2024-03-04 PL-SMA-2023-000046 Elsa Dedman Opposition Testimony

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• The SMAA should include the old abandoned derelict structures to control the environmental impact of these old abandon buildings that are leaking toxic chemicals hour by hour. These buildings were constructed in the 60's and 70's and a good chance they were constructed with toxic chemicals such as asbestos and lead base paint. Hundreds of people walk thru these structures each day and yet nothing has been done to resolve the seeping of toxic waste into the 'Aina, Sacred Historical Pond, Kai, and Air. • When Black Sand Beach, LLC acquired the property it appears there were no as built drawings and operational records transferred as discussed with Mr. Arai. The developer needs to submit their records for water testing of monthly purity and the current review of what is operational within their systems and what is not. In conclusion, the Waste Water Management System from sewage should also be tested and brought up to current standards. Currently, many water facilities in North America require that the waste water discharge is compatible for human consumption as type 1. I have been informed the current employees have stated that there are numerous problems within their systems and requested resources to repair the defects and funding is not available. Currently, the decrepit system can process only 20,000 gals of water per day and unable to increase its capacity to met any change in volume. A new Waste Water Treatment Plant must be completely reengineered and replaced as a complete system. • SEIS is required because existing wastewater treatment plant and technology are dilapidated to the point that it must be re-engineered and built as new. In addition, the U.S Supreme Court decision in County of Maui v. Hawai'i Wildlife Fund now applies to the wastewater treatment plant. The infiltration basins meet the definition of"functional equivalent" of a point source of pollution discharging into the U.S. navigable waters, therefore violating the Clean Water Act (CWA). • A CWA National Pollutant Discharge Elimination System (NPDES) permit is required in addition to a NPDES permit regarding stormwater discharges from the project site. It was not clear within the SMA how the stormwater system is managed and filtered on the site. • The current Waste Water Treatment filtering system must be upgraded so water injected into the subsurface systems are certified for palatable water for human consumption. As the water is injected into the underground aquafers and are fed directly into the water system in the bay; therefore, this is the only way the 5