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HomeMy WebLinkAboutCOM 0620.073 2022-2024 p / Council Res.372-23 Calk PO From: David Hunt Sent: Monday, December 18, 2023 12:15 PM To: Council Testimony; Planning Internet Mail; Kimball, Heather; Lee Loy, Sue; Kierkiewicz, Ashley; Evans, Cynthia F.W.; Inaba, Holeka; Kagiwada,Jennifer; Kanealii-Kleinfelder, Matt; Galimba, Michelle M.;Villegas, Rebecca; Roth, Mitch D; Kanealii-Kleinfelder, Matt;Villegas, Rebecca;webmail@doh.hawaii.gov Subject: An opportunity for positive policy change, respect for our public trust waters, and compliance with the CWA. TO: =3 C") u C3 Dr. Kenneth Fink, Director, HI Dept. or Health K=3 ='G: webmailadoh.hawaii.gov ` Kathleen Ho, Deputy Director, HI DOH Environmental Health -- "" --' webmail doh.hawaii.gov c.:) HI County Planning - t. ...T... _L. planning@hawaiicounty.gov `' Heather Kimball heather.kimball@hawaiicounty.gov Sue Lee Loy • Sue.LeeLoy@hawaiicounty.gov Ashley Kierkiewicz ashler.kierkiewicz@hawaiicounty.gov Cynthia F.W. Evans cindy.evans@hawaiicounty.gov Holeka Inaba holeka.inaba@hawaiicounty.gov Jenn Kagiwada Jennifer.kagiwada@hawaiicounty.gov Matt Kanealii-Kleinfelder matt.kanealii-kleinfelder@hawaiicounty.gov Michelle M. Galimba michelle.galimba@hawaiicounty.gov Rebecca Villegas rebecca.villegas@hawaiicounty.gov Mayor Mitch Roth mitchd.roth@hawaiicounty.gov> We have an opportunity for positive policy change, respect for our public trust waters, and compliance with the CWA. Please help Hawaii move towards compliance and cooperation-rather than costly, disrespectful, and ineffective combativeness. • I offer my comments to the EPA below for your review and consideration. Comm. No , • Ref. To: grcilite Ref. Date J EC 1 9 2023 i EPA NPDES Guidance post "Maui County v. Hawaii Wildlife Fund" SCOTUS Ruling. epa.gov 0 https://www.regulations.gov/commenton/EPA-HQ-0W-2023-0551-0001 I am pleased to see the EPA finally taking at least some minimal steps towards "guidance" in this post County of Maui v. Hawaii Wildlife Fund SCOTUS ruling period. I believe, however, that there is more that the EPA can -and needs to do to in order to remedy the examples I will briefly outline below and the many similar or related cases across the US. More clear and specific procedures, rules and regs CAN be developed, implemented, and enforced to cover a vast majority of similar and related cases. In the state of Hawaii, on the Island of Hawaii, we have two "excellent examples" of a dysfunctional, improper, and rather egregious point-source pollution discharge process -which needs accountability, redirection, supervision, and recourse from the EPA. Case 1. Applicant "Hu Honua" clearly sought to circumvent the NPDES permitting process and the State of Hawaii was complicit in utilizing the UIC permit process rather than the NPDES permitting process. The state was repeatedly and strongly cautioned by myself and MANY other knowledgeable individuals and groups that this was in violation of the CWA. Case 2. Hawaii County Mayor Mitch Roth is, unfortunately, unilaterally following in Maui County Ex-Mayor Michael Victorino's pointless and wasteful footsteps, in seeking, foolishly, to attempt to re-fight an identical fight against bringing the Kealakehe Waste Water Treatment Plant's point-source pollution discharge into CWA compliance rather than using the time, energy, and public's money to simply negotiate a course of action to bring this plant and point-source pollution discharge into compliance. These two particular cases would be an excellent example for the EPA to utilize in developing a prototype process for CWA and NPDES compliance for many other jurisdictions and agencies in this era of post-County of Maui v. Hawaii Wildlife Fund SCOTUS ruling. Respectfully, David J Hunt, Honoka'a, Hawaii 2