t #23a i
COMMENTS OH THE DRAfT EA, PAHAIA ICC Rf PlAfCMrNT PRCHFCT
woe oct27-2018
SUBMITTED TO;
Wilson Oiamoto C#ffWfiit§©ft
1907 South Sefeianla Street, Suite 400
Honolulu, HI 96826
Fa*: #38/9*6-2253
SueMITTEOBY:
Sandra and Joseph I
to* sti
fiiiitelwj HI 96772
Comment:
$** attaelwl comments ana supporting eviifence that follow.
Signed in Naafehu, Hawaii m October 21, 20X8
, k.<< • I" ' '• *"-.•> w ' •'
s Sa I r - saa|1»
l)
Sandra L Oem oruelie
COMMENTS ON THE DRAfT l*» PAHALA ICC ttlWCOWNT HtOJECT -
Mr, mil Mrs. Deniowcllc, forty year residents of Ka'u, point out thai it is tie
public's duty to raise issues.
They miisi doiinguiah themselves by their opca-miaiJeilBcs, fcir high
aemm of justice and duty, by eamdor, modesty m& iwir entire devotion to the
welfare iitcl interests of their community and humanity. lie truth ihey mm will
become clear and evident to *11. They are speaking the truth and never entertained
hatred toward anyone. Their soil purpose ift speaking out about the ICa'u LCC
Closure I'rojecl is to stale ifcii truth ami ewmun liie situation.
Our Ka'u community, to a ixxly, strives to the sprit of cwliisivoiess and the
Counts re » «* of secttcy to curry out their domineering
Kl"i iv* -
collaboration with members eftn Ka'u community, ihe common-
sertse and good judgment of people who reside here, I* County and EM- Ills led
» poor siting Axisiwis in brth Mate and Naakhu.
Lacking any reciprocity. tlwrt was no thorough exploration of issues to seek
unity of vision. There has be* i» spirit of inquiry into mm is best icir all
concerned.
-------
Ctenmruelk.- Pjkc J
traarscf, is!.;- people of Ka'u who speak out line bdittled, humiliated* insulted,
ignored, and generally act accorded courtesy and respect.
We urge the mm of consultation to amemm tiua mmm ot j»wertiSai«,
Hut cciBiBlwiiin Is mil an isolated event. It is a process that allow* participants »
grow more capable of fostering collaboration.
There are two types of «j*«.nJt»t»rc
1) between equals fcinlii i like Ka'u CDP Policy
9© envision* (supported by toft parties), and
2) decision being made by those with authority - so wm&atkm takes
form of discussion to draw am thoughts and information towards lie enrichment of
CSWfTilfflitSIl i k'i -.a,, "i' li • . i > v- > -Mction i.i- t, -vi«' n ,t:< *
ad of goals, tail individual and collective.
"i I in'-,!!* ws o! . •• i*i ii J",a,,., '• -ifllf preferable to one man,
tiiti «$** * "V ri'w.'f m| number atom ii#fe®or» it,- .'i n t'n wnn-t •»! we
iBiM," (Cited in si tefler written by Shoglti Eflendi to the National Spiritual
Assembly of Persia, February 15, If 23).
DemorufHi* Pagn S
Therefore, the Demoruclles recommend the vm of consultation »>¦ and
within the Ka*» community to investigate reality mm mm awh, convinced m mis
hi, 'lv r\'^v r > • i,;ii i," -i-
wl-H I'M ULCI itiL IIUiLAi Oi MlLM, Ift lili
SCHOOL
We sure sick of seeing blameless children used as political pawns to allow
Director Kuchataki to place the Naalehu WWTP on lis preferred sit# and use fit
school snc es ass Htitcmative." Iway discerning person can see the need far justice
for Ki'ii?
We don't know if ti affects everyone in the same way, but the
lia*ir®ni»eiiiiil Management Cmmmmamm appeared visibly bonified to see «
iiiiJergMei ctawrooro beside the open sewais iwxm,
"All i wwii m vm* horrible place far my gnai-gaiMfciii to
drown..§» what Sandra Deuwtielfc thought when site aw the
Brawn and! Caldwell presentation on April ll,2GlKatthcNaalehu
Community Clubhouse. "From the moment I saw the project last
1 I ,*¦ l- i |„' .11 » "I *,i li . I k t.MI ¦> I' ' . **1
ikc,a>w mey denied m any access to the Ml*, it remains unclear
hem iiiiicti this tetorism hat con a in %»iiie4 tax iolltft and cl»«agc
to «tr community. We iiiit -> who wilt make repwtfeiw to Ac* §&»"«
1.CC homeowners? And wl*> wilt p=>* as for lie personal injuries
earned by the County''«lerrorislk tiia»iii|wlalkliis.w
-------
Drmorui B.-P,.*;.' 4
Surely we ,,"c , i. n: ncmntenl witii COHDEM Director Kii«liif*ij thai
to iJtpiriitiMt "kave bM ¦••»!% i» doing their ilirty to ill* eavitvitmem
and »®«l resMeiits,** Let m be crystal clear, Mr, Kurt*
taxpayer-funded CCH IDEM, (EMC, 4/25/18, Page O).
i
taw to I* requested and paM fart
3) ..y„;v i, i >!• mmmi. » !«'-! -V «-V, oi,nth , ,«ii,..|Cijiui»lheCDP
statutes were followed miiti a, large RD grant funded Lock* Kona, white the 2017
It'll CDP makes no mention ©("either WWTP, nor mm Policy 9© far public
participation followed.
•I'V.M.mtru'U , i V NKI I ",s'i k tV, »\ "A j I1';
Kama. iitmiseWds voted to ps»>« the balance of the LCC cIemoifc costs - wilh ED
granl fi'ti . r . j- in.- I i" o | :>.*v, w»i c, E*cef» fewt sum!•ii»uu!of
remain. >ur • " \ \ M' ,¦ . t-i! •« •, ' • "IIH pay for tie
two WWW projects will* CWSlf Slirtiirif, wiilwit m&ntrinf and satkhig
-------
emUittfUf He 0
piitScipnioi from Hawaii lap; din* sigiiitlcam BwmcW
s'¥"' l"1'•' •••' »•"•«»*• (< .lll'-HM met Willi Lunolotia
stakeholders early ml made public records available tor mmw, i« Ka'u. llic
COHDEM nail EPA fluted to provide BUS J4l or NEPA notice in TEN for ilie two
going to happen" (Kuchnnlu. EMC April 25.»««, Page 15). No B/VB8 Has
been published for the Nwfetw CWSRt funded project
we Lam Ktirm's meeting records indicating who was present and the meeting
¦periil* and outcomes, lite COHDEM refuse* to premie any meeting Infanailfc*
t* environmental mkrm records (except the PEJVDEA) to the local
libraries or online. By denying accesa under Ul PA, lie NanWiii OKA has been
withheld since at least April 2017 per the ACM," Attachment II 4jirc 3 ¦tuieraeut,
I!iicferf2l*-i2, Mrs. Dentoru*lie'$ request that COHDEM skill mate
available foe pMc inspection wl thpMe* during your regular Mm howre
(3) government purchasing information {10) consultants (14) emmmam nat ocen
denied. &» also, 92F-15 denial of record).
8
OcmoruclU.- P.ijjc 7
FA It » HI. Mi IH) aN IIS OK TWO KILL-SEE WWTPS (II MI. APART)
ALL HAWAII WWTP* HAVE A HRPA EIS:
1996 Waifilua - lilleiwil WWTP
I«i Waimanata WWW
2009 Kotoft-PoipuWWTP
2010 Watale Water Treatment Facility
2011 KiiBcelie-ICsilu* Treatment Facility
2017 llonocilittli WWTP Secondary Treatment
JSMtlT leiliikfiiie WWTP 111
Tli* EJSPN Act 172-12 Direct to EIS would mm been the appropriate
choice instead of this Pahiito DEA, sine# all n«w-bulte WW I lki have required m
tit$. In Act, MRS 11-400-12 and U|siffi-!i. ,."t • !>ti -i.,i t.-.j.i,!.- '-M ,i 4 ii, (. -
snow prior MBSultslittii; conBiiiftity mating record; notice of public hearing;
record and affidavit of piiljlfcalioii, which COHDEM/EPA have MM to do.
Nowadays, i is toil to find an environmental suit where rtoNEPA EIS
document wa mm produced, Now, an me suits do is challenge the adequacy of
-------
Darnioruellu Pjge 8
the EIS document *• . •.!, ; , I'public review. IM 11 » i" i .nK .> , >*M.>
tlw 1970s mi catty 1980s, «*» thcw.-i.st. M i'.v... rt. oM and the EIS
m$ a requisite early guide to it is,
HARM TO THE KA'U COMMUNITY
, iv . itizcns of KaVineln.i , v >•i, *••>,!< 1 "M, lie, have been
significantly harmed by COHDEM and EPA Mure to incorporate environmental
review from the initial proposal of tie WWW projects In 2M2 PFJM's CIP 2012*
13 Hn»Wi 11..-.- ... -v. siiji'ty in iictltat is timely be iiig pursued and which
will I* remedied fey a tawauit.
s sw- tiPA mil County m making an irrevocable comroitmem ofrcxnirccs to
place two foil-sized, new-build secondary wastewater treatment plains to tew it*
about 300 hornet to tmm. nw»J KiV J to* is • commitment of resource! oor
comraumty holds sacrwd - ss Noli®# Xitaw® testified,, her family sst) ¦> "m -axitix
eplicei " (County CmmeMmimmf on Ra. 65§-UJ).
There areredressable injuries fraiti t final agency decision, by EPA hi Mend
compliant* 4mm mm which EPA RS> esest«s authority and
aver the pirn in', „ut>» m "i-m..- iib mm the K.s*ut WWTP Projects. Federal
10
Otmoruqlle PsgC 3
fcu ' 111 . ".';n«. .vl&omthc'-.'iM'.'M's'oi i'ivM t uJerNEPA42
use 4321 et so).
There fciii been »n ongoing procedural violation under HIS 3411 which
require preparation of notice wil ounce, intent; commence
public outreach wiii notice of holding public meetings iinsl soliciting public
comments; consultation of Federal, State. COM and Others - businesses, NGOa,
orgsiiialkms, and individuals; and finally issue a DMA.
In fact, the Project Schedule required meeting in Majslelai by ! iQS/fil) 11
ma smut hive occurred in compliance will lie EPA June extension approved by
MRS 341-1 requires EADs b# made available for public inspection,
providing transparency and avoiding [wte.nl k»( ft* deception. By denying any
access to liie Nailefcu DEAi, there :m wen no opportunity for public review and
comments.
The Pahala WWTP Project was separated (torn the Naalehu WWTP - and
EPA SAAC grant funds were transfetned m Msy 30,201%,» i»nli«hi mm Nmilchii
to evade NEPA review. Since late Rao is wwt®-, r i • uku . 11' I v\4gr
hasn't she dene one far Ok Narfdw project
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11
Demon*!* Page 10
As demonstrated by the November Reaoluiion 412-17, t m„,«. i> »A h •
irrevocable mm »c,*,n ~e'we «» environmental review of the primwei WWII"
action Mr. At the time, the Ptliala iatull i k*n consulted on
this action.
Without consideration of alternative ae«lw»;., se-w can, enlightened decision-
¦a fas make intelligent, optimally beneficial decision be made?
Soc. W2I21C) {42 USC •€!»<2XeJ] 'irate tr.st a iirftiilM aaetiw* ofimpact
0® »t» environment, environmental enatt and alternate mmmmm, A detailed
statement is t upposed ® "aecorap any the praposa! il>, «„<11. k o.i t..... *y
|W*A an tAitiiMMl review pwcesscs," "lie procedural mmh respire the
environmental review mm wrly to accompany the project step by step. Tbm, far
im m as in iCii'u, ifce persona1 iiipry hde/a&o caused by violation ofNEPA
procedural slaloies,
HAR I i-2' Hi ! '1 ]i-• ,>.;•> 41,! ,S Iv w jvr ,1 . 1 ilea appenumty in
pi mii-i smili i»« im> merely * »] f-serving recitation of benefit! and « nlisiitlalkMi of
the proposed action, as Mr. Kuchnrski stated 4/25/2018 EMC Mimms.- iltTti w
"in formed" a WWTP was ping » biippen - siting was being determined
12
As the Kate ICC Closure Projitt started ax a Mfigje action, it was a violation
of MAR U-.<:wy-5 i« aotkisw «* project* into two WWTP Projects and full to
consider theni .<» "hr;-.; i."'. >1 n ,>!. t! hi < „< . In tl.i! * .. >rs, I.- • i • must be done PRIOR to
preparation of »PEA to amm « till arid complete consultation process - and not
« \ vu| I j 'i . ¦ < 1 nvieu | •. v n «•>...,« i. vr<.<>< .5 concerns.
Wist is needed is reparations to nil Ka'w LCC households - for homeowners
abandoned it* original agreement leaving homeowners paying iw semap Am is
STILL pit,sett in their backyards (in aging pipes).
Since KPA ma mw *utp m stir envifonrBtiuiil review when it mm triggjsed by
> <„• il. m i iviiiiiu' >• i . , »"<¦ won't in (lie future, Al the October 10,
2f* ' .V»,.»ln Vno ' >. ¦> . "-i -ttt that the County w» without concern
for everyone affected. Therefore, the DcsnonieHcs mg/m torn, pr B* t&mm* of
the November 5,2004 County letter, LCC households need to stop receiving sewer
kills, ».>i t '.mu |> until tl*i new sewer •> ..'ii, -n taliarimi
accepted by Htwiil Stale DCiH, To bring tatter ceimillalion wtfee pmem, ptar
K**u COT Pctlicy ti, IJSIM Rural Devetopmeal shtwiii liKililate femsliaJ
«»iai«iaft»iy mteiiiip te coiisi-cler dteaiilivei, including the erfgM oorwmsIoa »
sejilic,.!# clcsw it® LCCs.
-------
coMMiim cm we draft ea, pahasa loc rimapement t*neȣcr -
OtffiWfud'It Pjj?c U
ATTACHMENTS:
Wastewater Treatment Unit which is total* misleading.
8, Patiala meetings Oecember ll through 14 2017 emphasized the
importance of COST consideration, vet no analysis of the ecoioinle Impact of two
HMtw cwsw lows OB the COM: credit or repayment abilities, and no impact el
costs en the Pahala households,
C. The P'lihah DSA list of pn^nn failed to list the "outreach"
,.:.....ocs,
D. The WA and COHDEM conspired to move tie CPA grant funding to fahata
on May », 2018, i»«J cause the M»Mhu Project to no longer be subject to NEPA
and erossaitters icie, HHP1* and most importantly ISA. Therefore, Sandra
Ummfw (•;.«.>«notice «f this ISA violation and will file her lawsuit In HI# en
November 21,2011,
i, it* community plans to file multiple lawsuits, which may tapitt the
"nipperf* between til* project Wm »MI the Kg» residentt-
14
Demofuci'c Page 13
1-^00^*
F, The com of the Kealakehe wwtp Isjfi liner mplacement ran so much am
toilet, III# $14 mill ion budget far the Fahaia Project is frossly underestimated in
It* PES, And sine? the mm is the most important project in Koni, why aren't
the Ka'u two WWTPs treats! s$ Inpnm end provided with an HS?
6, The falitli OCA shows th* mw fllW is do* to tkt school, but the
Naalehu DfA has the Naalehu Elementary School as the Wast boundary of the
Naalehu WWW Project. Only one school on Hawaii Island Is atoM % mite from it
sewagetreatment ri,Pr m «..-nol* School is u »<•,-» ivy .y, How far is
the WWTP from lit# f Asia schools?
if. mbotmb W armm Kticwsfci, the Naalehu School is stil the preferred site
far the Naatehu WWTP and it H only II miles away from the Pahala WW
proposed site.
I. Tfw Paws utn ffcet m consideration to any decentralized, more cost-
effective project fcr rural aw® such as « Ka'u. Also, no consideration has teen
giverv to seeking any other ews« ot tsiniingfor this dearly impoverished lire®.
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15
(tamortieM« f»»g t W
I. Dating A® May 1410l«, "team update call * the §M and €GH cerapM
with the Conl«ct®n to matim the Stile of Hawaii towj Use Commfsslon (lilCJ
review of the Pahata Project which would be a "much toupt pr«*»" by stating
the site acreage under IS acres. See See 2®S-6|ci) ftj#t*hittil requiring sptciil
ItIC permits for lancf area greater than 15 acres. ft« the Pateta PuwctwuMi m
this MA is «i *I« ant ag ricutturai lands,' so rtgariltss of
site, the Project »il be subject to the UIC ptnniMf promo.
16
COMMENTS ON THE DRAFT EA. PAHAIA ICC REPLACEMENT PROJECT
woe oct27-2018
SUBMIT ifcD 10-
f.Hil SVyisukcHva, AttP
Prn(t>it
Wiiwirs OSwmoUt Corporation
HO / South (ioMarnd Strppt, Ssiitf 400
Honolulu, HI 1C82C
M*' sn8/°'Jfi-2253
SUBMITTED BY
Sandra and loneph Demoruellc
Box 5S8
Stotehu HI 96772
Comment.
beo an ached comments <-md suppoitmR wiiitwe that toHow
Signed in N.uleltti, Hnw.w on Orlnbcr 201 is
!"tt- i»v O^l \\ f
'i.nidrr. 1. DwioNieHu .'ifWopAl IVmofuflH1
-------
roivwtmrrs ok tw draft ca, mmai a i re KfPtACFMFWT raoacr -
Owivuiuulic HaK<-' 1
Mr, aiict Ma. Demoraeiie, forty yew residents of K«*u, paint out ilmt n m tne
They must distinguish themselves by tl»»i|l
kMK clear tod evident to *11. They m speaking line talk ml nmt «tertiiiieWtiPcl iflyortc. nidf sij1*!1!? ptjjrjMj&ts in cwi. iilxuff tltts 41 LC^C,.
Closure i»rcij«i to to a»» the truth and explain the simtikw.
Our Rfi'ii eomiminily, at * body, strives«®the ifiril of"cxehwwwss aiw rm
Ci I -. t ¦ , '*« *!.!> ' I I , >.-wv- - ,.;i > ., »! ill,. ¦ ,i • ' a' 4'
Lacking collaboration will! members of the Ka'u community, lite txmmm-
mnrn mi §mi judgment or people who reside hew, the County and EPA ton led
'• | . m:w rmofwllr P.igp J
.'<> '> • i! til ,'fit; 'h- >. ,i" '.-i i- • v' it iI'll , u" '•¦>! !*i>.m11 tii Ui >n! !',il t
.1' !(, ' 1 ' III . 1"! Illl il * >.M ' I" _ 'I'i . vi t>" it | I ; i \l '
Hi'i , ,i i *u,' ,|u,u ; ti'" i • . i..'! i. i >!>¦,: • n, > !u >•>, ,t > "¦
- i <;¦>. t - i.r il I, • : !r-r r • . , .;) o
11. - ri f-n.i -miU l >
i' i rt| i' ii,' • !j iiljn li • .i '"hi' • «*> i *i lik • h" * I i'i' i'r'n.
'«l :t<\ 11, i i, . mi; "'i 1! .1 ' \ j*, i I i'i J
.'•>.Vvt • i: ¦ *, n.j.l on iA,
vi.'i ,< , ii K ,,i tji iv m',,' \V., i.i'v i! J in i' ;; ! nl , n.ii'i"' ¦
. I 'I'llli I . Il'h t' (l|.ti',;' In 11 i >!i% I 1 1 ¦ MlV-t . 1 i ,M I,i! , t* t ! h "11 1 ' '1 '
rn of gtmts, both aaJ co(le«tive.
*1»ictc views ofrnvmri imiivitmk mm mmtmfly to at dim,
cv i miMiber of no is of course grmtt thin lie power of otie
•: i ,111 ' it 'shit «« .. Ii-I. ! W.iil" I; V sogjti B m> lie Witmoiil Sprilini!
\ . , i-in . .it Vet '¦ k-rtm ii-:, H !
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19
Ormorurifr f>3gf» 1
I iwfvtoft, the Uemaraelles recommend tie vm of ctnimililtai with tin!
•*"i i 'In R.t'n tMrnmrty v i. iKr. ^ i' . i s.i'.iKllliiiilii
has the power is- tuiite us,
i Motti i m wirji iHr i m or nit iuftf ai oi mum, in' on
M tldlll
vv, -it -• '< "t ¦ , f ¦ r.i 11, triJi, ' ,iij r i olir >, |i , .A-ii'-- 1 (H.i-.".
I hi -VH I! -ki liv ¦>!' IC ! i !<•' N ! ll.llil V. \S 1 I' /'-• hr. :i y'il-T,- 1 -ill- .hi.I 'u.'
'!'i .li , ?i* . "11 "' :'I"i"? M i"l\ . ' f . r' ^ l/' .. >"l ,(IH^ | 'I .In U! < 1 ; irv \..\V t'< M ? " H- c
V». i|. n i i i" i 'A )' 1'SH lilt
I !i. i'i • mi.*u\-! .NJ.'ii kv:i."i (, i ,r: 1 i i, i* . ii_¦ ' , i" k 'm i!n le i > « „¦ >
kWcrgaitcn cliittfwjtn. beside tlvc open sewage Itgoous,
' \ i I . i >iiL( ' ,vr ',s. ' ,! ' i t u>i - >; „> ,¦ 11¦ j ^ i'sr i! 111 ?!' i 'h .ii.
ii isll.l I V 1 I ¦! II,"I « > , II, n!l,"l , .
Hii-'i! !:;ii < uUl", J t'K 11!1.',! .ill. .'!! 'III ' A' \> ,"<%
t's M.I fit.' f , i ",l!r! >' ,1* "1 i I'll 0,1' I.I' El!', t'A !t'' |l i-,i. '
\ r m I, I !' "i v !vi 1 iii i' 'i. , '¦ ii I' .ii i k 'i \ • r.-\> ' ml
i\ . iir i sh.", il. mi ;l .1. i m. i,, j- . ii« i|( I >I ,-\ iv 'I;.1 ^,i «, .,i, 'i
' i >> > iu» j !il IHi * ,i 1 ii , i! >.iv i.!i 11, ¦ , i
f > i>'m' , .i •! 11",;:> W,1 i'in •Aif .rt.H.,. ,i ;\ r,i ii,-- i<4'I'.,1 K i'h
I i k || .iiii'.'i ¦ \ "i1 w I), i "m|I j' i", i !.:• I i-r-rr-r' i huh; ">
v 'u a< lii„ 4 m.iia !,'fi'»;i u numf. V.i ifi-
20
[Vrnorurtio P,1gt> 4
N;,u \,<{\ i1' v" <11 C i#i ^ ! «itli t t>!11>( M Klich.ir*ki th:tf
f)U Hi ji.irlnx nl "h.'»i' f.iiliil riiK<-r.tlt|i in lh< )r ilu1% ht Iht iimrdMniBl
•unit 1 ¦ I sK '"'I ,r*'(.' i" im* \h* ki:. !¦,!! ",i i •. nj I1'.
;.. • I r'.t1 *ii t • il It >i M • I Mi. , ^ 1 3 i
' !\ i u5l * •!c "¦ " 1 v L ij 'i. !, i 1" ' -v,." ^,l i ^
ll i', If.,, ' ! i k 11 h '.i'i i III i K' ' H \t "l\ I M I 1 , II*! 1' I
i, ¦ ,n .• N,-v,i-1 .ir.rt'.t a.iii'i i -' if if'a; ¦-i. im i'\ i ii'.i i >i'i
tegi»tai%*e hA!
5 i?!i i:, »«rtfHtr
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21
*4*^5 " » fU1* U"C I ! %« f £3 ^f, C* *•*
Diilsretifss between the way lie County of HawoH Deportment of
liiwiriiiiiiieniiil M» ..v, J iiing I.cibib Robbi, the CDF
•« e (Hliiw i >1 ,«Hk. tLtiv K !> |tau funded Lotto Kona, while the 20) 7
Kb*« flW'wwt- n't mrnth n i I •' n >i At. •«' 1. : v : ,1.
pstxu^ipntetf-ii I&ikiwcu.
'* i Sl'5: fi.riik'it: i«i,o km t C^&RF Ltwuro .funded Ka'u ll W I ft'
Hop* houMholds voted to pay tie hairnets oftit LCC doom cons - with RD
grant funding ft* most, of the projected ©usfaL I t of
remaining Ei' \ ^ \ \i' i-Mi, ,ik. • t ill »l M t>M't ¦ -.ofctNy pay for the
twoW% .lh,,withoutInlwiiiiniandseeling
22
Dcmoruelle Pagt: 6
fai^tfflAftamiiiHnritewpQwt^irriMMiiinpmii •• ¦ -fin* <«.t n • «.
• ' I'I M 'V I
sliikeiiolilee early *m*I made public nxwds available fa' review* In K«*», tile
€CIfl*M and RPA failed in provide 1I1S Hi «r NF.PA ri«to « TEN tar fc two
'-tails**!.'" kwhocu intended "to mfoim the community the two WWTP» were
gluing to happen", k 1.. 11,1!^., I \ V \ [ ¦; i t'.o-i ; > i No EA/E1S liiii
be fn pufe 11 itlicd I'tic the C SKb fumictl ppcyf€*c.f»
Instead of the Pahal* iintl 'Mialetn meeting records being available online, as
we tow Kmi's meeting m»rd» indtcating who was pfttmit ma the ttwetww
HieiSttii .iiuo outcames, the COHDEM refuse* to provide imy iwectiiig infonnatkm
«r enviriwitifBlil review Kiwis {«mpt fhc I*»M« PEIWDEA) to ll»e Iwi
Utwaries or oolitic. By dm^nftaccow under mPA,'K Nrv .'>>• HI \ u
wiilite?-) • i ,-,i ^,1 ^>17periisAOCAltai• ¦¦ u-o M ¦ -•„k »•*
Under ©P-12» Mis, l*»msriMille"» nqtwsl thai COHIiBM sliai make
available ft* fwislie inspustion aiii d«plic«iion iiiring piitr regatar hisiiicia taws
C3lB«n-"t I i . .t .'<« «i
(.t-i-nrBxi,) v""r st'w ulf- r> ve"rol <'1 twwl
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23
ficmcvruotle p.iic ?
* Ml I IO Hi1 IK) \N EISmTWOTOLL-SIZE WWTPSC»I Ml. APART)
,-ti i, Htw*> I' '.•,<* I :l;S f 1 ¦ H.'ii [ .* it.-f ' : (> i( ,-,it , ,r: > l\i;n.i ,, i >, , ,o
. ]i'iii'i ,»'<,j:I-,>¦. v\"iini..i'-l. (tuts!'!,¦ u'l'/i ,t! p.tr!.v\,:; .u
! i I -1 v v, i. i-.. ;> -l-t't.i -r, v*:i!i'h i < It II H M H" *i ,'-i .->• !.. ,b
\.fu., r.ri \ i! i.t i' i-l.»¦ s ¦-*\ h, . , n'v t,.t \| l".\} is
i'.w. !!>¦ , *. riv.l ns'.S Niiy,, ,ii: ih. i.ti I > >,-K. k ti.v lin.' i i.\ vi
24
U#tWWUt4lt< tf
1 * S h ' s* - . it' Y\;! v' 7 1(i! l< >
tl-.. ! l»~H> .111,1 ,¦ )! I -l.xl I III 'll l! '"'J ' % I. .1 11 r' [1 .'i"i 1 11 H'.Iv I 'I 5 i\
^'K •,s i I Mo lu j.., i i< "k!. . i ,j oo ¦
HAliM HI I HI K VI < (!MMI M I V
Hi' 1 4 v. vnih>,, S,j Js. .a; j •: ;[ 1 u'ii.'I r\ Kr.. * '
¦•!. • i111 < (">•.•. I ..iiii.'il >¦• C 't i! II M M 1 1' \ i-t i.) ¦¦ . '.i1
iv.i.'v. im-u-v il '»! 1 !>• SI t ll'.'iil,'-
4 I! I.,'. (!.' hi h >¦ . I <:• l.„ ' I I If.'iln ^Ui, ia«iiiiig *n.d i««|iteiiie,iiMion tnror the Ka'ii WWTP Prajects. Federal
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25
Demo run IV Rifjr 1
'««- . »'«i iroiiii the beginning of the IXC closures under KGPA. 42
"sr
¦ tir v ' r- I tii i; hi < . < ii!! ;t n psU:; ,> n -a >,(>!i i i ! MR ^ ^ P 4\!
¦ > 111 ;»• ii.tfii-ii n! n t" ;¦ • His iM i •>": i•' ]«•, ¦>*«••> .ilw.' -t\\ t
riih:u 1iiriui ImI.Iiii, pi!' , . .ii l1 j"a, ,>< ,ci;.;i if-hv
,-;ni'k1 , St.,v. i, f >[ 1 . i,,{i ;ih:i f«?- ;,vv.- . \i u
> I,' in Ml'i'll . I'll I'I,li\ lii,.!, 1 • i,1 !'• ill.' i I >? \
fM t% ;t.,i V !„ .i.,10 i,• -1 H;' ¦!, \ . •(-•! l'.\ ':< < >
i'i; tr t 1 1 h l \ m <. UiH V . ^ s!>- H\S "i\i . a n1): , >) ,1, si's lm!".
the EPA,
HIS 343-3 requires EADs 1* amis available for public inspection,
providing transparency, > •• , ,• r^-ttiaJ Sir deepen. %de>'- «„ » y
tccess to i* Mfiiilefcti IJEASj there has been no opportunity tor public iwisw ami
>. I k' ¦ ! V \\ I!'awns wpntaf from the \ . . • IfWTP - and
El' V ^ v \r ,nt in,.! wre trans&rmion Muy 31,20-lS, ie fiJifili frontMtllflili
id evade Ml?A. review. Sine# Rtitie Rao is overseeing the Federal HIM!A, why
nasn'i it* «!«# «n# i* ft# Naaleftu p»j«.
26
Chi5 fr Hr tfi'O
As tmasmaami by tie November Resolution 412-17, County is »ltog
in.-.v)1'! ;»<.• „i iv s.ii4i -mriNiiM«^itM^^th«papiiaedWWIf
action itself At ft* time, Hie MtitJa landlord manager hail not been consulted on
tH 'Kliffl
Withoute«is»> »- ncri .•«
mikera mike iriioWgiiiu, optimally IwelcW Ascisic* be made?
Sec. 1I2(2XC*J (42 IJSO 4:i32f2;Mc>J state tnm a j^isiled Mmmm# mtfwpm
on iltt iiiivirciiiBiiiii, cnvinxunental costs and il* > %\ m>. \ J
¦(I--..<..•{»». ai. >a >i' r-u v the propoaal through tbcc- ire t v>y
tEPA an COICDiMl tmkim profit-,." t uc mrntimtil sialate require tine
onvirimmenia.1 mmim sim m rly ta aoeom , fer
11:. > [ I: ^ • MM ' . !i-I ¦ HI -1 I I, I ¦. i mmm1 by vfalalloti of WA
MAl ! 1-2:00-14 '¦ M-.ii i •„ • • iSbepwpttt:.' i- iesi opportunity in
S"r-n~- pv .1 ,n..Mi. I .. „ . ! . M\k 11-200-.3 '>1 <" . l't n!-..-
BIS stall not be mtwly it self-t«ir*i*f» fecilaitaii of benefiiis and a of
»v 1' i! ,'A 1 • 25S8!lBlVlCMi«iiles,-K.a*i»%*i»i
"iafuKned*a W\N 11' v ¦ti-sSi-in||-wa*h • >i»ifie-il..
-------
27
•t UK K i' • 1 I « < I V Si'L", .Uon.il -w. I '...I.n.-u
of HAR t I-2M'*t 10 »p»Hite the projects into wo WWTP Project* and M10
- ,:l ¦ • ,r. " i , toed undertaking" that it i ,1 „, . , r i >, - ¦ r
Finally, HAR I l-2iCMS(»| Hales tint oituuliiiieii sittst be dooc PRIOR «o
preparation or§ PEA to mmm a Ml «nd complete c«»saliaiioii proww - and not
rely SOLELY on tit review process to impose environmental comma*.
\\h-< • |., ~. r .1 man* to at! K»*u I < i •> • *. 13
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37
*u>'
SANDRA L OCMORUELLE
Post Office Box 581
Naaleftu, Hawaii '3b7??
i / !j i, r i |
September 24, 2018
lt,I> Hi,r,-»,i|ri 'iyjf, ,'|
V'> I "f I' v. .'Ml.'II t'"ri ¦ t l" Mr
r •,! -i i tuv
,V t in AY-lli
<4,» x};
i! f,UHU U' 'MH NIHN.t , 111v- N ill,I' I ¦ f JI f I- H ih Ini S. S Y¦*.*I1 >: A >.. i.i
i.-;,.vt,i
r,..r„ (-(<-^,1 -rv
is mf fj'fl t,p n> , Mi't-l ij.; v.1'. 1m vVrl
!M"< f I , i t j -V i/"**'' • Wl"»SS >1 H)S !'K ' < !M'< O'ii1 II -
• \Mi Il-'fl LH VDK 1! t i
.. I ¦
38
woriet OP CITIZEN SWT UNDER Til ENDANGERED SPECIES AO",
II 1M»C, ISUitti-in H V) and /!H V)|i)
raSGN GIVING NO 1IC&
Sniuim i
Physical addica: 94-1S13 k ,u Y,i . i H.«,I \t.r t-f». 111! ¦ i«
MaJIift].' ,i ur.un
it i it i hi-A 'i I in j'lv m f l.c.i,IU\mr.K?-\>* '.Vi 1^.4.*ii 'i He
J'l t p.'lHni I Hi I1! J'I'.V. '> V,
i i *11 IVMI..I \j .. ,,, i
I- IW Pi iijrn Office-r- I aura Ofltcul M C.K.K. h
ia.'« 1 sl-iiMi i ix r," « j \yi in !•; _.n;s
!' ,n •, ; ii' i
.-.ft ft •*){'•• *,<
' 1 r * - s v^iC'U' >(T,'; P4 f< i , I'ir , h,i\
>;.¦> :.jf i i,.'K f.'l, I-" ,r< , '(..J,,,, r i
1 Kit A I t ¦ iiA''7 *' !> "¦ ^ 7'| ¦'' V ,Yr % t.'f.1 ;
h ' ¦!'» Au'.'l/ ( J1 -S unhi I /' I
. itmyi/iVii fc'/rt /Ac l.nt /W«i ,'lii
0Bfl «rfirr i r.m-i'iWHi 'v
-------
39
Current 1Mb: §S/»p2i; i» per u.>. t;ii¥ireiiii*iilii Protection Agency Oram
Agreement with County of Hawaii, Assistance ID Number XP-9WM540I-? for
project period - 1I0«|2®.
COH Project fctaniigitr: Dora Bmt
EPA Project «mr.. K-.U- j komwiOU* i iiteiatt411 C,1 ,K. ft.2»
(SI* Exhibit J,Cam I:Ii-sv-tit72-lMS*SC Docum.-K ^ »1.»».!»•* 14/2018
Pages » lo T%
tubulin; Ongmas: |Vi Wf ».f »€#irttfit»«i PI. from data
°f »*»ri itSlKiatS lirwiiigii tmwt Grni Period coauMnciag iSOftWItt
EPA DttCRETHMARY ACTION IN VIOLATION OF 15,4s
1) fifA FAILED TO TAKE iARLY HAK111 M( ir. A I till- ~, \i i U . ! V
AS REQUIRED BY NBFA AND CONSEQUENTLY FAILED TO COMPLY
WITH ISA
in the original EPACOH Grunt Agreement Section PI dated Sept. 20,24MB
{XP-96942401-0}, if A wa* firit required to comply with Mlf»A "and other
environmental.... .«.• llA. t t \ ^ < V ,< «
revisionshavercMihedinUk-.«> s.m-u «k. «*»* • , i*r. t« " 1 >t
ri!, ii-nirr * 5' \ V| i>-\ , wji,- I S \ .-in review procedures, into
two separate EPA WWTP W«fe only one- of which will require RSA
Section'?consultationprocess. li< «» .f»xi»r <¦ I r \ r. ! V.\ ;! „v.l •. , ,
Niaieliu ESA proem, Bee w-t*vs..» ><. ,m,ift* Mah, ww expressed.
NEPA m^ak&i Federal i. i-\ iv ,'i , >¦ p> -r 4.. > 4;i - >,
statement" prior to »ppr®%.inf any "mior federal action signifies#
qtiiJilj'afihehuman envircr . >t,n i: t'l U -n . i;„- ..
prepare mi environmental impsct statement creates a iciiiocmie JeattoiiBakiiig
p.,! - M'l »I • 1' ' c,,, •!¦!.« 5., • ,! Ihf public review mi
careAilly consider detailed information about environmental impacts before any
decision is made. Agencies- -1 •'[, h> ,<-n 1, ( .:a'!.,.HnaiepuWk involvement ill
wl till r .[is iiii% 1.1 :h >',n> m c ...„i i'a I K , ,
mtirnlmDimCMMw, Mtd, r n-v r»,.
f.»|j i V I -J
40
2) EPA HAS SRPARATEI1 Ui! K CLOSURE GRANT XP-
M«24il|A« Arocwlei 0 iiiwijjti ?1 INTO TWO SEP Af \' 1 "R« Ul .* Is \ V>
REFUSED TO FOLLOW NEPAflBSA PR0C80URI5S THAT EPA FttJ jOWF.D
POR THE PAliA I A !'R» Ml 1 llii A \MuK ti£i \ \ ALEHU W'WIT WORK
PLAN
No WIPA ei»*injiiiiic«liil renew pweothaw has* baen Ibiiiwetl since the
!'f i»^l» i " mirn to Mptie f »r nil of tha Htgal *«« I.CXi-
provitted Notice of the PEA/FONSI in A«i»t23,2»f issue of 3H« Tbcoriiinal
2007 FRA/FOMSI far tail the Piliila ail NaaltHhu l-CC lie timet (tad i
•!. .1, N,..n .riS. iiNln-• ii' 1 NTviouti chiing,cs to the original
K»u Cesspool ffojeei,
Fiinlw since this Minteha'Tihilt 2007 PEA/PONS1 never been
.*> >•,' '•«••»! ,!1'««1 v> 111 j.m*bIIS Nsti«| |» rial, it ia »pilisl tte
TEN Pilialft IMM4FMS1 Matite on Septemlici 23,281S as pari of die
NEPA/HEPA reijBisilf ptie«liifal review.
'I..i", k' in ml' :ir.v-u vkvKA':i <1 -ill n-n- >•> iln rs-- ml •*1 u,
"><>, • n' j -ii. t > 111 1 1.. 1 m 11 wUli V f \, s» 1 Ti: I di- i
i»i n!i," .i-iu1! .k't' hi.' 1 > \ iiTui 1," r,
•' C | 'i'l S. A iiw J'l't >1 *¦ I. J. hh" In 1" !•. 1 i •• l>\, >ti ¦<;* 1 I ill l!
C tl 'i'lil].
>*v II >.'x 111 i;« 1. H.j' Ui»» 11 J! ti!, M !"¦ poted L%»teh»i WWS EA
,K"i! M I'.si >,,1 WWS i IS 1 llKirr t'.'.Jr, »- i>K\) „U > ..*< !
«eparaie atudi» #«l dotwenft pn^aml »t iilferei* points in liint. Ml 10 consider
, 1 ¦ 1.-, t>y II,.! 111-.' i ,'!•,!• .'(• • 1,
wiistuwater aew»gc tneiiiitiwi pw|c€t» «n flw k»wat» fnvironmcnt in the
and spiseiy D>Jilricl of la'u.
t'BQ implementing NEPA "itcpit* iliii an agfiney consider
"eiifiinecleil iiciiona' «ni 'comiili Wetlmdi
Actmm Network * US Army Cttjn of Engineers, 222 F.3d ! I ttSk llii (9* Of,
2000) (emphasi» added) (c»ti«g_40 CfR 1S§« JS)« fuAtr, under I S«JS, two or
IH-'V wnsiBUiilt*lit!.u-d !!; s> ¦, . «p hi a**- v.; lie
"c«mfi«t€4" ar "cumuEative" action. 40 CFR J $0|.2St»K I !,|2) a« cited in Ktamaih-
StsMpm v, Mareim of Land ManagimtMi, » F.3d tg« f# Cir. 2004).
-------
41
ACKttlilhll-..- -r i ,«u' til i,, \l p\ , w!. I <• >V I III
impact on the m/mmmms which results from the toetwm i
.*!.> 'i I ,« | .i,: ,ihh foreseeable iiliiiciictitins ....
Cumulative impacts can remit flora individually minor but colfeoively significant
actions inking place over a period of time." 40CFR 15111.f.
Far "efHaxetmP* «kI "cumulative'' actions. He agency is WW il "should"
analyze them in a tingle impact statement, wliki,' i». « h.ui* n.t*,.rvw.. .• -•
¦iiuiildfy requirement. Ste Eatfe ittand Inuitut* v. ®S,H1 f,M 1291 (9*
Cir, 2CMJ1) m cited in Simmik-Sisiimiti v. Bureau of land Management. 387 F. M
fit (ffcClf, 2004).
J J EPA HAS PUBLISHED NOTICE OF AVAILABILITY OF Till PAlIALA
DEA PUBLIC COMMENT PERIOD WITHOUT CONSIDERING THE
ClIMi ILATIVB IWBCTS OF THE AOC TWIN WTO WORE PLANS
WHICH SPECIFY BUILDING TWO SECONDARY SEWAGE TREATMENT
I'LAN're JUST 11 MILES APART IN ilMOTll, RURAL KALI 1IIF01E
APRIL 17, 2022
Despite Kile Rao approving EPA SAA1* funding iw the original Ka'u LCC
toLC5Sconversionp. >-i l a> -he' *, *,ii>iituiin. N.^iii>. s'i »I®
Wf •'•VI' .1 • m •! i' ¦ »>•! V l'\,.!..! ;•,< viirfvt J K\ 7 consultation
will FWS, as she did m >• I' •• ,1 - tl • ,.-r> it <•••< I Hi» m ,i.> i.-si 1 S \ in" •• "it- t.
2018 letter, if allowing avoidance tif coiisMwitoti ot cumulative impacts and
.hi' iy \S p \ ,.r I \ i, ! t, vl'V*» •• i i'iaij his allowed the separation of the
two Ki'u Biw-fcttllil WWTPs with no 4ggie§aitkH> of on the numerous
affected endangered plants aid williie mm apoarentlv intentionally iiwiiini any
NEPA cumulative impact analysis. ("fTJlie district court properly determined that
the Forest Service violated the IS \ , i." • . ,» »i. i >>i m • «n i nh 'ion
•Her ine revised its critical habitat designation., ,** Gommwem
EmimmmmrmltMwCmmv, !^- i ...'V-,,. , > *l'< I ^ >75 (9* Cir. 2015)),
In Cottommed. the Forest Service contended that "Itjhe MA or BIS ma each
action .., will document the cumulative impacts of thai action and nit previous
iiclions,** >, v i m'.m k Ik . ! "that consideration of cumulative impacts after the
fond has *!«•% le« ajpproved a insufficient to fulfill tie mandate of NEPA, A
central pwpcK of the EiS is to Slice tli« eoi«ii«»iI®» rfeBwirenflieai*! impacts in
the decisionmaking prcies®, Sm, ef „ Cotumbkt Baskr Land Ptoueftem A$* *»f v
Stkhmmgiitt, 141 F.'2d M$ Cm, City Davis v.
(9mGf, Brmegart50(tf.2i677j593 (f't'Sr, If74)(ethane)-,
:»#»«. BfS
42
Calvert opr • Oxiiirfiliaflfff Committee *, ABC, 440 F.2d 1109.1! 13-1114
(O.C.Clr, l"'l! ,.T v !lt II 111. \i PA ;-i,k • K 11,-ji.iU-J wiA
agency pint »¦ V) nn -,i r, ¦. i,\.. ' Hi, | ).¦ , i; ; -h. r>.,iT. ¦¦ •
. I..M tH, hil \ „ rv'Al I,, jr.uL't.i.ii.n 'V'. «i#ti%«efTe€«#rwccei!sl*e,
'''r''' "•"" *•' L-la>evi t.r«;11 tl* first step is ate®!* liken,*' noman
753 PM 1S*t T#® |i* CIr, HIS),
Beeatte the EPA has lake# specific steps to cfcsnie d» EPA-COH Grant
Assistance Amencbnents i*XP-i6S424l)i, „i* I :l».».!» <«s 2011
ameiitlimitil evat!>' K !k> N' l''\ I S
ptf&G&w&'-K ,u- S*ui\ \\ W \\ j«' I-v.hai H'sr* % Ihf l'|#A % nuimf
11 ..iifaiw»y fe Artwli Pahala WWTP P»|ecl, I hereby give
of a p i i • -n i.ikI," "rt« r SA,
Herein I object foth* l I" \ *» m> m <..l.-..••( ..
.(taisioiisfjo eitlitr Pwj«t tlwi^n i t.nirbefeVMttpatlj((Bte|]Hie
ii.SA Sieetiou I tojitttllitiaft *n< issuimee of a Biofepeirf Opiitluft cewli^ i»e
cumulative actions that will "Jeopard :ew of nwlltoh
i 1 . -... V .U4II, I l(.|t;s !>7 I ,,h '.-.i f ,1,,-i,, \ n/L-hi:
WW IP Projects.
I decline under penalty of pcrjiify lfc«t the Is ttw tad conrect
Dii«|: September 24,2011 itt Nualehu, Hawaii
i, I f
s wr.Mi.\ sij \;< iri rj i i
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43
PfopaMrf p»»uu wwm»
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49
"flltCTT
paying fitr tin uwsr system because it was tke Cwnfyjhm C Brewer
Si,mw *»»*( W «***« "•»« »"»«« h *te
imtkottkey
sfkangfo.it 8at other people m the
mmn-mm'Wffdt c ttpflBttfewit lili)
' '''• '"! v I "Vt*m That's wkati reatfygatmepvizM. And
timnwhatm wmt » fair, 11% tow AmfMtoftrronetfMn to&nm » aft »
a» •% M fewer «
V)
triggered m SB.
When did tkiif plan m |»«i ttfr t»«i to Mr
flit: Mr. Director?
^Vtr.
UlUm^WkLJLul^ .V». iM **jfiwtmtlfr fctailf of# Junior®®*
/or ^ Irtper
Awn the EM ami/mm miik tJZJLmur
trmtmmt phut* mt then the a* mwnm Thmt'f mikat mmi imymr—t «w gel it. I
fiitfl'ss
itf * ck-W*?|cwt«,^« s»t^»n
,, « ttesttomittfthc f.life the*, t* tli*mM»lstte«ithe
¦—.—J'
rrnmskemmm
mm far tim process, wtmtfwr it rnpm'm ImMm to At So until the £4 ti» 4
SSSSSssS&SlSSSSg....
».« tw hM fifcrisirirf sttff efcet«, n#cfmt to * m« £4 * i* mr .**#» *t The Jim
pan of f#K» 1M b rite wucnfof .sftettfii, ammeter nmt soliciting comments from the
community. Tfttft has token phot
iliJIsinstlllJles Ho sir, « has wot Wm htmt lit fie mtom
£mmlmtsmtSskmmi so ntfaum m moke o-mmmmt to thai, that imim
wtth tMe emltimmi emt to IAt scheat in NUMt Uti speak to Superintendent Chad
50
1
F>* >
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51
m jini mi Mow Im m trn turn. m»t In ill
Decentralized System Partners
KPA's Ii®«Mtraiieii Wastewater Management
of Understanding (MOU) Partnership
EPA mil ihi "•> • .< 'i. I' ' lit' v» ii i «a«k«e«>- K . s 'i i , 1 ..
'¦ I -I- i ; i-. , ¦' i, i i i .' i n' c " \ hi, i | ,> ¦ i ir; i , 'i, i , • ,ll - .i , 'i. ,j
• . I' II ' > >
mi tall pmMMi, mi dMmftaUaMt tgmm pmeMmm mid providcK,
IflTMO-llilgitof !«¦»
52
1 ¦ f X I, ¦. I „ I IK t% * ¦> i' j. .(
" -I. ¦= ¦ ' ¦ ¦¦ ¦! ¦' " ' ' 5 Vl.."V
««»;&» V«h* U.S. EM)
HIT MOO ftmew»l Proa R*feut*
%-itv pmiis retettcs I# tfie I© If Ctec€iiSiiax4 MCltJ c&tfllniitiig llww
emmitaKflt »w«ts eoUMKtflUively Willi EPA and otter puilwtii la tmprove dmnUiliaNl
perfbrauuee and protect puMfc tolth and wM*r mmmmti
ililiilftll
111I2,<« Ml.«» K, «*U5S) EOT
« Wai» ^ K j; Wg^.1^131 Ewr
yktMMmmi&saiw »-*«
ftiptrs if lie IltctilMkliMi WMOO PfcltftenMp
, e-... ..^ .... ,'a -^...^| i-..... ...n-. ...s-.... ... .. ".. f .. ^. » '.| .-^.^ .. a _ ^ .. .. ^ S' |i .. i,-^ ¦ ¦=. . ^. 4-.^. . ^ ... ,w -. ^ |
* DmmmR** tfmkmm ttmsmm Cm Us. Cssfiii antf Suiakalili
* WiiitmiiiwTri\ s i i- m !,nn "• '¦ 1 -i-'f - t •' I( im ' r. Mr h'. *p1 aicf
fjialily
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53
,i ... . .i, . ¦ : ¦ » .. . ...
it'*. y!->ML h j ttW&A
tra »«# .in**!,,-« mt mm •"«¦ *»»•»~*•»*«*«'
Funding for Septic Systems
• Fefciil.Fs^ss&OKe
" ;lifclaBilIE.,SiiBll.
Federal Funding S#ar««
|-.:FA l.lgaa Wmim Slsfrg Mgygjiviag Psioi I'CWSKF'I
nfevmfcf trarimcnl.
t fetr: •>«;!... m 1 If of lit?. Qaia Wrier AO, K.PA p«»*kl» »«l* I
I ¦ if, ¦ (1 i s >,i 1 i -„• ¦ I > i' ,11 ¦ . (
> ; 11 ' , " 1 i ¦ ' >l i 'i nx*ffip iRjurn*JiUi>n, < - m ti 1 1
sy 4**1 «n*ireiifiifulil Bi»« «
mJkmimaMiairnk
a of 1'e.titfcaikl ak immiUMM tfttctate*, eo*»l»itiM»i» of pufclfc
54
%"afiel|r sf waiifsl»i pfctlgssiitifi pfQpt&ms,.
State Funding S»o««s
EXIT
_ »• ,« I*'-* L.i;. m«,«, ™,,. ,f _ «.* ,t _ V — H,
ot at Ntvt i mh witetstietf in iMUmmt* >uM*v-*r», m
iisasSiieilissisi £®i
ft to stmifkt pif*?* , .,v \ 1 , . ' i ¦ f (. p , Iviiitii PffMitsireiit 9!
sfcfi ftflia. to w^fefifsi! liisit io lniifK^WKfi i§ feiiif or fs^plicf iticlr
«»p4fc|i.»*il %*»«,
1e»s» tXQ's M«j*iiot S#«s l«rs»Bi» plni» iwi ii^faaciils »linlics lh»t prcwnt or i'lwfc mm
Funding Targeted fm Tiilml C'cwiinimiitlts
I ®fr% ttMS* H-lfKl 1fl|y Itlf' ^nrra.^tr\Jc£v*fV 10 JTidlSFI inHfKJi iVMlW V ^ HI -'*»
. . ¦! „• ' • m'.m I ." ' -,l >„•
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56
Afaaftsr/rK. —.
wCrr* » ,
Funding Sources for Small anil Rural
\\ astcwafcr S> stems
MM ; p I i m , ,, i , , , , Wrt .. ,,,i [ , , I ,11
Funding fi»i All f i immunities
fcl'A l*'ii.(i«ii«iR SsolirWi'
• £||p:?a^ (
scieiEe pottuion control. mvl WKHsfitsI mt esAmtf mmgmtm. Tils C WSKF asei
. \ , 11\ ¦, r,, I t i . ¦ i, i , i , , i t,i , ,, > 1 i up i 11 .11|. .' , n,,
ifwiilily States wisf wiIwiimc f©#tt irntt* 10 n;#wl iwpib el
tflflJBtjMfigS, wnscn IJ fHCIl ty RIV? f€W®f plM£M?3$|; il^WWk
' " " I ( !1 . 5 v 1 I HI ' IK v VI ' " >f S it I *1 i " ,i i . I M ill I vA "h M i I ' 'I
eiismirifs preventing peMtan to drinking mm
W* fiwiMil ilswitiiic* to eligjtife orgytizttions to tfcwtstep erfbtamtiut pwunmJiip*,
iite'ftlsfV inxf oeMsc htall'b Kl>®c$" ami foe* £^kx;te-
" W|»BgM.aiBlSlli^llJ!llBSlB^
>¦ ;;.mk'>( i h'i.«i'.E ski1 ¦.;;!! .v..m,vi fi»„. :;!.ii.:iii-.v
- 1 . ^ ' - »>' I - I . M il (J » 1 . •» >.. 1 V r , f ,s \ , 1 , , M 1 >1 I
|WopSiA\ asst. ilioii(fgiii!?|; imatfMispl WMftw fi8p|©»gt'5liii|jfi |*4$gtil>§t- §wsi§Ri,s s®liKfa
""! imsm
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57
» Tt»k
* MfMissiiatlisisHBii
s EfllllllilllllilSlfl
\ . i . i ^, i 'u- mi, 1 ., ,« >- I-1,
vwwsy (if mtiemi»l ptototfioo pmptU. I i 1 >. ¦¦ , i ; i i • 1 „ I , i, „ 1,, h 'I , r-'..
» « pilte and tiititiliia tints® system*. EPA f«iwi*lits pints to flii «U» tiipiiiliaeiil of
CoffiftHV*! . * , t , • .! .. ! I II.
r,)sn.
More (»,»tiliHsiu tribe* ««! At*** Nartiwe Vlitigp;, the
€MS.% ftugnan is mlmmiiimii in cmipmima wilii (li# laiKati Htiffli Stwice (IHK), To I*
58
life IfitKli Willi IfeiSfeTCCS 46
protectiheir MMml environment*.
I'Vokiiiia Seidifilail ami «mM assfalai*m to Man tiilies ami Alaska Kin cMMMife fat
ttur ceejwith mutmrnu, tot wtil
¦•it* ipioia. i»s ff tHcsd iiifprn
fiiiiaLBsssiB
!Vll I !¦ I . • I ' ' ,1 | „ I, 1 , i'l '* '< ' „i( ||| 1,1' . I \ i . .i.i
! I H • 1 ,1-1 » ,,| ,f < ' K, 1 II, I 1
rKH!S«, I'fun ;K.
Provide* through conttatfe. simI «««ipacft »o Amtrietn firfiitw mi Ahislai
mmm m eahwce I • ' ¦ , ,1 ' -i I - -I i .. i
i , . ' «... l tl M ,v „ - *., 'i i "i^[»ltfHEl««. 11)S y,S,-HesK«
torifcr regioii' is MW b W UMm (St milts) iK»tlb Mid IW Blofiwtew ssn»lh efIlls
-------
59
t!,S,"Ms*k» toils, EPA* soiam*
p wis m M.rn.«fc« i.if if it
' t • - , • „ T • ' ¦ »*« > • ¦
i «i.i:i ' ^"V 4"'-' <""1 '"n" — -»*"! m• - v^vW»(.vi
am; mm mmm mm M*
i'» ¦ , • Hitum! (MPSMMMKI - Mdta tim SWit Gill
1 • » .i •.•rfn'.vv.'i ¦< < tf l*» u'Ji u „ t-,t ",i i, ,w, !| „iwW( ) •r, r,»)«,!» « , i i h
'•Vr .» , '.J** v,r > -\ r
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* -mm* -«**V * * "v i'* K' 0«; a«» l<^* « 4 f 1 " MVU^IV • IV , *-• }ii<
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fc»*»'»n i m ., -
,j tnwmi AfHcpvMrt MMnMtm jlici»*»|
| i . » r»
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>. ¦¦ If ¦¦!.,. ...
und fj» Cammiiiicm {»«f,
Mmmm , Cs-toti t*
COMIACTus
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o«SMfffB#*ii aiimmm,ummmk OcwtopmM& twrnm
P.O. Bo* JK9
ho
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63
NOTICE THAT PAHAIA PEA ME1T1H6S ARE IMS VIOWIOW Of HEPA
woe oct27-2018
Notice if ptevWed ilti the filmfe ft,,11 ' >- i . \ v, .:t| »v •• I pi, , , >,• - i NEPA Sliilules, The pmp:mnl Nonfatal
Wastewater Sjiifem {WW mmmmt Sfymtm DEA are lep% inadequate
Iseuij
aggregated mi »i®f trentsKM
p»|€tlf.«n Me MmhrwMqmmnI «tii# Mil awl sfaHelji populated Disfciel of KaV
C£Q reputation tmptancmuif NEPA 'tapir# that m JiffiKf eeondcr "efiOfMei mams,' ami
•aiiinlir ii t ,-i • . , ..in L- • i „¦ »%rfa*nir4c(n»»t-, U!i Arm,*-VWjm s>f
)¦><< 5 IP, ItH : v MV. I!' . , - 1.1 !' n ' tniilsr
I 50S.15,, mm m mm agency action* i llwy »«
•WiWtf or-'winkitiiifwe" actum. 40 CI* 1508,251 »X i m citel i»» KWrt-Sfrffw» Hum*vf
hmt Uanagemmf. X7 EM fW if Cit »«, A cwwiWve impel il ifcliwi te MIT*'#
Bllif iricpfitianil impact til
actions . , €. umutotive
impact* rain remit Iran iitSwiiii»iij» imnor hut eeMvriy signifies mm * period
of time" aOCFR l»M.
Ii* •tmmurni' and action, the k Md it "timiM" mtiiym llmm «,* *11 j.fc
... (>«• .! I'tsicta lie- f* Circuit tnlei, >, *,,.*.•* • V. ...<¦¦> . mm '<¦ i«*
m mm, 351 r, M I m if* Cir, 3t»J}as Hindi « mmrntkiMfrm I*. li?
F,Jd»St|?»Clf, 2t®%
OmA (kMiimsr», *«, rn MmMm, Hawaii
* tmum OTMORUHLLE
64
SANDRA L. DEMOAUEILE
Si-1513 Kaaiualu Road
Post Office 80* 5®§
Naatehu, Hawaii 96? 72
Email: naa»#hutl*atr##fsho«,coii«i
tote is©
IP* Project Officer
75 Hawthorne Stniiii, WTA-3-2
San Francis ",i„A ¦ -fl-ir*,
flora Btstlc
rfyject Minaf tr
Wastewater Biwisiwi Chief
County ©f Hawaii m$mrnmmi ef imimmmmM Ummammmt
2S Aufltirii Street
MUe, Hawaii 96720
iter fewest faf Coi1»i;i,i* Parly Stilus
tsi»ij De.1', t. f-N. I lep.iac««eiit Prelect
AssIsi.bc. iD Mm** {»« MMQt» W«24«l-?
Dear Ms. Rao
»am a (wonmiwiw art IS ye» mMm of Uwltlm In the historic district ef
1 «w» cMWwb f*« who graduated from NwMta Sc,l*»l
IMISJ and, airfetitlf, mf 7 fmmr oli greattltenis first fraul# the«» I
as the Parent Ra
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65
The cm and County m making an iirrweeibit conwnitment *rf resources to
place two Ml-uzed, riew-touM Mcondary wastewater treatment plants to twice
about 100 homes in renwta, rural Ka'u. l tv, ¦>', 9 commitment of resource our
community holds SSC»e«i - ¦» Mh kaawa testified, her family say5 that "s«f«t
is anything tliit cannot b* repfx*d." (Ciwaly Council test!mony on Rtt. 650-18}.
To d«MnRMi my Mwt»»this EJ>* undertaking, I mm point to my
att«nttee participation through testimony to relevant County authorities:
County ot Hawaii Council
Mat 9, mm regarding bium: lono mm $mm mmm bonds is
May 22, 2018 {Sp«c» Budget Hearing} REGARDING BULL 111: NAALEHU AND
PAHALA WASTEWATER SYSTEMS CQHOCM Clf 2018-19 6WCII PRIORITIES »2
AND #1 TOTALLING $4J,0S1.000.
Mm 6, ma (Special Budget Hearing) REGARDING !Utt 111: NAALIHU AND
PAHALA WASTEWATER SfSIIMI COHDEM OP 2018*19 BUDGET PRIORITIES «
AND m TOTALLING S41.0S1.000.
County of Hawaii Council Ftmmm CommittM
August 7. Mil [R£GARDING FAILURE TO PLACE WU COMMUNITY REQUEST FOB
AyWT .M.i .>„i" , .TIKtS PROM NOVEMBER 5.2004TO KESENtl.
August 11, 2018 f?fSAiOliS IIS, 654-18: GRANT FOB FORMES NAALEHI!
SEWAGE TREATMENT SITE.
County of Hawaii fntfronmamtal Management Cemmteton
April 25, 2018 "toll of Port, Utile Sewae? * 1"« Two Ka'u Sewage Hants* |3
Pips),
May 21,2018 Provided Commissioners with copta of 1J ih# Wialtlw WWTP
CWSRF Fuming Form slewing 33 points making » Mw*» »j 2) ih* DIM OP
Budget ctaps WOS to 2019; 3) HOC, Naalehu Work Mi« Attachment B, arsci fi
fcponse to community comments; 4) Otiwiiili# v 18-0017.! an
iSC Complaint;» Km'u Cakatfm dated May 2018 article; SJ County mi
demonstrating Sown family ownership of Naatehu property since 1*8.
66
June I?, 2018 Complaining of the lack of environmental review and the Naalehu
B\ •. i a, *«> 1.,. .tone after theCOHDEM has decided on II* treatment
plant site, and the COHOiM has not been transparent and has withheld requests
for the two to*# OEAs, «f!s ami t$A Phase I.
July 27, 2018 RE: ITEM {II DIRECTOR'S INFORMATIONAL UPDATE - J'fstoJ of fl#
pmpmiit Mmkku mm flKwlded Commissions n with copiis of tin COHOCM
Extambn Compfianc* Rtqunt letter dated June 14,2016 to 0>A; »rtiei« tl»«l
»*u iiifai Hawaiian Cafft* and Toa LP mi Its tend tnaragw, Mm C««s,
Inly 2?» 20» RE; IT EM 5A Policf on cerumen*!, on •nwirefimtmal mm,.
fherefftre. I m fwrnilt* mpiii "caiiwlttoi pmtf stjilus under NEPA,
HI pa, and all sttWti ineluiiiBi E»a«l NHPA, and to i* eoasM
«i»J iiiloriwei of all PA #ftdl COH hlttoric property WiHtlficallcw and
tl®termi:iiaii#n. of off#s for the Naririw MM Han prefect, and (or the
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SANDRA LOEMORUELLE
Post Office Box SS8
Naalehu* Hawaii 96772
taail: !i?jMil!ll|.E«fil2h22i£2S
Itily 2?, 2018
Dora Sect
County of Hawaii Department of fmmmmnliJ
m/mpmiSvm
Mile, Hawaii 95720
fie; Request for Consulted *#rty Status for the itMi and f alalia Wastewater
Treatment Want Projects for WIS 343 HEM and NEPA fJt/ES/f©
Dear Mi, Beck,
While l Ml tontiiittng four (allure to <1® a timely ftS m the tCi'ii
Wastewater T reatment Plant {WWff3} pnjf efts {which irt aiertcy pspoialt lor
actions described in the AOC Attachments for the Naafehu and Mub WW
mark plans), Mr, Kutharski ml thai the «»«ii WWTPIA was going to start
in 'fate f*i,4" presumably in lilt, (mi* Environmental Management Committee
meeting mimitm of July 26,2018J.
Therefore, I am requesting that a! an* point in time the CQHOCM sens or
continues any H£PA/NEPA ecwfiwiewaiat review for either of itase WWTP
projects, I am femi% requesting -consulted pmtf mmrn ma to be trnmtm
art informed of all COHKU environmental review actions and Akmors.
Sincerely,
Sandra DemorueNe
cc: William KwtosiJ, Mayor Mm, l*e la#., KatNeen Johnson, Tessa tempi,
Sim! mm. Tom Helper, ftirui Cabacunga
68
***** mJm Of CITIZEN sun FOR VIOLATION OF ISA {Notice attached)
twi nAMi*t,,mmt¥S-f*nm',sm
l m rnmmmw 'Urn UutftjKfe* fs»; MM mai$n» ¥n
anpm0bmnum*am;
#!*».« #«,««:
*<¦ «W »»! ttm
p,,«, mmMj, ». j®iamm « w hji
This mb* woi out today.
Best, Sandra Oemoruefe
|2t ?«*«¦«»-ftat.Noncfa«.»i u«
IB «*»
jjj nowt or crmtN suit i*w» wi ih&aw*» shciis *u a«»
HK Co ismm*
*4M6 lEI !%«¦
-------
Skmm i 3CMOfton.il
Post Office Box S88
Naalehu, Hawaii 96772
Email; nalelrothealfefpyiliooxofti
September 24,2011
111# Honorable Ryan Biike
Secretary, Department of Interior
1849 c Street m
Washington 1>C 2024&
fax: 7M/3M-1930
RE; MOTlCf Of IMPENDING CITIZEN SWT UNDER ISA 1« UVC IMOftjflJjAJ and
Bfar Secretary,
Attached ii my Notice of Impending clliien wit, Thank yo«i far four
attention lo my gram concerns which art causing me concrete injuries.
Sincerely,
A Sandra DemorueNe
SMWRADCMOItUCLLE
70
NOTICE OF CITIZEN SUIT UNDER THE ENDANGERED SPECIES ACT,
1« tJiLCl 1348 CfMlKA) Md P*AMiJ
PERSON GIVING NOTICE;
Ueirtijruelle,
Physical W-ISI3 laiil««,lo Umi, Urnfelftu HI W7T2
Mailing mMks»: tO Be* Sllt KhMiu 111 »T?«S»
Telephone: I-808-929-9244
Kmaih iiaiifcfcuilicitttWSHmlimo -awn
NOTICE:
Legation; NahUHu 4Rf
Hawaii, |I»S»A,
U.IU >iU-..mmriisvmento! 1 S'« V. '>.< <:tSultaiNHi vtolatkm:
[line: September 20, 2005 pa- ijj, Environments! PnacctkH Agency limit
Agreement with County of Hawaii, Ai«wia.«« ID- Number XP-9W240 J -0 for
project period CiPMffilii - 1.2/11/2007.
CO!i Is '> V.: Mrs.1,'1; E km leek
EPA fmjm Offteir: i Jiiim mm (ItofKHMtMe Official 40 CM. &}$3(aX$))
(See Exhibit 5, Case 1: 18-e v-001 12-JMS-KSC Document 2S-9 Piled 09/14/2®i I
Pages 1 to *?),.
The mapiemt (Cmmty efflamaiij agrm* imf k* inii or
request mimkmmmmms'fkmrn EPA far any catu
associated with the design or comtructhm off he prefect
/Kan Cmifxmt Mtftimwmmi Project jot Mmhhrn and
Pafmh » Kan) funded by this grmtt... until EPA km
.««**«/»«* »*• V«!m»i f'nth'i -1.1
rmummvwtt! urau-amen h»' *»' f ft
*>,w)'1 to It,^^ (M, Section H.J-
I ©f 5
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71
ClliWfli I I,!..- nh ill ,N-| I, ,> ; ;n 1 f 1 '* *>'"• «•!!!• -v«li» Assistance ID Number XP-®f»42.-l®I -71*
project period 06ttl/2005 - UtBVIim,
COM Project Manager: Don Beck
EPA Froj«ct Officer; KHt 111® (Rl«.|H>nMlilr I Ifrinitt 4(t I I.K.
(A* Exhibit ?, Case i:l8-cv.0om-JMS-KSC Ejectment2$-9KM 8
I'ilEVS- f Uj :>%
lisle# of ting*,** .luring !.«..«) „l <.««»CwlKton pI, from J*e
Of •W««il#atfliiStiliWIKh current (Jr-rar vnmmr,umK 05 tlU«IK
EPA MSt HI, I ION \U\ w IIOMN VIOLATION Of* ISA:
I i EPA PAILED TO TAKE EARLY fiARO LOOK AT THE KAU PROJECTS
AS REQUIRED BY MEPA AND CONSEQUENTLY FAILED TO COMPLY
WITHES A
,,n *•"""V1*1 EPA-COI1 Grant Agreement Section Pi tltiei Sepi, 20. 2005
(XP-%942401-0), EPA was Ihi required let comply with NIP,4 "mint other
iw.ja n,. !•>•>% \ vu- t ,u.,i w>.v. , -
rcvistans have rauhed in flitting the original Nailehu&i si i*.« j.t p«mv<, i> .«>
requiring the fePA NEPAfciuwvutuws bSA environmental review procedures, into
two separate EPA WWTP W«k fliiis, oiilj one of which will require ESA
Section ? consultation pnx PA from FW5, Ik need for s
Niiileliu ISA pn »..c,v,, nK,- what wa» occurring for Piiiila, * expressed,
NKPA mi,'. K-.L'-.s -ss, ii*iWilli*lie EPA, to prepare a "detailed
Statement" prior to approving any '•major federal action sigftiffcaiitly affecting the
quality #1 liis Jiiiimin crtvtrannwnl.. 42 CFR 4332(2Xe).„ **The requirement to
prepare an environmental impel mtsitKat €«•!<.,- ,1 cu-u.i ,i;i J., i, <? imm ©1* TEN, The twigiini
2 !' ii, i\( WWS ElSilTU are tsiplJy inade> >> i .,• > ^ ,,, ¦ ., ,u»
«pfile etiKfies awt doowMM* p«pmt4 tl dlfftrtut jmols in time, Ml io mmiim
lie aiggKigtifsJ «i| cumulative eflecn of the emmxmtl tcfitw ef the p-eposecl
wastewater ww«gc ttestmem protects oti the human «vi«iiicui in the inialeJ
iimJ i|j!i*!S0ly populated. District «f Ka'u.
CEQ regulaikiiii impleiticfiiing MEPA "retniirc ihat an aiwnfy consider
'coiineciisl «ic»f»an J ¦cuiinilmivB within a stogie £4 m BIS,' Wnhntb
AetitMNmwwkv, US, ArmyC&ps tf Engineers, 222 F .3d 1105. ! litfFCir,
2fMM) (emphasis added) (citing 40 CFR I S«,25). Further, under 150K.25. two or
more agency actions nm.- •. ,t,v « .-.| ,»t t v. •• tit.iiMit •!«, „rv
"connected' ar"«ii*»l«ii*e" j*tim, 40 CFR «S«.2S
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73
A cumulative impact ..MiucJ ,n M r V& implementing rcgulatit n • iK
¦<>: .'«¦!!' ii iii'lronmen! whichBails from the ai.>v",c- 1<: (,-i'ifce actio*
wfcenadded i©cilerpast,ptmtsi< , .1 ,K .• i«.i \ 1 i n- <> ms ....
Cumulative impacts can result from individually minor but collectively shmiflcam
actionslikingptawmc « ...•, ,K> ,
for '-awmmM" and ^mmulative" actions, the agency « toB it "should"
analyze dmt ini tingle impact mmrnrnl *-K- >i t ». mi nn,;Uv .<. ..
mtnJaevKtttiretnciii. See Eagle Martd Institute v. USFS,m WMlWl W1
(**0**'iKM)**l!a™•2A4M~w¦,m **»*«««Ma«ife«e», 387 F.W
3) EPA HAS PUBLISHED NOTICE OF AVAILABILITY OP THE PA1 IA1.A
l*;A PUBLIC COMMENT PERIOD WITHOUT CONSIDERING THE
CUMULATIVE effects m Till AOC TON WWTP WORK PIJVNS
WHICH SPECIFY BUILDING TWO SECONDARY SEWAGE TREATMENT
PLANTS JUST i I MILES APART IN REMOTK, RURAL KAU BEFORE
APRIL 17, 2022
Respite Kile Rj® ippravi«iig EPA SAAP finJin« for Hie Mgj.mil Ki«,ii LCC
to LtSiS «t-. .-i .* r<.-ii|. < i'>. .;<>¦ ... -un-i,.. Nmfcli Wirl. H»u to be
imiimmmM m violation of MEM, Kiel to e«i ESA S«kw ?
S! 83 Sl* jKi W1,b Ps,M«- *siii»tiiii ERGto do this ESA in the June ?,
tftli tetter. By allowing avoidance of consideration tfansMtt impacts mt
avoiding W •' \ vm S I Jeoll® illl'i" > c 'n;ii,l,i;. « \E A
efiatnil pun*»c of ifce EiS is t© !mf lie coiisiieniion of enviiionrrtenia] impuds in
o..-1 .mi'ki ,1 ai§process.Stw, ir.g, €MmtM i the tV ur-.,1 . »* likes." Ikmm v.
Peterson, 7S3 fM 754, ?«ft* Cir, ! 9BSJ..
Bccmuc I* EPA Jiiis taken s|iecifie step to change the EPA-COH Oram
AMJititi.es Amendments May 30, llil
i. - n, i « •>, tfvctyevaciti, \ )».« \l r \ l-s \
prn.. vi;-- !,t, s. 'A 'ATP Pn>|ea by tlii'iplv moving ite EPA mrnmy
•«>.,- • i Hcsawaytothi-vwi. hi,.!-vu\ H'|'^!.v i ibygiv^ Notice
' > 1 .• C":.. • ' •, n 1 «n suit iifMfcr III# ESA.
^ Herein 1 objectto ti* EPA tailurc w iBipfctneni iJi« ESA Sec. 7 coaailtaljwi
ft* NtiJeliii m K.»fc; Km «IH for Piih»ta mul ff^nest ili#j 'before, (here is may
decisions on either Prcjecl, that the EFA^COH be mpiired to provide
IjSA Seatlkm an m,.v-a ,-m ,\n, c ... finiple
Hawaiian enclangewi
WWTP Prajeeto.
i declare iincler penally i>f pcr|a.ij« ihti the ferpiiig, is true ani comet.
Dated Scplfiilnf 24,2§1S at NaafcSm, I lawaii
SANDRA DEMORUELLE
l>ip»afi
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75
FW; Records Request far Hawaii County Department of Bmrmtrnmal
Managcmflflb Request for Consultant approved Mlhal* Community OuUWth
Wan ami NaaMMi Community Outreach Hs« f«l»I
ita.
£r. ««% IwliaM.Iigti.iartMf,#*, v»Mmm*umpjtw
m.i: WwwuwanWinKH"1**«*•«
ttrtp: Ikkflli* S#|»Bltar |l, im eiSiWI AM WIT
Comment«1
Ti» County ef H*wak Department of iMgamnW MaAagenwni fCOHDEM*} Is
currently m ¦ second vwMen of «w HEPA pfis 343 at aeq.) trnf UlPA tlMN (fcW
•u« n Hi 1WMcar. 11-1-CM328S - mum*# of m *m>* «,
5»W mmrnrnm mmmrn wmM * mvtHm tmim tm mm
prowtiwl, not ttw recocdls} raquaxtaa pwrtti! to fete (September 24,201$).
This i# mm cteniiil wf require another UtPA tawmiit, apparent^
Comment #2
On May 30,201 ft, the EPA trantfenwt pint ;! > '• fi-.-s,ui I j
SSptgH'llMtf 2fif w it'i'" "inr ¦'"V *.!• «*w »r.TVf*i if; i.
Hx-ll ti 1 l">>. r . t»\> I .! » i"1 . I i I I • TCI*!
Cesspool Ki#»fo«ft Project*to provide P« t. m v * v k a --.¦«<
ttenrirweten • WHatwwtai ImtMi* •• H'1 — tt* *» *»• «»f«wicf
PMCmml. 1 <> i ¦ >1 it, > . \ ,i • 1. p i • i' (i* • > i' v *fcplan*
You < iun 11 :j'.\ •!, _><•¦ .< is .¦ fitmmwtimmscru'i , ¦ >. >1 .n.i •. >>!<- "t
darning i «n» "«*%* « » mms par yew CB&tP*aifi-Wil»an Ofcamoto (hereafter
eiifefi U» Contracto«)May meetiine mliirtes., wbicta mum LUC »*iif¥ii»w at 15 acrac
j! H . f m . .i -H mm>>>:»• i|. -i:i»H«uramantoftheactual fcwtpnnt yov
(MMCflt].
Similarly, are yew tipng to «*•* Iht NEPA mmmmmrn of tm ewmutartw
tiMfjicti, elite im «*••: . is- -m>, s.-^ipaning
oum » » Ce«fi»¥ «oo»omy Nwt t* te#i«8 to ?«#•~«% tax bus# to law awl
wtii'tiIt*waftxpwitiu'r .> ts,r< " *i fc. ,<-i0»aod
163 i»ws«M<*s en iCCs'?
„]» M> if 0
76
Bmmm fm tm csmpM^ » mM MEP#HEP* »im.ts
» WBslstr I* EiwtmiMMimlSpacraaAd Sec ? I» m si t«, t tv- 1 n •
iiKlifWPAaetf _,t'.v,r,i.u',>u .it.1.1 "I,r-Wnih-.t-K., , • • > i ;|fe»
WwltealaHuPwjacttyaa^proteiigBMiai^ . ». * > i-.-.n. »t imi k i .i- *i »i
II* mm tint l an mm* mmmft, iffoi*. h-j.« .. <#.->¦ i- ¦ • ,< ¦ i,
sui in SS days
I am fcwiif * m to «he NaaMw U>«y ttxmr» »» 9m m*. Immmm »i «>H m
immf mrnpwim^ AWwuRh t'Imm hhnm C«ss»I«ii# part*smtws mDom
itw County am Fadwal «•»!, no 4m>rm«i l»»s Dmr powM to ma upon mf mmA
jou
Siiaijfe SiNwr*
c>mmm ci*#;
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77
CowDf«itH*Mrt
emmmmitm a» Emmmownm
WiWWrt S«,S#«
Mfltk WW»
SS»«t#«i -Tdwhecw
ie»*f-lai« - F«ei*»iii(
s»iif mm mmtge m mttimtmrn.
•—4w9mirnmmm~-
f,mn fen*.
To • i i,. . t. ,4 ,,
M*t.
ny mm*t it# mm m
* you m rn pftmpfr fP«wtk tmm mootl*. * mill m.* pu (w Hum
Bui-Mis.
78
111 li-ws t%'«isui*fc 14 (llptf 1""% ;|01K>l1SOm«l(»:lf
1»5*1 lil mw
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79
s»ti,«rAti»ch«l: Sandra Demofueil* Commmit #5 PAHALA BlJVA#HSl and bwt taw
Opening on my computer m pirnsa sand ny Paiiato OfA copy!
" .VjfO*
w«.
Miltm WMimm OMmrto mm fmtm,
•gm* (Maitag *w mrnmtm of
l»SW!h«»»W»"i c! Mi ««r» WHIBf I»W1
«< (.IHMKHW9
-ftp
To: Ml dffc# af Eiwweoiwiit
s5i.Af" UaiMtaif awoK*-* 14 «**, »• in < * %» .4* k
.v * ¦¦ ¦¦ O' U ? C ^ f % I.
i liiwitaf *¦ i
\WMmmm
if. I «m an analog p*«cwt anyway, «o win ®ie>ff» fttaiefw Ittw#ry
shortly to iwiMf H to pm h»M copy -
Thank* f« «v .,-nn-p « Ti <«, f Mbtoml
Ob mm*. ****** m, -mm m m m am wrr, m ©•©» <* cmmmi ci«% cow
¦mOmmKmrnBMMmmm *mm mt* wo*
Stfwisi. '¦ \ >. - smmm
mm*m* «p**tr •*» «* i*«tp»tt»« ftw wtww < w «enw* <* «w ww.
(maw* if»«» «na «* •*« a
CMfM
) ¦¦¦ ,' ¦>¦¦ »¦'¦¦•¦ ¦¦¦¦ <
Pwewil le Chapter .141, HMi|
•. ¦ ... „\'s,
I am haw* toot* - mm after mto* half an twwr - mrnmtm 9m epa/coh
Pahala DEA/AFN$t
i >'<•; 'i I iri.i .t-b M.- . j ,t ' ; v, r , i '
1 Mm net m any frail* «mM« «hVw teky wcMmki PiA^0N» to w»
«•-»«# 9f0|Nt
-------
81
, liable
onMwferymrimimr.1lito«mMi-, . 1-¦ ¦ i. s. - ... y..;. - t m
cmrent i»«l* ©i Tli# BrmmmmataiNotice.
wniiii Quality Coiiiftj!
(MS) SilMIW
-------
«* »•« mmm «***
nm
0*111«..
84
Sij»f«;i S»ri*i Otmoruelle comment »§ attached - nciiwrao uro» km actum
ettlueiit flow
•'«' mmmm9f*murn
t.» f*si»»##»pt.fa« bnuMgcMM**^ «!»>».
»». R »M lift j«M I Ml HSi
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85
PAHAIA Sandra DEMORUEUE COMMENT M
COWMfNT rn - The WWTP I, tiu.it w ha,,* li»,»Ogal#af Will.
mmml flew reported f<» a larger papulation list in 2007 HA w» SO,000 rJri SO
the tjuh'.y tfcsign w too k,ge.
To paraphras* M Tammons in htr tn»irmw»ni tlmmKwmkmmvHuA
newsletter (Vof. i, m. 8 Nov. iSMfs ffW quutcd m*tw«l in taw type)
letiof Porfc, Uttif Vwuge sr »- l•,« l".i«rt$
SwioiK probtemt *»«" •*>"' irtHng to thoflttult'> 'r.nJ. v.-iy meetings held If
County of Hawaii Department of Environmental Managpmont contractor grown '
and c*MweH. B&C held niiitJnp April W -12* »r» « Task 1,2 af the
MmMm Community lm§* Capacity Cesspool (ICQ Rtphcemmt Project.
It* COHDEM plana to locate a full-size Wastewater Treatment Want, featuring
four open sewage lagoons, on property next to flit Kailelu Elemernary School,
To demonstrate how serious the COHDEM b tft put W* sewage phut next to a
school, toil November, the County started condemning private property and
acquire »family-owned ranch to* June 2018,
The prefafetMidentffiedty the communis wit be planed generally In two
tfth»nw«Mlity«Ml Comity (III* irfanned irww pW
*«V demand likely to (Wtop in Naafehu far the life of the mm
facilttfeij
86
Tht €fei$#i W&BM: Set
If all thn County Iwtl wanted wm rnmplaAC*With A««-W»t«f raqpinmente,
and With tht* Ip,wf (iKtruw lo th? tapsytr and pjryer §1 Sewagt-spt** user
f«s, i p»fc»blf would have explored afternative meant of sewage treatment ~
methodw, vuth as to^struftcd wetlands, are less capital -and
f,ihor-l«*wi»e than traditional treatment plant*. M the very least, It would
ham (nought Hit pfiittftei tnwtmant plant's $lt# more til In* wfth mMk
demand projection* unit would haw dwlopprf A tirtH-tiitefer cotntrudtan to
nmmmm the Naatehu ice problem.
Once again, is with tht Mile sewage plant in 1989, mm of then cowra was
pwsuad. Whan cttum fttaseitei aftanwtive tnatment method*. tht Ihim
••I iceonipiiifing information wm ignored in the im'g RfSmMStS TO IVBLK
emmmrs m the *oc rnmtomm B, No r«i of *m ***mr itaKlttii af
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WILSON OKAMOTO
COUP T t § II
10349-01
March 6, 2020
ref (23a)
Ms. Sandra Demoruelle
P.O. Box 588
Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for the
Pahala Large Capacity Cesspool Replacement Project
District of Ka'u, Havvai'i
Response to Comment - USPS October 23, 2018
Dear Ms. Demoruelle:
Thank you for your October 23, 2018 comments sent via the US Postal Service (USPS)
regarding the County of Havvai'i Department of Environmental Management Draft
Environmental Assessment (EA) for the Pahala Large Capacity Cesspool Replacement project.
Our responses follow (note that the page numbers referenced are "as received" with Page 1 being
the first page of your comment submittal):
Pages 2-4:
The Draft EA Section 2.7 provides a the discussion of the criterion used to evaluate various sites
for the treatment and disposal facility, including appropriate site characteristics, site accessibility
as it relates to the various requirements of the Administrative Order on Consent, and
environmental impacts. Further, the Draft EA Section 2.8 discusses the various site alternatives
which were considered for the PER and then no longer considered as they contained "fatal
flaws".
This information will be repeated in the Final EA.
Section 2.1.4 of the Draft EA provides a history of wastewater management for Pahala. As
stated, in 2003 C. Brewer requested assistance from the County to close their large capacity
cesspools as required by the Environmental Protection Agency. Section 2.14 discussed that,
around 2006, C. Brewer requested that the County construct and maintain a new and improved
sewer system for the Pahala community. A County Council Resolution approved the C. Brewer
request. In anticipation of C. Brewer's dissolution, the company proposed, and the County
agreed in April 2007, to enter into a formal agreement to construct and maintain a new and
improved community sewer system or assume maintenance and required service of the existing
systems by April 30, 2010. The Final EA will clarify that C. Brewer committed to complete the
line (called a lateral) between the residences and the property line at the edge of the public right-
of-way adjacent to the new collection system for specific private properties in Pahala and
1907 S. Beretania Street, Suite 400 ~ Honolulu, Hawaii ~ 96826 ~ (808) 946-2277
10349-01
Letter to Ms. Sandra Demoruelle
Page 2
March 6, 2020
Na'alehu. It was agreed, if the County did not complete its' portion of the work by April 30,
2010, it would assume pending and unfinished obligations to connect the new laterals installed
by C. Brewer to the residences and new collection system when complete. Thus, the project
includes connecting these C. Brewer laterals, which may now need to be replaced.
As outlined in the Draft EA Section 2.1.3, the County has been discussing the need for a new
collection system, treatment and disposal facility to replace the existing collection system and
large capacity cesspools (LCCs), with the community since 2004.
On December 13, 2008 and April 25, 2010, community meetings sponsored by Councilman Guy
Enriques were held at the Na'alehu and Pahala Community Centers, respectively, to discuss the
Na'alehu and Pahala Large Capacity Cesspool Replacement project. As part of the meetings, an
informational handout prepared by the County Wastewater Division, provided a history of the
project documenting that, in 2004, Mayor Kim's office used a ballot system to get input from
property owners regarding different wastewater treatment disposal alternatives for those property
owners connected to the LCCs who would no longer be served by the C. Brewer system after
LCC closure. As reported in the Draft EA Section 2.1.4, 87 percent of the returned ballots were
in favor of the installation of a new sewer collection system and a treatment and disposal system
to be operated and maintained by the County. The handouts indicated that Mayor Kim's office
advised the property owners the County would move forward with a new system for Na'alehu
and Pahala on November 5, 2004. Additionally, the handouts stated that public meetings were
held in both Na'alehu and Pahala in November 2006 to discuss the wastewater system
alternatives and the biggest challenge to date had been finding suitable land for siting a
wastewater treatment disposal facility in Pahala. The handouts also stated that all properties that
become accessible to the new sewer system would be required to connect in accordance with
Hawai'i County Code Chapter 21.
This information will be included in the Final EA.
The Draft EA Sections 4.1.1 Past, Present, and Reasonably Foreseeable Actions, 4.1.2 Actions
Considered but Excluded from Analysis, 6.2.2 Ka'u Community Development Plan, and 7 Public
Participation, references the Ka'u Community Development Plan (CDP) as considered in the
preparation of the Draft EA.
The Ka'u CDP Policy 90 states "Implement protocols for receiving community input at meetings
in Ka'u during capital project siting and design.
Notwithstanding that the Ka'u Community Development Plan was adopted in October 2017
(Ordinance No. 2017-66), the information above shows the County presented information to and
received input from the Pahala Community at meetings in Ka'u during project siting and
conceptual design.
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10349-01
Letter to Ms. Sandra Demoruelle
Page 3
March 6, 2020
Pages 4-6
The Na'alehu WWTP and Lono Kona project comments are not pertinent to the content of the
Draft EA for the Pahala Large Capacity Cesspool Replacement project.
Page 7:
There is no requirement to publish notices of public meetings like the "talk story" sessions you
mentioned in the Office of Environmental Quality Control (OEQC) The Environmental Notice.
OEQC may publish such notices on a space available basis.
Page 8-9:
Havvai'i Revised Statutes (HRS) Section 343-5 Applicability and requirements states under item
(c) (4) "A(n environmental impact) statement shall be required if the agency finds that the
proposed action may have a significant effect on the environment..." The criteria by which the
proposing agency makes the significance determination is provided in Havvai'i Administrative
Rules (HAR) Title 11 Section 200-12 (a) and (b) which states: "(a) In considering the
significance of potential environmental effects, agencies shall consider the sum of the effects on
the quality of the environment, and shall evaluate the overall and cumulative effects of an action,
(b) In determining whether an action may have a significant effect on the environment, the
agency shall consider every phase of a proposed action, the expected consequences.... and
the... effects of the action."
HAR Section 11-200-10 Contents of an environmental assessment includes "(9) Findings and
reasons supporting the agency determination or anticipated determination..." The Draft EA
provides this in Chapter 8 Findings and Determination. Neither HRS Chapter 343 nor HAR Title
11, Chapter 200 contain any requirement that all proposed wastewater systems require an
Environmental Impact Statement (EIS).
The Na'alehu WWTP comments are not pertinent to the content of the Draft EA for the Pahala
Large Capacity Cesspool Replacement project.
See EPA response to comment section.
Retained to address EA required for CIP.
HRS §343-5-1 states (a) Except as otherwise provided, an environmental assessment shall be
required for actions that: (1) Propose the use of state or county lands or the use of state or
county funds, other than funds to be used for feasibility or planning studies for possible future
programs or projects that the agency has not approved, adopted, or funded. The CIP program
reviewed annually by the County Council is not yet funded when passed.
10349-01
Letter to Ms. Sandra Demoruelle
Page 4
March 6, 2020
HAR 11-200-2 definition states: "Action" means any program or project to be initiated by an
agency or applicant. Further, HAR 11-200 states "Agency" means any department, office, board,
or commission of the state or county government which is part of the executive branch of that
government. The County Council is part of the legislative, not the executive, branch of the
County.
Page 10:
On March 15, 2018, the County mailed a letter stating a Draft EA is being prepared for the
County the Pahala Large Capacity Cesspool Replacement project along with Pre-Assessment
documents to a total of 47 agencies, elected officials and utilities requesting comments prior to
preparation of the Draft EA. In addition, on March 29, 2018, the County mailed Pre-Assessment
documents to 14 Native Hawai'i an Organizations requesting comments prior to preparation of
the Draft EA. The Draft EA Summary shows the list of those consulted prior to preparation of
the Draft EA. The Draft EA Section 10 shows those agencies, elected officials, utilities and
Native Hawai'i an Organizations that provided comments. Finally, the Draft EA Appendix A
includes reproductions of the comments and responses to those making comments.
In addition, the County submitted required information and documents to the OEQC related to
the Draft EA. Based on the County provided information, on September 23, 2018, notice of
availability of the Draft EA was published in the Office of Environmental Quality Control The
Environmental Notice. Subsequently, on September 26, 2018, a public notice was published in
the Hawai'/ Tribune Herald, West Hawai'/ Today newspapers, and the online Ka 'u News Brief.
The public notice was to announce the October 10, 2018 public information meeting to be
conducted by the County in Pahala to discuss the availability of the Draft EA and process for
submitting comments. The notice stated that the second part of the October 10th meeting was to
address Section 106 of the National Historic Preservation Act (NHPA) involving consultation
with Native Hawaiian Organizations (NHOs) and Native Hawaiian descendants with ancestral
lineal or cultural ties or cultural knowledge or concerns, or religious attachment to the proposed
project area. During the October 10th meeting attendees were invited to provide information
about the proposed project area.
On November 6, 2018, 11 copies of the Draft EA were delivered to the public libraries in Pahala
and Na'alehu. Subsequently, notice of availability of the Draft EA was republished on
November 8, 2018 and the comment period ended on December 10, 2018. The Final EA will
include the comments received and responses provided in Appendices F and G.
This information will be included in the Final EA.
The Draft EA for the Na'alehu project is not the subject of the Draft EA for the Pahala Large
Capacity Cesspool Replacement project.
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10349-01
Letter to Ms. Sandra Demoruelle
Page 5
March 6, 2020
Page 11:
The County Clerk has confirmed that Resolution 412 was not voted on by the County Council.
The Draft EA for the Pahala Large Capacity Cesspool Replacement project was jointly prepared
by the US Environmental Protection Agency (EPA) and the County of Hawai'i to address both
the National Environmental Policy Act (NEPA) and Hawai'i Environmental Policy Act (HEPA).
Please refer to Appendix F for EPA's response. After the procedural requirements of Section
106 of the National Historic Preservation Act have been completed and comments to the Draft
EA have been addressed, the EPA and the County will issue a Finding of No Significant Impact
and Final EA.
See response to Page 8 above.
Page 12:
HAR 11-200-7 Multiple or phased applicant or agency actions states that "A group of actions
proposed by an agency or an applicant shall be treated as a single action when (1) The
component actions are phases or increments of a larger total undertaking, (2) An individual
project is a necessary precedent for a larger project; (3) An individual project represents a
commitment to a larger project; or (4) The actions in question are essentially identical and a
single statement will adequately address the impacts of each individual action and those of the
group of actions as a whole." The wastewater projects at Pahala and Na'alehu are not phases or
increments of a larger total undertaking, are not precedents or commitments for a larger project,
nor are they identical. Hence, there is no requirement to consider them in a single environmental
review document.
See responses to Pages 2-4 and 10 above.
The Draft EA Section 7 also documents the 5 public meetings held in Pahala December 12, 13
and 14, 2017 to discuss the Pahala Large Capacity Cesspool Replacement project.
On September 10, 2018, letters containing information on the availability of the Draft EA, the
comment period, and the October 10, 2018 meeting were mailed to property owners with C.
Brewer lines and newlv-accessible property owners. On October 26, 2018 letters were mailed to
property owners with C. Brewer lines and newlv-accessible property owners informing them of
the extension of the public comment period to December 10, 2018.
This information will be included in the Final EA.
The Draft EA Section 7 will be revised to add that, on March 21, 2019, the County held another
meeting in Pahala which included a presentation to provide information on financing sources
available to owners of parcels which would become accessible to the new County collection
system. The purpose of the meeting was to fulfill a County commitment made in October, 2018
10349-01
Letter to Ms. Sandra Demoruelle
Page 6
March 6, 2020
to research financing options available to the newly accessible residents of the Pahala
Community by March, 2019.
See also response to Page 4 above.
The Draft EA, Section 2.8.2(a), discusses use of a community septic tank.
Further details for the use of community septic tanks are also provided in the Draft EA,
Appendix B, Section 7.5.1 and 7.5.2, including the need for a Department of Health (DOH)
variance from HAR 11-62-23.1 requirements (which must be renewed every five years), and the
need to provide for additional flow.
Page 13, A and attachment A Page 31:
HRS Chapter 343 Section 5 (a)(9)(A), states as follows: "(a) Except as otherwise provided,
an environmental assessment (emphasis added) shall be required for actions that: ... (9) Propose
any: (A) Wastewater treatment unit, except an individual wastewater system or a wastewater
treatment unit serving fewer than fifty single-family dwellings or the equivalent...". HAR Title
11, Chapter 200, which implements HRS Chapter 343, however, differentiates between "agency
actions" that utilize state or county lands or funds and "applicant actions" for which an applicant
must seek agency approval. Since the proposed action will utilize county lands and funds, it is
an "agency action" requiring compliance with HRS Chapter 343 and HAR Title 11, Chapter 200,
pursuant to which an environmental assessment is being prepared and processed.
Thus, the project description published by the OEQC in the September 23, 2018 issue of The
Environmental Notice OEQC was correct.
Page 13 B and Attachment B Pages 32-34:
HAR Title 11 Chapter 200-10 Contents of an environmental assessment does not include a
requirement for evaluating the fiscal impacts of a project on a County's budget or ability to
obtain funding.
Page 13 C and Attachment D Page 35:
The public outreach subcontractor did not prepare the Draft EA.
Page 13 D and Attachment D Pages 36-42:
This is not a comment pertinent to the content requirements of the Draft EA for the Pahala Large
Capacity Cesspool Replacement project; the Draft EA Section 5 includes federal cross cutter
analysis for both the Pahala Large Capacity Cesspool Conversion and Pahala Wastewater
Collection System parts that may also be funded by the State of Hawai'i DOH Clean Water State
Revolving Fund (CWSRF).
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10349-01
Letter to Ms. Sandra Demoruelle
Page 7
March 6, 2020
Page 13 E and Attachment E Page 43:
This is not a comment pertinent to the content requirements of the Draft EA for the Pahala Large
Capacity Cesspool Replacement project.
Page 14 F and Attachment F Page 44:
The Kealakehe Aeration Upgrade project is not a comment pertinent to the content requirements
of the Draft EA for the Pahala LCC Replacement project.
The Draft EA Appendix B is a Preliminary Engineering Report for the wastewater treatment
plant. Table 5.3, Section 5.5 of Appendix B provides a conceptual planning level construction
cost estimate of about $14.6 million for the secondary wastewater treatment and disposal facility
only. Table 5.3 does not reflect the total cost of the Proposed Action and does not include
planning, design, land acquisition, the collection system or past project costs. As stated in the
Draft EA Section 2.1.2, the project may be funded by the State of Hawai'i Department of Health
Clean Water State Revolving Fund which authorizes low interest loans for the construction of
publicly owned wastewater treatment works and an EPA Special Appropriation Grant. This
information will be included in the Final EA.
The Final EA will include the Final PER and related construction cost estimates for the Pahala
LCC Replacement project.
See also responses to Pages 8-9, 12, 13 A and 13 D above.
Page 14 G and Attachment G Pages 45-48:
The Elementary School Complex, the portion of campus closest to the treatment and disposal
facility within the Ka'u High and Pahala Elementary School campus, lies more than Vi mile
directly or about 1 miles away from the proposed treatment and disposal facility by road. From
the school, one must travel on a portion of the school parcel and on 5 streets to reach the fenced
wastewater treatment and disposal facility. The intervening streets access or abut residential
parcels and other land uses. The distance and intervening land uses show the treatment and
disposal facility is not located in close proximity to a school facility. This information will be
included in the Final EA.
Page 14 H and Attachment H Pages 49-50: The Draft EA Section 4 discusses the Cumulative
effects of the project.
The Na'alehu WWTP and its* proximity to the Na'alehu school are not comments pertinent to
the content requirements of the Draft EA for the Pahala Large Capacity Cesspool Replacement
project.
See response to Page 14 G above
10349-01
Letter to Ms. Sandra Demoruelle
Page 8
March 6, 2020
Page 14 I and Attachment I Pages 51-59:
The Draft EA Section 2.8 discusses wastewater treatment alternatives. Effluent flows greater
than 1,000 gallons per day are subject to Hawaii's Underground Injection Control (UIC) rules.
Use of a small capacity system to treat the wastewater generated by each privatelv-owned parcel
in the community currently served by the County operated LCCs would likely necessitate siting
multiple units within private property. As outlined in the Draft EA, Appendix B Section 7.5.4,
issues associated with individual wastewater systems include:
• locating the treatment units within developed private parcels, many of which are small
(less than 10,000 square feet) and significantly improved;
• insufficient land area within developed private parcels to effectively use dispose of
treated effluent without impacting adjacent parcels; and
• soil conditions and subsurface geology unsuitable for effluent disposal compliant with
HAR 11-62-34 requirements, potentially necessitating import fill soils or elevated mound
systems.
This information will be repeated in the Final EA.
Additional issues that would need to be addressed include: access for equipment, ownership of
the units, and operation and maintenance of the units in this remote location.
This information will be added to the Final EA, Section 2.8.2.
The financial impact of the project on individual newly accessible property owners was raised by
the community during the December 2017 public meetings as summarized in Section 7 of the
Draft EA and again during the October 10, 2018 meeting. Although not required by HAR Title
11, Chapter 200, the Department of Environmental Management (DEM) voluntarily convened an
additional public meeting on March 21, 2019 to gain further input from newly accessible
property owners and fulfill a commitment made in October 2018 to research and provide
financing options available for the newly accessible residents of the Pahala Community to
pursue.
Programs discussed included:
• US Department of Housing and Urban Development (HUD) with County of Hawai'i
Office of Housing and Community Development Residential Repair Program -
Community Block Grant Program, and
• US Department of Agriculture - Rural Development (USDA-RDA) Program.
As noted during the presentation, these programs may change in the coming years, and additional
options may be added to this preliminary list. Hawai'i Legislature, Senate Bill 221 SD1, which
could amend HRS Chapter §342D to establish a low interest loan program offering financial
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assistance to cesspool owners to connect to wastewater treatment systems approved by the
Department of Health was also discussed; however, this bill was subsequently not passed during
the 2019 legislative session.
This information will be included in the Final EA.
Page 15 J and Attachment J Page 60:
The proposed Paha la wastewater treatment plant (WWTP) 14.9-acre project site has been
developed to provide the necessary land area for the facilities needed to treat the incoming flows
and to dispose the treated effluent from the treatment processes. The proposed project site
minimizes the use of the adjacent lands which contain a commercial macadamia orchard. A
larger project site is not required. The special permit requirement applies to the proposed
WWTP parcel only, not to the proposed utility easements. The Draft EA Section 2.10.1 states
the County will apply for the required special permit through the Planning Commission.
Pages 17- 30: See response to Pages 2-15 above.
Page 31-62 (Marked A-J): These are duplicates of some of your other comments, attached as
reference material supporting the comments provided on pages 13-15 and duplicated on pages
28-30, to which we've responded. Responses to each were sent to you under separate cover and
will also be included in Appendix G of the Final EA.
For clarity:
Page 31 is Attachment A for both Pages 13 and 28: See response to Page 13 A above.
Pages 32-34 are Attachment B for both Pages 13 and 28: See response to Page 13 B above.
Page 35 is Attachment C for both Pages 13 and 28: See response to Page 13 C above.
Pages 36-42 are Attachment D for both Pages 13 and 28: See response to Page 13 D above.
Page 43 is Attachment E for both Pages 13 and 28: See response to Page 13 E above.
Page 44 is Attachment F for both Pages 14 and 29: See response to Page 14 F above.
Pages 45-48 is Attachment G for both Pages 14 and 29: See response to Page 14 G above.
Pages 49-50 are Attachment H for both Pages 14 and 29: See response to Page 14 H above.
Pages 51-59 are Attachment I for both Pages 14 and 29: See response to Page 141 above.
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Pages 60-62 are Attachment J for both Pages 15 and 30: See response to Page 15 J above.
Page 63: The Pahala and Na'alehu communities are not a single community, but rather are two
distinct communities that are located in different drainage basins. The Pahala community is
located about 11 miles north of the Na'alehu community. The US Geological Survey
topographic maps show the two communities are separated by five drainage gulches: Hionamoa,
Moaula, Punaluu, Nicole and Hulea. The topographic map shows these five gulches drain in a
generally west to east direction. These same maps show the Alapai Gulch located adjacent to the
western edge of the Na'alehu community drains from north to south. Thus, the distance,
separation and topographic configuration of Hawai'i Island shows the two communities are not a
single entity subject to a single project under federal and State environmental laws, including
analysis of impacts.
The Pahala and Na'alehu LCC Replacement Projects are not connected to each other and are
physically separated by a distance of 11 miles. Separate EA processes are being conducted for
each community's project. Cumulative impacts will be considered for connected projects as
required by HRS 343.
Consultation and informational meetings such as the ones held regarding connected actions
within appropriate geographic boundaries for this project on October 8 through 10, 2018 are not
mandated by and do not violate NEPA.
Pages 64 to 66: On October 19, 2018, the US EPA replied to this request stating, there was no
rationale provided why the request for "consulting party" status was appropriate for this project.
As such, the request for "consulting party" status under the National Historic Preservation Act
was denied. Further, the EPA stated the Na'alehu LCC replacement is a separate project that is
not part of the proposed action currently subject to environmental review by EPA. Comments
regarding the Na'alehu LCC Replacement project are not pertinent to the content requirements
for the Pahala LCC Replacement Project Draft EA.
Page 67: EPA has provided a response to your request under NEPA and the National Historic
Preservation Act requirements. HRS 343 and HAR 11 200 have no requirements or definitions
related to consulted party status for an EA.
Pages 68 to 96: These are duplicates of some of your other comments, to which we've
responded. Responses to each were sent to you under separate cover and will also be included in
Appendix E of the Final EA.
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We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
Project Manager
cc: W. Kucharski. COH DEM
D. Beck, COH WWD
S. Mendonca, COH WWD
K. Rao, EPA
C. Lekven, BC
P. Goodwin, ERG
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