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HomeMy WebLinkAboutCOM 0349.460 2006-2008 U N I V E R S I T Y O F N A W A 1 1 A T M A N O A Environmental Center December 21, 2006 RE:0756 Mr. Pat Blew Sea Mountain Five LLC 6 Mazin Lane Honolulu, Hawaii 96817 Dear Mr. Blew: Draft Environmental Impact Statement Sea Mountain at Punalu'u Kau District, Punaluu, Hawaii Sea Mountain Five LLC is proposing a project to develop a 434-acre property in Punalu`u, in the Ka'u district on the Island of Hawaii. The proposed development on the site includes single-family and multi-family residential units, two hotels, an 18-hole golf course, cultural/environmental center, light commercial uses, upgraded wastewater treatment facility, water reservoir, open space, recreational areas, and other supporting infrastructure. The plans call for up to 1832 units with approximately 300 units in hotel rooms. This review was conducted with the assistance of Tracy Wiegner (Mazine Sciences, UHH), Jason Turner (Marine Sciences, UHH), Davianna McGregor (Ethnic Studies, UHM), Jon Matsuoka (Social Work, UHM), and Luciano Minerbi (Urban and Regional Planning, UHM). In the interest of full disclosure, Davianna McGregor, Jon Matsuoka and Luciano Minerbi are working with Group 70 on an unrelated project, a hurricane evacuation study for the U.S. Army Corps of Engineers. General Comments Our reviewers took issue with a number of sections of the draft environmental impact statement (DEIS). They aze listed below by section and page number in the DEIS and Appendices. Chief among our concerns was the cultural impact assessment of the azea because of a significant Native Hawaiian population in the vicinity of the proposed development and the importance of protecting their right of access to the area's resources. We found the section on the shoreline and coastal waters to be inadequate especially the analysis of the impacts on the green sea turtles (Chelonia mydas; Honu) or hawksbill sea turtles (Eretmochelys imbricate; Honu'ea). We also found issue with the socio-economic and water quality analysis. Following our substantive comments is a section on minor issues. These are mostly editorial in nature. 3 ~-f~q.`~`o Comm. No. 2500 Dole Street, Icrauss Annex 19, Honolulu, Hawaii 96622-2313 Ref. To: Iraseaf- sd ~r Telephone: (806) 956-7361 • Facsimile: (806) 956-3960 Ref. ~Cte llir~ i9 ~nm An Equal Opportunity/Affirmative Action Institution Mr. Pat Blew Page 2 of 18 The one general issue that was not addressed in the DEIS is the appropriateness of this development in the proposed setting. The southern part of the Big Island is very rural in character. This proposed development would bring in a group of people that are substantially different than the current residents. This could be a positive development for the azea, but it is sure to have some negative impacts which need more discussion than this DEIS provided. This development might have been more appropriate if it were located closer to either urbanized azeas on the Kailua-Kona or Hilo. The proposed development also includes a resort. Anew resort is a major event in the locality and the creation of a resort and community corporation is an essential way to cope with the major impact that is inevitably created by the new development. This community based organization (CBO) is entrusted to ensure that promises and stipulations made are really carried out, that unresolved issues and those that may arise are addressed. In addition, this CBO would be responsible for the training of the local labor force to fill the new jobs and the new entrepreneurship opportunities that would emerge form the new development. CBOs were created on Oahu at Turtle Beach and West Oahu resort. The Sea Mountain developers should consider forming a CBO for this area if it insists on going through with its plans. Cultural Impact Study: Appendix F The study provides an adequate ethnographic overview of the historic resources and practices. However, it does not provide an assessment of ongoing contemporazy subsistence, cultural and spiritual resources and cultural practices. The territorial period is also weak. The most significant shortcoming of the report is that it should, but does not address the mandate to government agencies making decisions about land use in Hawaii by the Hawaii State Supreme Court in its ruling, Ka Pa'akai O Ka `Aina v. Land use Commission, State of Hawaii / 94 Haw. 31 (2000). The specific section of the ruling that the report should have addressed states: "In order for the rights of native Hawaiians to be meaningfully preserved and protected, an appropriate analytical framework for enforcement is needed. Such an analytical framework must endeavor to accommodate the competing interests of protecting native Hawaiian culture and rights on the one hand, and economic development and security, on the other . In order to fulfill its duty to preserve and protect customary and traditional native Hawaiian rights to the extent feasible, the LUC, in its review of a petition for reclassification of district boundaries, must - at a minimum -make specific findings and conclusions as to the following: (1) the identity and scope of `valued cultural, historical, or natural resources' n27 in the petition area, including the extent to which traditional and customary native Hawaiian rights are exercised in the petition area; (2) the extent to which those resources, including traditional and customary native Mr. Pat Blew Page 3 of 18 Hawaiian rights will be affected or impaired by the proposed action; and (3) the feasible action, if any, to be taken by the LUC to reasonably protect native Hawaiian rights if they aze found to exist. n28 The report does not document the cultural and natural resources used in the ongoing contemporary exercise of traditional and customary Native Hawaiian rights for subsistence, cultural and spiritual purposes in the project area. The consultant should have interviewed a broad range of subsistence fishermen and gatherers as well as cultural and spiritual practitioners. The seven kupuna provided meaningful accounts, however, as they say, they are no longer actively engaged, themselves, in ongoing subsistence fishing and gathering. For example, Makahiki ceremonies and festivities aze annually conducted at Punalu'u and yet there is no mention of this. The broader impact of the development on culture and the way of life in the area is not addressed. The consultant should have held at least one community meeting, if not more to receive input from the community on the impact of the development on the culture and way of life of the community. The consultant could also have met with Native Hawaiian and community organizations to receive input and information about ongoing subsistence, cultural and spiritual practices in the project area. Additional ethnographic sources that should have been consulted include: "The Polynesian Family System in Ka'u" by Mary Kawena Pukui; Russell Applegate's study of the trail systems in the project area; and the video Kapu Ka'u by Na Maka O Ka'Aina. The conclusion should include recommendations regazding a substantial setback to protect the coastal resources and substantial buffers to protect the cultural and historic sites. We provide below an initial list of coastal cultural resources that key informants could have been asked regarding a full range of potential resources in the coastal zone of the project area. Coastal Cultural and Subsistence Resources streams ponds `auwai (tazo irrigation ditches) lo'i kalo springs caves trails wahi pana (named places) sacred places dunes landings bridges surfing sites sandy beach _ fishing area. fishpond fish trap fish house hunting areas kilo i'a (fish sighting) Mr. Pat Blew Page 4 of 18 muliwai (brackish pond) anchialine pond trails salt ponds wells turtle nesting azea historic walls basalt veins for tools alae vein salt pans shrines salt gathering areas ko'a (fishing shrines) heiau (temples) historic sites cultural use areas ho'ailona (natural signs) sighting place lele (cliff jumping spots) native plants pu'uhonua (places of refuge) holua slides cultivation azea ]eina (jumping off point azchaeological sites for souls to cross over) burials kupe'e _ o'opu hihiwai/wi aholehole `anae steam bath areas bathing pools limu gathering azeas lava tubes _ subterranean water course petroglyphs kapu kai/hi'u wai azeas paddling areas artifacts view plane seasonal residential sites burial markers water caves birthing stones phallic stones Pohaku Kane coral reef estuary spawning grounds house sites po kane routes (night marchers) dams `aumakua (ancestral deities) domain The cultural impact assessment should also assess the impact of withdrawing water from the aquifer for the additional 1500 homes and 300-400 hotel units. The report refers to the neazshore springs along the coast which fronts the project azea. These neazshore springs are important to support the habitat of the marine species along this section of coast. Ground- water models on Molokai have shown that pumping 1.25 mgd of ground water would reduce ground-water flux to the neazshore azea by about 3% to 15%. Given the amount of water that will be withdrawn from the aquifer for this project, what will be the impact upon these coastal springs and the marine life that it supports. The mazine life is an important natural resource utilized for subsistence, cultural and spiritual purposes by Native Hawaiians and kama'aina in Ka'u. These flaws in the report make it inadequate to serve as an effective or valid Cultural Impact Study. Mr. Pat Blew Page 5 of 18 Groundwater Quality (p. 1-13) The DEIS states in paragraph 3 that "There are no indications, according to data produced in the engineering reports, golf course management plan and mazine biology report, that the project has significant potential to negatively influence groundwater." However, this was based upon a qualitative (non-enumerated) assessment of the coastal zone; essentially there was no quantitative survey of the mazine habitat, therefore the authors are in no way qualified to make such statements regarding groundwater effects. Further, the information provided on the potential influence of groundwater contradicts the work published by one of Group 70's consultants in the preparation of the DEIS (Dollaz & Atkinson 1992), which states that leaching 10% of the N from golf course fertilizer accounted for an increase in groundwater Nitrogen flux to the bay (Keauhou, HI) of 116%; leaching of 1 % Phosphorus resulted in 22%; at another site (Waikoloa, HI) levels were 229% (Nitrogen) and 400% (Phosphorus) in coastal brackish ponds and 80% at the shoreline. Obviously, nutrients from fertilizers can have a significant impact upon the groundwater of sites on the island of Hawaii. Flora and Fauna (p. 1-14) The DEIS states in the subsection on Fauna in pazagraph 2 "The project site is often home to nesting Hawksbill and Green Sea Turtles. Additional visitors in the area may cause damage to their habitat or interfere with their nesting patterns." This is an understatement of the possible impacts of such development upon sea turtles. For example, factors such as beach use, lighting, vegetation, and changes in beach chemistry can have adverse effects upon nesting sea turtles. Further, the negative impact of high anthropogenic nutrient flow into the coastal zone has obviously been ignored as detailed above. Coastal Water (p. 1-16) The statement that the nutrients will have not impact upon groundwater and/or coastal waters is misleading; see our statement on Groundwater Quality above. Topography, Soils and Drainage (p. 1-18) The scientific evidence for percolation having the stated effect upon groundwater is lacking; there is no evidence showing that nutrients and pollutants will be removed as it moves through the topsoil. In fact, data from the Dollar & Atkinson's (1992) paper contradicts this conclusion and states that increased nutrients added to the system will have an enormous effect upon the local nutrient budget. Coastal Water (p. 1-18) The statement in the second paragraph of this section "Long-term studies of turtle populations indicate that the numbers of turtles have increased, while the growth rate has Mr. Pat Blew Page 6 of 18 slowed." is true, although the authors reference the wrong Balazs & Chaloupka (2004) paper in making that distinction (the correct citation is listed at the end of this review). However, the statement "If the slowed growth rate is a result of decreased food sources (marine algae), the only effect of the project may be a benefit to turtle populations owing to an increase in algal growth through slight increases in nutrient fluxes." is not correct for several reasons: 1) The authors have already claimed that there "are no indications... that the project has significant potential to negatively influence groundwater" Although this statement is incorrect in the first place they cannot have it both ways. 2) If we correctly assume that there will be an enormous change in the nutrient (nitrogen & phosphorus) inputs to the system, the above statement is, at best, a dangerous oversimplification. For example, it is well known that significant nitrogen loading changes the physical structure and food web relationships in coastal communities, and thus changes fish production (Deegan et al. 2002). 3) There is local evidence showing that high nutrient loadings can have adverse effects upon sea turtles. For example, a case study investigating the waters off Honokowai, West Maui has shown that the area has an increase in anthropogenic nutrients, have subsequently developed frequent, substantial macroalgal blooms, and that the percentage of green sea turtles infected with fibropapilloma disease (an epizootic disease characterized by fibromas and papillomas lesions) has significantly increased. 4) Based upon the data presented here the authors do not know enough to make statements about the possible effects of increased nutrient inputs on turtles. Residential Component (p. 2-8) What is the range of prices for the residential housing? How much of the residential component will be targeted for resident buyers and second home buyers? Where will the work force housing be located? Resource Management (p. 2-9) The third paragraph of the DEIS states "Programs to protect the honu (turtles) will be in place with increased signage, education of staff and visitors and the use of resort personnel to assist in the management of the resource areas within the control of the resort " We do not believe that this level of protection will be adequate to mitigate the impact that the proposed development would cause. We have more to say about this issue in the section on Fauna below. Mr. Pat Blew Page 7 of 18 Wastewater (p. 2-13) If the first two statements "Biological nutrient removal will be included with the treatment process to mitigate down gradient impacts. (Figure 2-3) Additional filtration would occur via the irrigation process." Then we do not understand how the third can be true "No impacts to coastal waters are anticipated from use of recycled water for golf course irrigation." As we earlier pointed out, based on work published by Dollar & Atkinson (1992), which states that leaching 10% of the N from golf course fertilizer accounted for an increase in groundwater Nitrogen flux to the bay (Keauhou, HI) of 116%; leaching of 1% Phosphorus resulted in 22%; at another site (Waikoloa, HI) levels were 229% (Nitrogen) and 400% (Phosphorus) in coastal brackish ponds and 80% at the shoreline, nutrients from fertilizers can have a significant impact upon the groundwater of sites on the island of Hawaii. Solid Waste (p. 2-13) The documents states that a "recycling program will be encouraged throughout the project." What actions will be taken by the developer or construction company to make sure materials are recycled or that a recycling program is put in place? Does the developer or his/her consultants have a plan for a recycling program? Surface Water Features (Onsite) (p. 4-19) The authors continue to incorrectly state that lava rock has some ability to remove nutrient and pollutants and thus prevent it from reaching groundwater or nearby coastal waters; here they state "Due to the highly permeable characteristic of the underlying project soils, which consists predominantly of lava, it is uncommon for runoff to reach the sea coast. Runoff is usually infiltrated into the highly permeable soil and rock formations beneath to the underlying aquifers." Peer-reviewed paper by Dollar & Atkinson (1992) and others contradict these statements. Table 4-4 List of Bird Species (p. 4-35) The table list Lonchura punctulata, the Nutmeg Mannikin in an unitalicized bold letters. A note under the table indicates that "Bold Lettering indicates Threatened or Endangered status." Is the Lonchura punctulata endangered? If it is why isn't it discussed in the text on birds? If it is not a threatened or endangered bird why have the note under the table since it seems that no other bird listed is threatened or endangered. We also observed that there is a note indicating that an * (asterisk) "indicates native endemic species or sub-species," but it is not used in the table. Were any endemic birds found at or near the site and left off the table? Mr. Pat Blew Page 8 of 18 Cultural Resources (p. 5-1 - 5-2) In the section on Mitigative Measures there is mention of an Integrated Natural Cultural Resource Management Plan (INCRMP) that will be implemented to "address potential short term and long-term impacts of the proposed project...." Is the plan already written? Who prepared it and who will be responsible for its implementation? The investigators claim that because the coastal azea will remain largely undeveloped, traditional cultural practices of subsistence will remain accessible. They don't explain how mitigative measures will ensure access to subsistence grounds, how development may or may not affect the health and availability of subsistence resources, or where the subsistence areas lie. The statement begs a deeper, broader analysis that wasn't included. Air Quality (p. 5-3 & 5-4) In the section on mitigative measures near the bottom of the page, the DEIS states that "Use of wind screens and/or limiting the azea that is disturbed at any given time will also be considered." Who will decide if wind screens aze needed or grubbing will be limited and what are the conditions under which these measures can be taken? Without some effective guidance, conditions may never be deemed appropriate to apply these mitigative measures. If it's windy, and it usually is, then why not erect windscreens and grade small areas of the site as a sensible mitigative measure? At the top of page 5-4, the DEIS states that "[m]onitoring dust at the project boundary during the period of construction could be considered as a means to evaluated (sic) the effectiveness... necessary." Who will make the determination of whether this monitoring will take place? How will this monitoring be done? If this type of monitoring is considered, but rejected, what type of monitoring will be done? In the penultimate line in this section, it is stated that contractors will be encouraged to properly maintain their construction equipment. Who will be doing the encouraging? How will the public know that the contractor is in fact maintaining his/her construction equipment? What will happen if the contractor fails to maintain his/her construction equipment? Surface Water Quality (p.5-7) The first sentence under Probable Impacts states that construction activities will be monitored to ensure that fuel and other hazardous materials are not spilled. Monitoring is not a probable impact--it is a mitigative measure. The impact would be accidental spilling of oil or other hazazdous materials into the ground. Mr. Pat Blew Page 9 of 18 Ground Water Quality (p. 5-8) As a mitigative measure, construction activities will be monitored continuously to ensure that fuel and other hazardous materials are appropriately handled. Who will be doing this monitoring? Will it be the contractor or will a third party company be hired to make sure all the monitoring of equipment and people are actually done? Tsunami (p. 5-10) & Tsunami (p. 5-39 - 5-40) It is prudent not to built a resort in the historical tsunami inundation zone so its location should be moved inland to fully meet this requirement. In light of the 1975 tsunami that took two lives, it would seem the best mitigative measure is to move any structure out of the zone. Cultural Resources (p. 5-23) As one of the probable positive impacts of the project on cultural resources, it is mentioned that a cultural center will be provided. Who will manage and maintain this center? How will it be funded? The UHM Depaztment of Urban and Regional Planning (DURP) conducted a study of Kau for Queen Lilioukalani Children's Center (QLCC) (Univ. of Hawaii, 1999). The documents listed in the DURP report and maps of cultural and archaeological sites in the area, as well as the cultural study conducted for the Punaluu DEIS could be used to develop a cultural use plan to ensure that there are no use conflict between traditional and customary uses and the new residents of the resort and housing. Water Quality (p. 5-32 - 5-39) & Coastal Waters (p. 5-71 - 5-73) The proposed Sea Mountain project will affect the quality of groundwater, surface water, and coastal water at Punalu'u. Fertilizers, chemicals, and soils could be potential contaminants to these water types. It was surprising that the nutrient data collected for this DEIS was not compared to Hawaii Department of Health (HDOH) water quality standards. These standazds are used to evaluate whether a particular location is in or out of compliance with state and federal regulations. From the DEIS, it is apparent that the authors were aware of the standards because they used them to select which pazameters water samples should be analyzed for. Using data provided in the technical appendices of the DEIS, we compared measured concentrations of the water quality parameters sampled to HDOH standards. Nitrate and chlorophyll a (chl a) were consistently higher than the state standards at all the sites sampled (5 transects). TN, ammonium, and TP were also higher than the state standards at some of the sites sampled. The ratio of TN:TP for the coastal water sites at Punalu'u ranged from approximately 17 to 30, suggesting that these waters may be P-limited. The present conditions at Punalu'u (high nitrate Mr. Pat Blew Page 10 of 18 and chl a) suggest that current water quality conditions are conducive for phytoplankton blooms and possibly macroalgal blooms. These findings aze of grave concern because it is predicted that following completion of the golf course at Punalu'u, fertilization rates will approximately equal and be six times higher than the natural groundwater flux of N and P to the ocean, respectively. The consequence is that the nutrient concentrations in the groundwaters draining the golf course will be substantially higher and will elevate the concentrations to levels above the state water quality standazds. Additionally, and more importantly, the additional nutrients, particularly P, will elevate P-limitation of the phytoplankton and macroalgae and will allow them to bloom. Authors of the Mazine and Pond Assessment for Punalu'u (Appendix J) azgued that projected maximum increases in groundwater nutrient concentrations for this proposed development are below levels currently measured in West Hawaii. West Hawaii has unusually high nutrient concentrations in its groundwater and previous studies have documented that developments have enhanced the unnaturally high levels resulting in coastal water quality and coral reef degradation. As documented by the DEIS, nitrate and chl a concentrations already exceed HDOH water quality standards; further development can only increase their levels and the levels of other regulated water quality parameters, bringing them out of compliance, and possibly resulting in algal blooms. The DEIS states that nutrient "subsidies may be detectable" from the proposed development at Punalu'u, but are "unlikely to result in a change in biotic composition of the marine or pond communities." Yet, no data to this effect was presented. In fact, extensive literature exists documenting that increased nutrients to the coastal zone not only changes the composition of the biotic community, but can be ecologically and economically devastating. A good local example of this is off the west coast of Maui where nutrients from a sewage injection well have caused devastating macroalgal blooms (see our comments in Wastewater Disposal section). The DEIS also supposes that a change in water quality will not "have any effect on biotic composition of the area because such communities are already subjected to severe natural stresses: ' Macroalgae grow and thrive in these areas; additions of nutrients will only make them grow better, possibly out of control, and may result in blooms like those observed in Maui. Punalu'u `contains a large population of federally protected endangered turtles. Over the years at this site, there has been a decline in size-specific turtle growth rates, speculated to be caused by reduced food availability and quality. Turtle survey or inventory data were not present in either the Marine and Pond Assessment or the Biological Assessments. Yet, the DEIS stated that no abnormal chazacteristics for the turtle population at Punalu'u were observed. Additionally, statements were made regarding the potential impact of reduced water quality on the turtles. It is speculated that "small alterations in groundwater dynamics that may result from proposed project will not likely have any effect" on the turtles, and "should there be any effect of nutrient subsidies, it may be the augmentation of marine algal stocks, which are Mr. Pat Blew Page 11 of 18 the main food source of sea turtles which inhabit the areas." We disagree with this assessment for two reasons. First, high nutrients concentrations in coastal waters have been document to increase the level of bacteria in the water. High bacterial levels have been shown to result in a higher infection and disease level in turtles. Second, high nutrients levels have been shown to increase macroalgal production and also promote the growth of exotic and invasive macroalgae. This has been documented on the West Coast of Maui (see our comments on Wastewater Disposal). Even if nutrients increase macroalgal production, the types of macroalgae that respond to the nutrient subsidies may not be the type of algae that turtles eat. If this is the case, turtle growth rates could further decrease from the already low rates. The proposed mitigation and preventative measures to prevent or lessen the impacts of the proposed development on water quality are vague. It was proposed that lysimeters be installed around the property as a way to detect water quality problems ("an early warning system"). However, within the DEIS, the water quality parameters to be measured and over what period and how frequently they would be collected were not given. In addition, the DEIS did not state who would be responsible for sampling and maintain the lysimeter database. To accurately assess the impact of the development on coastal water resources, aBefore/Afrer Control/Impact (BACI) study is needed. For this type of study, baseline conditions at Punalu'u need to be established prior to groundbreaking and then monitored following the establishment of the development. This type of study is the only way to evaluate the impacts. Fauna (5-41 & 5-42) Punalu'u is a preferred habitat for federally protected threatened green and endangered hawksbill sea turtles (US Federal Endangered Species Act). Both turtles use Punalu'u beach. Green sea turtles rest, bask, and forage at Punalu'u, while hawksbill turtles nest there. Yet, no turtle surveys or inventories were conducted as part of the biological or marine and pond assessments for this DEIS. This is surprising because tourists and redients visit Punalu'u specifically to see the turtles. This is a major red-flag in the DEIS. Why was this type of survey overlooked? If the answer is because there is extensive historical data on turtles for this region, the next question becomes: why was this data not summarized in the DEIS? There should be a section that addresses the potential of human-turtle interaction and how the interaction might be mitigated. The DURP study of Kau for QLCC (as cited above) provides a land use and proposed zoning map that has a bigger buffer zone to protect the turtle resting and nesting ground. Zoologist and biologists should recommend what the proper size of the turtle protected beach and buffer zone should be, certainly greater that the one provided in the current DEIS. Mr. Pat Blew Page 12 of 18 Wastewater Disposal (p. 5-58 - 5-62) During development of the Sea Mountain resort, the sewage treatment plant (STP) at Punalu'u will be upgraded from its current state of disrepair to a facility with R-2 treatment. Within the DEIS, there aze conflicting statements about whether R-2 level treated sewage can or should be used on the golf course as fertilizer. "R-2 level treatment is approved for disposal to golf courses according to State Guidelines with a 500 foot setback to dwellings." "R-2 treatment no longer meets DOH requirements for reuse or disposal and R-1 treatment level is required." From an environmental and economical standpoint, it is in the best interest of the development to have the highest level of sewage treatment to reduce the possible impacts of the sewage on coastal water quality. This is especially important given the current environmental conditions in West Maui. Here, nutrients from tertiary-treated sewage injected into a well have caused macroalgal blooms. These blooms have severely impacted coral reefs and resulted in millions of dollazs in lost revenue from hotels and rental properties. Hundreds of thousands of dollars have also been spent in Maui to remove the odorous macroalgae from the beaches. Increased documentation of turtles with tumors has coincided with these algal blooms suggesting that the degraded environmental conditions have increased the prevalence of disease among the turtles. This being stated, the treatment level at Maui is much higher than that proposed for Punalu'u. A STP with tertiary treatment should be seriously considered for the Sea Mountain development to reduce potential coastal waters impacts. Power and Communication (p. 5-63 & 5-64) There seems to be a lack of imagination when it comes to the provision of power to the proposed development. Is the only way to get power to the development through HELCO? Couldn't photovoltiacs be built into the residential and commercial buildings to cut down on the need for oil fired generated power. After all the weather is mostly sunny with little rain; perfect conditions for photovoltiacs. How about wind energy? The trades are strong in the southern part of the Big Island and there are already some windfarms in the azea. Why doesn't the developer build a wind farm neaz by to generate power that can offset the use of oil fired power? These options may add cost in the short run but will pay off in the long run as oil prices go up and oil supplies become more tenuous. Rousing (p. 5-64) In every rural community, especially those with sizeable populations of Native Hawaiians, resort and resort related housing development has led to substantial increases in the cost of housing and subsequent property tax hikes. Unless there is a definite plan to build sufficient affordable housing, it is highly predictable that escalating fee simple housing costs and rents will price many rural dwellers, particularly Native Hawaiians out of the housing mazket. This is happening statewide leading to prevailing economic hardships that predispose Mr. Pat Blew Page 13 of 18 many to homelessness. That the LLC has "made contact" with the Department of Hawaiian Homelands (DHHL) to discuss partnerships in affordable housing development is a start towards addressing the problem. While the intent of partnering with DHHL is a noble one, initial contact is far removed from a done deal. The notion that "housing impacts are positive" is based on an extremely simplistic and self-serving analysis. Resorts aze magnets for out of state investors and migrant hotel workers. They lead to population growth. Without adequate affordable housing the basic economic principle of "supply and demand" will create housing shortages leading to higher costs. Furthermore, the analysis of economic and job market improvements did not take into account rising cost of living impacts (i.e. housing) with job types and salary levels. We know too well in Hawaii that salaries are not commensurate with cost-of-living increases and thus working adults, especially parents aze subject to increase stressors related to making ends meet. Community's Perception on Tourism (p. 5-67) A recent survey sponsored by the Hawaii Tourism Authority found there is a declining support for towism and the public sentiment is that it isn't good for families. Tourism as well is being blamed for a declining quality of life for island residents. This being the case, what would make this development proposal any different from those that have cumulatively led to this type of public perception? Interestingly, this issue and study citation was raised but not addressed. Population and Employment (p. 5-65 & 5-66) To be useful the estimate of the jobs needed generated by the resort and housing should not be a single number but should be broken down by type of job. This breakdown should be compared against the one of the existing jobs in the area. This detailed analysis allows a better estimate of the actual new jobs that would be created, as some of the job needs may be met from those existing in the area. It is useful to sort out the temporazy jobs during constructions from the permanent jobs. The breakdown of jobs should be compared with the current labor force in the area to see the degree of match or mismatch between demand and supply of jobs so that appropriate actions can be made to prepaze the local labor force to qualify and feel the new available jobs. Resorts also lead to substantial demographic shifts. A younger, mainland workforce arrives, and thus replaces an older, local cohort. Also there is strong evidence that locals are generally relegated to the service-level positions while newcomers assume the best higher- paying managerial positions. This analysis and ways to mitigate this from happening was absent from the report. Mr. Pat Blew Page 14 of 18 Coastal Waters (p. 5-71 - p. 5-73) Potential impacts of the golf course on coastal water quality are similaz to the ones discussed in the Wastewater Disposal section (see our comments above). Mitigation and preventative measures to reduce potential impacts of the golf course within the DEIS aze vague. For example, it was stated that "turf will be thick enough to absorb and bind nutrients." No turf thickness was given and no references were provided on past studies examining turf thickness relative to its ability to absorb fertilizers. Additionally, specifics on buffers to be installed along the golf course to prevent groundwater and coastal water pollution were not given. The following quote from the technical appendices of the DEIS is an example of the lack of details given on golf course management plan. "The width of these rough buffer zones varies between blank and blank feet" (Appendix H, p. 7). Obviously, the authors of this study did not spend time to write a careful and considerate report, which should lead to serious questions about their proposed plan and its effectiveness. The DEIS states in the middle of page 5-72 that "Qualitative evaluation of neazshore marine biota indicates a very depauperate community that is the result of very rigorous physical conditions of salinity vaziation and wave impact. Hence, any changes in groundwater composition owing to the project would not likely have any effect on the biotic composition of the area as such communities aze already subjected to severe natural stresses." This is incorrect, we know that anthropogenic stress does not cancel natural stress, it increases the overall stress load significantly (Benedetti-Cecchi et al. 2001); severe natwal stresses, plus significant anthropogenic stresses, can lead to ecosystem failure Alternatives (Section 7.0) We would have liked to have seen a more robust discussion of alternatives. Specifically, the No Build alternative and those that meet community needs as they emerge from previous community meetings should described in more depth. Assessment of the Marine and Pond Environments in the Vicinity of the Sea Mountain Village at Punalu'u Project: Appendix J In section B. Marine and Pond Community Structure on page 3, the author states that "Weather conditions consisting of strong tradewinds, and accompanying high surf, that occurred during all days of fieldwork precluded safe underwater surveying of the outer reef areas off the project site. The offshore marine areas were qualitatively assessed by divers working from shore within the neazshore azea that was inside of the zone of breaking waves. Pond biota was assessed by divers wading through the ponds and qualitatively estimating abundance of biota." On page 8 of this appendix in section C. Biotic Community Structure 1. Marine Community Structare, the authors states that "As noted in the Methods section, weather conditions during the present survey precluded assessment of mazine communities Mr. Pat Blew Page 15 of 18 beyond the surf line. Examination of the accessible azea, however, provides a qualitative indication of the overall marine community structure of the neazshore region." From these descriptions it appears that no quantitative marine survey was conducted outside the neazshore area yet the author makes statements about the coral and invertebrate communities but no data on fishes. If quantitative surveys were not conducted on this site as part of the DEIS then the author cannot make statements regarding the status of, condition of, or interactions with said communities. On page 9 the authors state that "None of the results of this study indicate any abnormal characteristics to the Punalu'u turtle population." While this statement is correct it should not be taken as an indication that an evaluation of the Punalu'u green sea turtle or hawksbill sea turtle population was undertaken by the author of this appendix report or in any other part of the DEIS. On page 10 in the section on Discussion and Conclusions, the author notes that "While such potential increases are probably measurable, they would not likely cause any alteration to the marine and pond communities for several reasons. First, the maximum increases to groundwater nutrient concentration aze within the envelope of natural variability found on the Island of Hawaii" We disagree with this assessment. First, we note that many values aze higher than HDOH standazds. Second, we question the amount of "pristine groundwater" being collected from wells in West Hawaii (Kona). It is well known that West Hawaii has unusually high nutrient concentrations in its groundwater and previous studies have documented that developments have enhanced the unnaturally high levels resulting in coastal water quality and coral reef degradation. Therefore this appendix statement (and the statement in the DEIS) "In summary, it does not appear that any of the planned activities of the proposed Sea Mountain Village project will result in negative impacts to the marine and pond environments." is incorrect. On page 11, in the section on Discussion and Conclusions, the author notes that "In compazison to these natural factors, the small alterations in groundwater dynamics that may result from the proposed project will not likely have any effect. In fact, should there be any effect of nutrient subsidies, it may be the augmentation of marine algal stocks, which are the main food source of sea turtles which inhabit the area." As we pointed out earlier in our critique on Coastal Waters (p.1-18), it is a dangerous oversimplification regazding sea turtles, macroalgae, and nutrients. On page 12, in the Summary section, summazy point number 5 states "Qualitative evaluation of neazshore marine biota indicates a depauperate community that is the result of very rigorous physical conditions of salinity variation and wave impact. Hence, any changes in groundwater composition owing to the project would not likely have any effect on the biotic composition of the area; as such communities are already subjected to maximal natural stresses." As noted by the author, the marine survey was qualitative therefore we find it Mr. Pat Blew Page 16 of 18 difficult to believe that the author can make these statements regarding that community or the possible effects of changes in groundwater composition upon them. On page 12, in the Summary section, summazy point number 6 states "Evaluations of changes to groundwater from golf course irrigation are estimated to potentially add up to 10% to the concentration of total Nitrogen, and 6% during normal operations and 15% during grow- in of total Phosphorus. While such subsidies may be detectable, they aze not likely to result in any changes to the composition of marine or pond biotic communities. Groundwater concentrations of N and P in the ponds are already high, and non-limiting to pond biota. Hence, the estimated maximum subsidies would not likely change the overall nutrient dynamics as exists at present. Such subsidies also would not have an effect on the neazshore marine environment as mixing processes are sufficient to remove the input from land within a very narrow neazshore zone." The author fails to mention that the projected addition of 10% total nitrogen (a conservative estimate) can lead to a 440% increase in the nitrogen outflow into the neazshore coastal system as noted in Dollar & Atkinson (1992). Minor Issues Lava Flows (p. 1-14) What is the difference between the Zone 3 in the first sentence and zone " 3" in the second sentence? Both sentences seem to say the same thing. Abandoned and Unmanaged Facilities (p.3-3) In line 2, correct the spelling of "ears" to "yeazs." Flora (p. 4-27) The first sentence refers to the objectives of the survey, but does not cite what survey the authors aze talking about. Is this one of the surveys that was conducted for this project and included as an appendix to this report? Remove reference to feral cats, dogs, pigs and other animals in the flora section since they are already covered in the fauna section on page 4-34 Coastal Dry Forest (p. 4-34) On line 7, the DEIS refers to a Figure 1 which we could not find. Did you mean Figure 4.9? Mr. Pat Blew Page 17 of 18 Flood, Hurricane, Tsunami, Lava Flow, Earthquake and Wildfire Hazards (p.5-9 & 5-10) All the phenomena listed in section 5.1.8 with the exception of wildfires are probable long-term impacts. There are no short-term impacts of floods, hurricanes, tsunami, lava flows or earthquakes except as they may affect the construction crews and equipment if one or more of these strikes during the workday. In that case the mitigative measure should be to immediately leave the area and seek shelter some where else. Fauna (p. 5-12 & 5-13)) The impacts and the mitigative measures listed in this section on short-term impacts on bird resources should be listed in the section on long-term impacts since lighting and golf course chemical application will continue long after the construction phase of the project is completed. These potential impacts will continue throughout the life of the project. Mitigative Measures (p. 5-17) Something is missing from bullet point 3 on this page. Ground Water Quality (p. 5-38) The word "coastal" is misspelled (costal) in the second paragraph just before the word "ponds." Table 5-11. Summary of Estimated Water Demand (p. 5-57) The figure in column two, fourth row, 12.68 seems incorrect. Should the figure be 1.268? Also at the bottom of the same page, in the penultimate line, there should be a period after the word "Standards" not a comma. Solid Waste (p. 5-62) The word "pound" or its abbreviation "lbs." is missing after the word "six" in the second paragraph in the section of sound waste. References Cited in this Review Balazs, G.H. and M. Chaloupka. 2004. Thirty-year recovery trend in the once depleted Hawaiian green sea turtle stock. Biological Conservation 117 (5):491-498. Mr. Pat Blew Page 18 of 18 Benedetti-Cecchi, L. et al. 2001. Predicting the consequences of anthropogenic disturbance: large-scale effects of loss of canopy algae on rocky shores. Marine Ecology-Progress Series 214:137-150 Deegan et al. 2002. Nitrogen loading alters seagrass ecosystem structure and support of higher trophic levels. Aquatic Conservation-Marine And Freshwater Ecosystems 12 (2): 193-212 Dollar, S. J. and M. J. Atkinson. 1992. Effects of nutrient subsidies from groundwater to nearshore marine ecosystems off the Island of Hawaii. Est. Coast. Shelf Sci. 35:409- 424. Univ. of Hawaii, Department of Urban and Regional Planning., 1999. Ka `Ghana O Kahikinui Community Based Economic Development and Makai Management Plan- Moku of Kahikinui., Fall Practicum Report 1999. DURP: Honolulu Thank you for the opportunity to review this Drafr EIS. Sincerely, Peter Rappa Environmental Review Coordinator cc: OEQC George Atta, Group 70 International, Inc. Christopher Yuen, Hawaii County Planning Department James Moncur, WRRC Tracy Wiegner Jason Turner Jon Matsuoka Davianna McGregor Luciano Minerbi 0 University of Hawai `i at Hilo Department of Marine Science 200 W. Kawili St. Telephone: (808) 933-3114 Facsimile: (808) 933-0423 Apri13, 2007 The Honorable Mazie Hirono United States House of Representatives 1229 Longworth House Office Building Washington, D.C. 20515-1102 Dear Ms. Hirono, As you aze well aware, Punalu`u is a unique marine ecosystem that is home to a vaziety of endemic Hawaiian and federally protected species as well as cultural, historical, and ecological resources. We know that the nature of these balanced ecosystems is often fragile, and therefore may not respond well to anthropogenic impacts. Further, this area represents an environment like few others in the world; where people have the opportunity to view protected sea turtles in their natural environment. The University of Hawaii at Hilo has embraced Punalu`u as a "living classroom" and faculty have taught our undergraduate and graduate students here for almost three decades. For example, our Marine Option Program, affiliated with the Marine Science Department has assisted Mr. George Balazs of NOAA Fisheries in his effort to leazn more about the diet and movements of the green sea turtles (ChelonBa mydas) that reside there. Our students have been fortunate enough to work with the leading expert on green sea turtle biology in their own backyard, at a place where these animals come to feed and bask. Further, our students have and continue to conduct water quality monitoring of the neazby ponds the neazshore coastal environment. Obviously, Punalu`u is a natural resource that we must attempt to preserve, both to acknowledge its great importance to the past and provide educational opportunities for future generations. I would like to thank you for the opportunity to discuss Punalu`u as an important "living classroom", not only for the students at the University of Hawaii at Hilo but for all who visit here and learn about these unique ecosystems and protected species. Further, I would be happy to answer any questions you might have regarding this letter or our meeting. I can be reached at the following phone number (808) 933-3114 or e- mail address (jpturner@hawaii.edu). Sincerely, Jason P. Turner Assistant Professor Department of Marine Science University of Hawaii at Hilo Punalu`u - a living classroom for the Universit of Hawaii at Hilo y Green sea turtles (Che%nia mydas) in their natural environment 3 Decades of r Sea Turtle Research with Mr. George Balazs 0 NMFS / UH -MtSfY`~°~ ® ;°r- (NOAA Fisheries) OFFICIAL,, SEA TURTI~ RE pR ,,,,.,~~v Educational opportunities for students to study in unique marine habitats f . i 4 . ! - " Paaae u is a aatara~resvaree t/cat we ,Kart attearpt tv frrese~ve, 6at/c tv ac~row~ul~e lts~reat iar~a~ta~rce to tlce past a~rr( ~irvwc(e edacativaaevppa~t~i~~~a~~utare~eneratiaps.. 0 University of Hawai `i at Hilo Department of Marine Science 200 W. Kawili St. Telephone: (808) 933-3114 Facsimile: (808) 933-0423 November 16, 2006 Sea Mountain Five 6 Mazin Lane Honolulu, HI 96817 Re: Environmental Impact Statement, Sea Mountain at Punalu`u To Whom It May Concern: I have been asked to review the DEIS for the proposed Sea Mountain at Punalu`u development by the Environmental Center. As you are well awaze, Punalu`u is a unique marine ecosystem that is home to a variety of endemic Hawaiian and federally protected species. We know that the nature of these balanced ecosystems is often fragile, and therefore may not respond well to anthropogenic impacts. Further, this area represents an environment like few others in the world; where people have the opportunity to view protected sea turtles in their natural environment. I have major concerns with the DEIS written by consultants Group 70 International, Inc. including flaws in survey techniques, unsupported conclusions, and incorrectly stated facts pertaining to the ecology of mazine ecosystems. Although I will address my concems in greater detail below, I will summazize them here. 1. No sea turtle surveys were conducted. Although extensive data is available, they failed to reference any specific studies relating to population densities at Punalu`u for either foraging green sea turtles (Chelonia mydas; Honu) or nesting hawksbill sea turtles (Eretmochelys imbricata; Honu`ea). 2. No quantitative marine biological survey was conducted. The authors make extensive statements regazding these unsurveyed marine communities including the lack of effect of anthropogenic disturbance and nutrient load upon them. 3. Facts regarding effects of nutrients upon marine ecosystems are incorrect. The authors make statements regarding the potential for nutrient impacts upon the coastal zone which contradict existing peer-reviewed scientific literature previously written by a DEIS author (Dollaz & Atkinson 1992) and countless others. Page 1-13, Groundwater Quality, Paragraph 3. The authors state that "There are no indications, according to data produced in the engineering reports, golf course management plan and marine biology report, that the project has significant potential to negatively influence groundwater." However, this was based upon a qualitative (non-enumerated) assessment of the coastal zone; essentially there was no quantitative survey of the mazine habitat, therefore the authors are in no way qualified to make such statements regarding groundwater effects. Further, the information provided on the potential influence of groundwater contradicts the work published by one of the authors* of the EIS (Dollar* & Atkinson), which states that leaching 10% of the N from golf course fertilizer accounted for an increase in groundwater Nitrogen flux to the bay (Keauhou, HI) of 116%; leaching of 1 Phosphorus resulted in 22%; at another site (Waikoloa, HI) levels were 229% (Nitrogen) and 400% (Phosphorus) in coastal brackish ponds and 80% at the shoreline. Obviously, nutrients from fertilizers can have a significant impact upon the groundwater of sites on the island of Hawaii. Page 1-14, Flora and Fauna, Fauna, Paragraph 2, DEIS states "The project site is often home to nesting Hawksbill and Green Sea Turtles. Additional visitors in the area may cause damage to their habitat or interfere with their nesting patterns." This is an understatement of the possible impacts of such development upon sea turtles. For example factors such as beach use, lighting, vegetation, and changes in beach chemistry can have adverse effects upon nesting sea turtles (Lutz & Musick 1996). Further, the negative impact of high anthropogenic nutrient flow into the coastal zone has obviously been ignored as detailed above. Page 1-16, Coastal Water: The statement that the nutrients will have not impact upon groundwater and/or coastal waters is misleading; see above. Page 1-18, Topography, Soils and Drainage: The scientific evidence for percolation having the stated effect upon groundwater is lacking; there is no evidence showing that nutrients and pollutants will be removed as it moves through the topsoil. In fact, data from the Dollar & Atkinson (1992~paper rg eatly contradicts this conclusion and states that increased nutrients added to the system will have an enormous effect upon the local nutrient budget. Page 1-18, Coastal Water:, 15~ paragraph, "Along with the turf, additional nutrients will be filtered through percolation." Again see above. Page 1-18, Coastal Water:, 2nd pazagraph, The statement "There is little potential for impact to these populations from changes in water chemistry." This is not true. Interestingly when the base-line value for Punalu`u were presented there was no mention of how they relate to Hawaii Department of Health (HDOH) water quality standazds. HDOH standazds aze used to assess whether local water qualities are in compliance with state and federal regulations. Since the authors chose variables used by the HDOH to assess water quality one would think that a comparison between state standazds and existing Punalu`u levels would be warranted. However, they were not conducted by the DEIS authors. However, when we compare these levels recorded by the DEIS to state standards we found that nitrate and chl a concentrations at Punalu`u already exceed HDOH water quality standazds; further development can only increase their levels and the levels of other resulated water qualitypazameters, brineing them out of compliance, and possibly resulting in algal blooms. The statement "Long-term studies of turtle populations indicate that the numbers of turtles have increased, while the growth rate has slowed." is true, although the authors reference the wrong Balazs & Chaloupka (2004) paper in making that distinction. However, the statement "If the slowed growth rate is a result of decreased food sources (marine algae), the only effect of the project may be a benefit to turtle populations owing to an increase in algal growth through slight increases in nutrient fluxes." is not correct for several reasons. 1) The authors have already claimed that there "aze no indications... that the proiect has significant potential to ne atg ively influence groundwater" Although this statement is incorrect in the first place they cannot have it both ways. 2) If we correctly assume that there will be an enormous change in the nutrient (nitrogen & phosphorus) inputs to the system, the above statement is, at best, a dan eg rous oversimplification. For example, it is well known that significant nitrogen loading changes the physical structure and food web relationships in coastal communities, and thus changes fish production (Deegan et al. 2002). 3) There is local evidence showing that high nutrient loadings can have adverse effects upon sea turtles. For example, a case study investigating the waters off Honokowai, West Maui has shown that the area has an increase in anthropogenic nutrients, have subsequently developed frequent, substantial macroalgal blooms, and that the percentage of green sea turtles infected with fibropapilloma disease (an epizootic disease chazacterized by fibromas and papillomas lesions) has significantly increased. 4) Based upon the data presented here the authors aze not qualified to make statements about the possible effects of increased nutrient inputs on turtles. Page 1-19, Flora and Fauna:, It is very disconcerting that there is no mention of nesting hawksbill sea turtles here, nor do there appear to be any plans to account for there presence. The fact that the EIS does not acknowledge a Federally Protected Endan erg ed Species is inexcusable and shows that lack of scientific credibility that went into this EIS. For example, over the past 10 yeazs there have been 7 confirmed hawksbill sea turtle nestings at Punalu`u with many other false nestings, and unconfirmed nesting events. Additionally, 20 confirmed hawksbill sea turtle nesting events have taken place at adjacent Koloa and Kawa beaches, alone with numerous false nesting and unconfirmed nesting events (Personal communication, NPS biologists, 13 Nov 2006). Page 2-9, Section 2.2.5 Resource Management, "Programs to protect the honu (turtles) will be in place with increased signage, education of staff and visitors and the use of resort personnel to assist in the management of the resource azeas within the control of the resort." This level of protection will not be adequate to mitigate the impact that the proposed development would cause. Page 2-13, Section 2.2.6.4 Wastewater, If the first two statements "Biological nutrient removal will be included with the treatment process to mitigate down gradient impacts. (Figure 2-3) Additional filtration would occur via the irrigation process." Then I do not understand how the third can be true "No impacts to coastal waters aze anticipated from use of recycled water for golf course irrigation." Again, see above statements regazding the effects of anthropogenic nutrients upon coastal systems. Page 4-19, 4.10.1 Surface Water Features (Onsite):, Again the authors continue to incorrectly state that lava rock has some ability to remove nutrient and pollutants and thus prevent it from reaching wither groundwater or neazby coastal waters; here they state "Due to the highly permeable characteristic of the underlying project soils, which consists predominantly of lava, it is uncommon for runoff to reach the sea coast. Runoff is usually infiltrated into the highly permeable soil and rock formations beneath to the underlying aquifers." Again, the DEIS author's peer-reviewed nailer (Dollar & Atkinson 1992), contradicts these statements, as do countless others. Page 5-72, 5.2.15 Coastal Waters, Probable Impacts. Again the authors misstate the facts. They state that "Qualitative evaluation of neazshore marine biota indicates a very depauperate community that is the result of very rigorous physical conditions of salinity variation and wave impact. Hence, any changes in groundwater composition owing to the project would not likely have any effect on the biotic composition of the area as such communities are already subjected to severe natural stresses." This is incorrect, we know that anthropogenic stress does not cancel natural stress, it increases the overall stress load significantly (Benedetti-Cecchi et al. 2001); severe natural stresses, plus significant anthropogenic stresses, can lead to ecosystem failure. Page 711 of appendices: EIS "B. Marine and Pond Community Structure Weather conditions consisting of strong tradewinds, and accompanying high surf, that occurred during all days of fieldwork precluded safe underwater surveying of the outer reef areas off the project site. The offshore marine areas were qualitatively assessed by divers working from shore within the neazshore area that was inside of the zone of breaking waves. Pond biota was assessed by divers wading through the ponds and qualitatively estimating abundance of biota." From this description it appears that no quantitative marine survey was conducted. Page 718 of appendices: EIS "C. Biotic Community Structure 1. Marine Community Structure "As noted in the Methods section, weather conditions during the present survey precluded assessment of marine communities beyond the surf line. Examination of the accessible area, however, provides a qualitative indication of the overall mazine community structure of the neazshore region." Again, the authors state that no quantitative study was conducted of the site, yet they continue to make statements about the coral and invertebrate communities; no data on fishes. Again, if quantitative surveys were not conducted on this site as part of the DEIS then authors cannot make statements re ag rding the status of, condition of, or interactions with said communities (as the DEIS does in this section). The DEIS statements regarding "None of the results of this study indicate any abnormal characteristics to the Punalu`u turtle population." are correct. However, this does not mean that an evaluation of the Punalu`u green sea turtle or hawksbill sea turtle population was evaluated by the DEIS. Page 719 of appendices: EIS "While such potential increases are probably measurable, they would not likely cause any alteration to the marine and pond communities for several reasons. First, the maximum increases to groundwater nutrient concentration are within the envelope of natural variability found on the Island of Hawaii." This not necessarily true; many values are 1) higher than HDOH standazds and 2) I question the amount of "pristine groundwater" being collected from wells in West Hawaii (Kona). It is well known that West Hawaii has unusually high nutrient concentrations in its groundwater and previous studies have documented that developments have enhanced the unnaturally high levels resulting in coastal water quality and coral reef de¢radation. Therefore the DEIS statement "In summary, it does not appear that any of the planned activities of the proposed Sea Mountain Village project will result in negative impacts to the marine and pond environments." is incorrect. Further the DEIS statement that "In comparison to these natural factors, the small alterations in groundwater dynamics that may result from the proposed project will not likely have any effect. In fact, should there be any effect of nutrient subsidies, it may be the augmentation of mazine algal stocks, which are the main food source of sea turtles which inhabit the area." is a dangerous oversimplification; see statements above re arding sea turtles, macroaleae, and nutrients. Page 720 of appendices: EIS "5. Qualitative evaluation of neazshore mazine biota indicates a depauperate community that is the result of very rigorous physical conditions of salinity variation and wave impact. Hence, any changes in groundwater composition owing to the project would not likely have any effect on the biotic composition of the azea, as such communities are already subjected to maximal natural stresses." As noted by the authors, the mazine survey was qualitative; therefore they cannot make statements reeazdingthat community or the possible effects of chances in groundwater composition upon them. Page 720 of appendices: EIS "6. Evaluations of changes to groundwater from golf course irrigation are estimated to potentially add up to 10% to the concentration of total Nitrogen, and 6% during normal operations and 15% during grow-in of total Phosphorus. While such subsidies may be detectable, they are not likely to result in any changes to the composition of marine or pond biotic communities. Groundwater concentrations of N and P in the ponds are already high, and non-limiting to pond biota. Hence, the estimated maximum subsidies would not likely change the overall nutrient dynamics as exists at present. Such subsidies also would not have an effect on the neazshore marine environment as mixing processes are sufficient to remove the input from land within a very narrow neazshore zone. Authors fail to mention that the proiected addition of 10% total nitrogen (a conservative estimate) can lead to a 440% increase in the nitrogen outflow into the neazshore coastal system (Dollaz & Atkinson 19921. Page 720 of appendices: EIS "7. While Punalu`u Bay contains a lazge population of federally protected turtles, there is little potential for impact to these populations from changes in water chemistry. Long-term studies of turtle populations indicate that the numbers of turtles have increased, while the growth rate has slowed. If the slowed growth rate is a result of decreased food sources (marine algae), the only effect of the project may be a benefit to turtle populations owing to an increase in algal growth through slight increases in nutrient fluxes to the ponds and neazshore marine environment." The authors are not qualified to make such statements for reasons stated previously. I look forwazd to your response on the matter and will expect comments relating to all problems discussed above. Sincerely, Jason P. Turner Assistant Professor Department of Mazine Science University of Hawaii at Hilo I 1 University of Hawaii at Hilo Department of Marine Science U Dr. Jason P. Turner Assistant Professor 200 W. KawiB S[, MSB Rm.116 HBo, Hawaii 96720 Ph (808)933.3114, Fx. (806)933A423 Email: jp[ume[@hawaii.edu Web: http://www.mare.hawaii.edu/