HomeMy WebLinkAbout2023-02-28 EMC testimony (02-27) Flaherty, ChuckSIERRACLUB
HAWAI'I ISLAND GROUP
February 27,2423
County of Hawai'i
Environmental Management Commission
34.5 Kektanao'a St.. Suite 41
Hilo. Hawai'i96720
Re: February 28,2A22Meeting Agenda Item VII.4.3.
Aloha Madame Chair and Members of the Environmental Manasement Commission-
After seeing the February Office of Environmental Quality Control's February 2023 Bulletin, the
Sierra Club Haw-ai'i Island Gronp became av/are the Hilo Wastewater Treatment Plant is on the
exemption list as shown below':
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In addition,the*23-01-17 Director's Report and Appendix" states
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"3. Hilo WWTP upgrades
The engineering contractor has conducted a two-day design workshop in Hilo on January 11
and 12. Phase I of the project remains on track for bids to be advertised in February 2023, with
bid opening anticipated in April 2023. The Phase 1 construction contract is anticipated to be
arvarded in .Tune .2023. Design of Phase 2 has begun. See also Appendix."
A large and substantial project that involves tens of millions of dollars. such as the Hilo WWTP,
does not meet the guidelines for exemption from an environmental assessment and does not
qualif"v for the exemption list. Exemption lists are limited to things like replacing pumps or
broken equipment and are not intended for large rehabilitation projects. Additionally. the project
listed as being exempted only represents the first phase and that the Department of
Environmental Management is planning and preparing bid documents for another phase.
Sierra Club urges.the EMC to require compliance ,"vith state environmental larv. Without an
environmental assessment- the impact of the scope of the work cannot be properly considered
beyond the price tag. Does it include much needed sewer line rehabilitation work to address
some 400,000 gallons per day oi infritration that inciudes saltwater that harms the biological
treatment process? Will it include new serice lines in Hilo to connect homes on cesspools?
What measures will be put in place during construction to prevent bypasses? What is the
expected capacity?
The purpose of our state environment laws is that projects must fully disclose what is being done
and what altematives were considered. as well as the impacts of theaction and the how these are
being addressed.
For many years, the Sierra Club HIG has been in very strong support of efforts to restore
compliance and end ongoing violations of the Clean Water Act. However. it does not suppoft
the dangerous precedent of improperly listing a project as being exempt when the project does
no1 conform to the exemption guidelines and is, therefore. in violation of state envilonmental
law-s.
Mahalo,W
Charles Flahertfl 6t ui.
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