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Mr. Jelani Shareem <br />Ms. Kate Rao <br />July 23, 2021 <br />Final EA Alternatives <br />The FEA analyzed a total of three potential treatment and disposal site alternatives. The <br />proposed project will remain within the same 14.9-acre project site that the FEA ultimately <br />recommended as the preferred alternative. <br />HAR §11-200.1-11 Conclusions <br />Based on the above preliminary evaluations, we believe the proposed project changes will fit <br />within the provisions of HAR § 11-200.1-11 and a written determination for use of prior <br />exemption can be filed with OEQC to satisfy the HRS 343 environmental review requirements. <br />Additional effort will be required to prepare a more comprehensive justification for the OEQC <br />filing; this letter is a preliminary review only. <br />Section 7 Considerations <br />The FEA discussed the impacts on related species listed under the Endangered Species Act <br />(ESA). As required by Section 7 of the ESA, consultation was conducted with the US Fish and <br />Wildlife Service (FWS). At that time, there was concern that the lagoons and constructed <br />wetlands could attract various species of waterbirds, including the listed Hawaiian coot (Fulica <br />alai), the endemic subspecies of the Hawaiian stilt (Hinnantopus mexicanus knudseni), and <br />Hawaiian goose (Branta sandvicensis). The proposed treatment and disposal facility does not <br />include open lagoons and constructed wetlands. Thus, the potential impacts to the listed <br />waterbird species would no longer occur. <br />Section 106 Considerations <br />Since collection system work described in the FEA would remain with no changes, the findings <br />of the previous determination by the State Historic Preservation Division (SHPD) concurrence <br />to consultation under Section 106 of the National Historic Preservation Act would not change. <br />Similarly, the determination under Hawaii Revised Statutes Chapter 6E would remain with no <br />changes. <br />We hope that this information is helpful in explaining the County's current direction with this <br />Pahala LCC project. Please contact Eric Takamura (808) 961-8333 <br />eric.takamurakhawaiicountygov or me at (808) 961-8099 ramzi.mansourkhawaiicounty.gov <br />should you have any questions. <br />Sincerely, <br />Ramzi Mansour, Director <br />CC: Brenda Iokepa-Moses, Deputy Director <br />Eric Takamura, Wastewater Division Deputy Chief <br />Malia Hall, Deputy Corporation Counsel <br />0 <br />