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12 August 2014
To Whom It May Concern:
We,the undersigned scientists,share a deep concern about the sewage treatment facility and pit
disposal located at Kealakehe, Kailua-Kona. Studies by marine scientists continue to show impacts
and evidence from anthropogenic sources(Johnson et al.2008,Parsons et al.2008, Dailer 2011).
In 2008, USGS scientist,Chip Hunt,gave a presentation about potential hydrological connections
between the disposal pit and our marine and coastal waters via inherent tracers.
The 2014 draft report by the Hawaii Department of Health designated the nearshore waters
outside of Honokohau as impaired under Section 303(d)of the Clean Water Act(CWA). In this
report,two nearby sites(Honokohau Beach and Pinetrees-Honokohau)had multiple violations of
water quality pollutants including turbidity and nutrients(total nitrogen,total phosphorus,
nitrate/nitrites,orthophosphate) (HIDOH 2014). Last but not least, it is clear that Hawai'i County
has no National Pollutant Discharge Elimination System"NPDES" permit for the disposal pit
dumping. Lacking a NPDES permit in and of itself is sufficient grounds for a CWA lawsuit.
It has been brought to our attention that the County of Hawai'i's chairperson for the Department
of Environmental Management has been referring to a dye study that was conducted in 1994 to
justify this continued dumping. However, by the County of Hawai'i's own follow-up progress
report,"these tests [by Aecos Laboratory for R. M.Towill in 1994] were inconclusive"(Waimea
Water Services, Inc. 1996). A more advanced study conducted in Lahaina,Maui took over 80 days
before the tracer was detected (Johnson et al.2013)in adjacent coastal seeps.
Those of us in the scientific community have a responsibility not only to do good research, but to
share those findings;and when necessary,to engage and be part of the solution. We are trained
to be good observers,and document what we see. Almost anyone who spends time in the ocean
can't help but feel wonder and amazement at the complexity of life there.
However,when those ecosystems are clearly being threatened by human pollution,we are
compelled to speak out:to sound a warning. It is in that spirit that we request an end to the
dumping of effluent at Kealakehe that is having negative impacts in the nearshore marine
environment. Given what we already know of the hydrology of this watershed (see Hunt 2008,
Johnson et al. 2008, Peterson et al.2009), it is unreasonable to think that sewage effluent going
into the disposal pit is not ending up in the ocean.
Coral reef ecosystems thrive in nutrient poor conditions,and research has shown that
eutrophication and bacteria released from wastewater and agricultural runoff has had deleterious
Gomm. No. tilg•Q.
Ref. To: M.C.
Ref. Date JAN. 2 3
Listed references:
Bell,P.R.F.1992.Eutrophication and coral reefs—Some examples in the Great Barrier Reef lagoon.Water
Research 26(5):553-568.doi:10.1016/0043-1354(92)90228-V
Fabricius,K.E.2005.Effects of terrestrial runoff on the ecology of corals and coral reefs:Review and
synthesis.Marine Pollution Bulletin 50(2): 125-146.do!:10.1016/j.marpolbul.2004.11.028
Hamnett,M.P. (Director,Hawaii Coral Reef Initiative,RCUH),L.Eldredge(Bishop Museum),K.Foster(US-
FWS),J.Leong(Hawaii Institute of Marine Biology,UHM), R.Nishimoto(DLNR-DAR Hilo),R.Richmond
(Hawaii Coral Reef Initiative,RCUH),C.Smith(Botany Dept.,'UHM),and W.Walsh(DLNR-DAR Kailua-Kona).
Letter to:William Kenoi(Mayor,County of Hawai'i),2011 Aug 31.2 pp.
Hawaii Department of Health(HIDOH).2014.2014 State of Hawaii Water Quality Monitoring and
Assessment Report:Integrated Report to the U.S.Environmental Protection Agency and the U.S.Congress
Pursuant to§303(d)and§305(b),Clean Water Act(P.L.97-117).Draft,April 2014.
Hunt,C.2008.Results of Sampling for Wastewater Tracers at and Near Kealakehe WWTP,Kona,Hawaii.
USGS/Hawaii Dept.of Health Cooperative Program—Wastewater Source Tracking—Briefing
presentation,March 2008.
Hunter,C.L.,and C.W.Evans.1995.Coral reefs in Kaneohe Bay,Hawaii:Two centuries of Western influene
and two decades of data.Bulletin of Marine Science 57(2):501-515
Johnson,A.G.,C.R.Glenn,W.C.Burnett, R.N.Peterson, and P.G.Lucey. 2008.Aerial infrared imaging
reveals large nutrient-rich groundwater inputs to the ocean,Geophysical Research Letters 35,L15606,doi:
10.1029/2008GL034574.
Parsons,M.L.,W.J.Walsh,C.J.Settlemier,D.J.White,J.M.Ballauer,P.M.Ayotte,K.M.Osada,and B.
Carman.2008.A multivariate assessment of the coral ecosystem health of two embayments on the lee of
the island of Hawai'i. Marine Pollution Bulletin 56:1138–1149.
Dailer, M.,C.Smith,and C.Glenn.2011.Preventing the introduction and spread of nutrient driven invasive
algal blooms and coral reef degradation in West Hawaii.Hawaii Coral Reef Initiative/NOAA Final Report.
Available at:http://www.hcri.ssri.hawaii.edu/fifes/research/pdf/Dailer_HCRI_NOAA Final_Report.pdf.
Waimea Water Services,Inc. 1996.Kealakehe WWTP Effluent Reuse and Management Project.Final
Progress(March 1996)Report on Effluent Discharge,Reuse,and Quality.March 1996.
Other sources of info:
Bowles,S.P.,J.Mink,and G.Yuen.2006.Geology and ground-water hydrology in the vicinity of Honokohau
Harbor:report by Waimea Water Services.Inc.,assisted by Mink and Yuen,Inc.,appendix G-1 in Kona Kai
Ola environmental impact statement,16.
Dailer,M.L., R.S. Knox,J.E. Smith, M. Napier,and C.M.Smith.2010. Using d15N values in algal
tissue to map locations and potential sources of anthropogenic nutrient inputs on the island of
Maui, Hawaii, USA. Marine Pollution Bulletin 60(5),655-671.