2024-03-04 PL-SMA-2023-000046 Nohea Ka'awa Members of SMA2023-046 Working Group Opposition Testimony

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Affects or is likely to suffer damage by being in an environmentally sensitive area such as a flood plain, tsunami zone, beach, erosion-prone area, geologically hazardous land, estuary, fresh water or coastal waters. As it is critical to incorporate an imminent rise in sea level and other climate change effects into plans for future development, these impacts should also be considered when drafting an EIS. d). Phased Actions - Project Segmentation 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; 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 (Section 11-200-7, HAR) A proposed action must be described in its entirety and cannot be broken up into component parts, which if each is taken separately, may have minimal impact on the environment. Segmenting a project is generally forbidden. If a project includes a later phase that cannot be fully described in the current EA because it will be implemented in the distant future(as opposed to the "reasonably foreseeable future"), the EA should disclose as much detail as possible about the future phase. Should the future phase of such a project eventually be proposed, a new environmental review document will be required at that time. https://files.hawaii.gov/dbedt/ep2/OEQC Guidance/2014-GUIDE-HEPA-Citizens- Guide.pdf Waste water treatment plant (WWTP): Despite the statement in the SMA proposal that the WWTP can handle 100,000 GPD, we are not able to confirm that any recent upgrades have made this statement true. The DEIS 2006 states that: "The sewer plant is outdated and continued lack of maintenance may lead to contamination. The treatment plant is in very poor repair and the treatment system technology is over 35 years old. The treatment plant apparently was designed for a flow of 50,000 gpd but has seldom operated beyond a 10,000 gpd flow rate." Where is the solid waste buried and disposed of onsite, as described in the SMA proposal? According to the 2006 DEIS,"The sewer lift station located near the beach is currently inoperative. Little is known about the condition of the existing collection system and therefore will require inspection by video camera and repairs made or pipes replaced as required. The 2006 DEIS states that "Currently R-2 treatment no longer meets the DOH requirements for reuse or disposal and R-1 treatment level is required. The project's civil engineers have assumed that the treatment plant will be replaced when the new development begins. What are the plans to upgrade or replace the current substandard WWTP?