HomeMy WebLinkAbout2024.05.13_Pahala Final EIDPAHALA LARGE CAPACITY
CESSPOOL CLOSURE
Final
Environmental Information Document
Prepared For:
Prepared By:
County of Hawai’i Department of Environmental Management
Wilson Okamoto Corporation
Pahala, Big Island, Hawai’i
May 2024
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TABLE OF CONTENTS
1. Introduction ................................................................................................... 1
1.1 Background .................................................................................................... 1
1.2 Previous Environmental Documentation ............................................................ 2
1.3 Project Location .............................................................................................. 3
1.4 Purpose and Need ........................................................................................... 3
2. Project Description and Alternatives ................................................................ 6
2.1 Proposed Action .............................................................................................. 6
2.1.1 Alternative 1: Package Plant with New Collection System ................................. 6
2.1.2 Alternative 2: Package Plant with Existing Collection System ............................ 21
2.1.3 Alternative 3 – Individual Wastewater System-Maintenance Contract Model ...... 23
2.1.4 Alternative 4 – Individual Wastewater System-Operating Permit to
Homeowners ............................................................................................... 25
3. Cumulative Effects ............................................................................................. 33
3.1 Scope of Analysis ............................................................................................ 33
3.1.1 Geographic Scope of Analysis ..................................................................... 33
3.1.2 Past, Present, and Reasonably Foreseeable Actions within Geographic Scope of
Analysis .................................................................................................... 34
3.2 Cumulative Improvements and Impacts Analysis ............................................... 35
4.Legal Framework and Regulatory Authorities ............................................ 36
4.1 National Environmental Policy Act (NEPA) of 1969 (as Amended) ........................ 36
4.2 Archaeological and Historic Preservation Act (54 U.S.C. § 312502) ...................... 37
4.3 Bald and Golden Eagle Protection Act (16 U.S.C. § 668-668c) ............................. 38
4.4 Clean Air Act (42 U.S.C. § 7401 et seq.) ............................................................ 38
4.5 Coastal Barrier Resources Act (16 U.S.C. § 3501)............................................... 49
4.6 Coastal Zone Management Act (16 U.S.C. § 1451) ............................................. 40
4.7 Endangered Species Act (16 U.S.C. § 1531) ...................................................... 47
4.8 Environmental Justice Executive Order 12898 .................................................... 48
4.9 Farmland Protection Policy Act (7 U.S.C. § 4201) ............................................... 49
4.10 Fish and Wildlife Coordination Act (16 U.S.C § 661) ........................................... 50
4.11 Floodplain Management (Executive Order 11988, as amended by Executive
Orders 12148 and 13690) ................................................................................ 51
4.12 Magnuson-Stevens Fishery Conservation and Management Act (16 U.S.C. § 1801)
..................................................................................................................... 51
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4.13 Marine Mammal Protection Act (16 U.S.C. §§ 1361 et seq.) ................................ 51
4.14 Migratory Bird Treaty Act (16 U.S.C. §§ 703 et seq.) .......................................... 52
4.15 National Historic Preservation Act (54 U.S.C. § 300101) ..................................... 53
4.16 Protection of Wetlands (Executive Order 11990 (1977), as amended by Executive
Order 12608 (1997)) ....................................................................................... 54
4.17 Rivers and Harbors (33 U.S.C. § 403) ............................................................... 55
4.18 Safe Drinking Water Act (42 U.S.C. § 300f) ....................................................... 55
4.19 Wild and Scenic Rivers Act (16 U.S.C. §§ 1271-1287) ......................................... 56
4.20 Clean Water Act (33 U.S.C. § 1251 et seq.) ....................................................... 56
5.Existing Environment, Impacts, and Mitigation Measures .................... 57
5.1 Climate .......................................................................................................... 57
5.2 Physiography .................................................................................................. 58
5.2.1 Topography .............................................................................................. 58
5.2.2 Geology .................................................................................................... 60
5.2.3 Soils ......................................................................................................... 61
5.3 Water Resources ............................................................................................. 62
5.3.1 Surface Waters .......................................................................................... 62
5.3.2 Groundwater ............................................................................................. 64
5.4 Agricultural Lands ........................................................................................... 65
5.5 Natural Hazards .............................................................................................. 67
5.5.1 Sea Level Rise ........................................................................................... 67
5.5.2 Flood and Tsunami Threat .......................................................................... 68
5.5.3 Hurricane and Wind Hazard ........................................................................ 68
5.5.4 Seismic Hazard .......................................................................................... 69
5.5.5 Volcanic Hazard ......................................................................................... 70
5.5.6 Wildfire Hazards ........................................................................................ 71
5.6 Flora and Fauna .............................................................................................. 72
5.7 Cultural, Historical, and Archaeological Resources .............................................. 75
5.8 Air Quality and Odors ..................................................................................... 77
5.9 Noise ............................................................................................................. 79
5.10 Energy and Natural Resources ......................................................................... 80
5.11 Land Use and Land Use Plans .......................................................................... 80
5.12 Roadways and Traffic ...................................................................................... 82
5.13 Hazardous Materials ........................................................................................ 84
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5.14 Socioeconomics & Environmental Justice ........................................................... 85
5.15 Sustainability .................................................................................................. 89
5.16 Human Health And Safety ................................................................................ 91
5.17 Unresolved Issues ........................................................................................... 93
6.Selection of a Preferred Alternative ....................................................... 94
6.1 Recommendation Factors ................................................................................ 94
6.1.1 Regulatory Compliance............................................................................... 94
6.1.2 Community Preference ............................................................................... 95
6.1.3 Environmental Risks ................................................................................... 95
6.1.4 Cost ......................................................................................................... 96
6.2 Action Items under the Preferred Alternative ..................................................... 96
7. Consultation .......................................................................................... 98
7.1 Early Consultation ........................................................................................... 98
7.2 Community Outreach ...................................................................................... 99
7.3 Draft EID Public Review Period ......................................................................... 100
7.4 Amended Draft EID Public Review Period .......................................................... 100
8. References ............................................................................................. 101
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List of Figures
Figure 1 Location Map ........................................................................................ 4
Figure 2 Alternative 1 Site Plan ........................................................................... 7
Figure 3 WWTP Overall Site Plan ....................................................................... 10
Figure 4 WWTP Operations Building Floor Plan ................................................... 11
Figure 5 In-Channel Cylindrical System .............................................................. 12
Figure 6 Aerated Grit Chamber .......................................................................... 13
Figure 7 Granular Activated Carbon Scrubber ..................................................... 14
Figure 8 Calcium Hypochlorite Feed System ....................................................... 15
Figure 9 Subsurface Drip Concept for Pāhala ...................................................... 17
Figure 10 Alternative 2 Site Plan ......................................................................... 22
Figure 11 Alternative 3 and 4 Site Plan ................................................................ 24
Figure 12 Typical Septic Tank System .................................................................. 27
Figure 13 Typical IWS with Absorption Tank ........................................................ 29
Figure 14 Typical IWS with Seepage Pit ............................................................... 30
List of Tables
Table 1.1 IWS Percolation Rate and Required Area ............................................... 31
Table 5.1 Demographic, Economic and Social Characteristics of Pāhala and Hawai'i
County ............................................................................................... 86
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1.Introduction
1.1 Background
This document is intended to address State and Federal Environmental Review Requirements of
the proposed Amended Administrative Order of Consent (Amended AOC) (Docket No. SDWA -UIC-
AOC-2017-0002, proposed February 14, 2024) Large Capacity Cesspool Closure (LCC)
requirements for Pāhala outlines that an Environmental Information Document (EID) must be
prepared by the County of Hawaii (County) Department of Environment (DEM) for US
Environmental Protection Agency (EPA) approval by July 30, 2024 to meet Federal Environmental
Review Requirements.
The Amended AOC §31.a. requires evaluation of four feasible options:
1.A package plant and new collection system (Alternative 1)
2.A package plant connected to the existing collection system (Alternative 2)
3.A maintenance contract model Individual Wastewater System (IWS) program (Alternative
3)
4.A County issued voucher program with an operating permit model IWS program
(Alternative 4)
In addition, to meet the requirements of the EPA, this EID will include:
5. A No Action alternative.
Unlike the previous AOC, which was initiated on June 22, 2017, the Amended AOC no longer
requires the WWTP provide secondary treatment of the sewage. As such, the IWS alternatives
provide a method to close the two LCCs without providing a secondary treatment process. The
package plant discussed below will provide the secondary treatment WWTP.
This document is intended to address State and Federal Environmental Review Requirements of
the Amended AOC, including the feasible options and a No Action alternative under the
direction of the County of Hawaii (County) Department of Environment (DEM). The
environmental review is to be consistent with requirements of the National Environmental Policy
Act (NEPA) 42 U.S.C. § et seq . and documented in the EID, including the necessary
consultation compliance with Section 7 of the Endangered Species Act and Section 106 of the
National Historic Preservation Act which will be updated for the Selected Alternative.
Supporting additional studies include Archaeological and Cultural documentation as well as
Botanical / Faunal Surveys and regulatory coordination as part of this EID. It is understood, the
County will coordinate with the State of Hawai‘i Department of Health (DOH) to ensure timely
review of studies, documents, and necessary concurrences by the State of Hawaiʽi State Historic
Preservation Division (SHPD) and the US Fish and Wildlife Service.
Within 30 days of receiving written approval of the EID, the County shall submit an
implementation plan for EPA approval. The Pāhala Implementation Plan shall include
a schedule and completion dates for each step required to implement the selected alternative,
provide wastewater services for 174 properties, and to close the Pāhala Community Cesspools
no later than January 22, 2027.
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1.2 Previous Environmental Documentation
In February 2020, the EPA and the DEM issued the Final Environmental Assessment (EA) for the
Pāhala Large Capacity Cesspool Replacement Project which was published in the March 8, 2020
issue of the Environmental Review Program’s The Environmental Notice. The Final EA discussed
the proposed wastewater collection system that would be located within five County-owned
streets in the western portion of the community (Maile, ʻIlima, Huapala, Hīnano, and Hala Streets)
and three streets in the eastern portion of the community (Puahala, Pīkake, and Kamani Streets).
The Final EA also discussed the County’s process for identifying alternative sites for the WWTP
and the selection of the preferred project site for the WWTP and effluent disposal system. A total
of 9 alternative sites were identified and assessed before selecting the 14.9-acre project site as
preferred alternative. As stated in the February 2020 Final EA, the development was to consist of
a headworks and an odor control unit, an operations building, four lined aerated open lagoons, a
subsurface flow constructed wetland to remove nitrogen and an adjacent disinfection system to
remove pathogens and four slow-rate land treatment basins for disposal of the treated effluent.
As set forth in the AOC dated June 22, 2017, the County was to provide an industry standard
wastewater collection system and a secondary treatment and disposal facility.
The February 2020 Final EA found no significant impacts are anticipated from construction and
use of the collection system and wastewater treatment and disposal facility. On February 24,
2020, by letter to the State of Hawaii Office of Environmental Quality Control (now Environmental
Review Program) the County DEM issued a Finding of No Significant Impact Notice (Joint
NEPA/HEPA) Pāhala Large Capacity Cesspool Replacement Project. The letter stated a Finding of
No Significant Impact (FONSI) is determined for this project. The basis for this determination is
set forth in the Final EA Section 8.1.1, which follows the significance criteria set forth in HAR,
Title 11, Chapter 200, Section 12.
Subsequent to the findings of the Final EA/FONSI, as part of the engineering design work,
additional geophysical/geotechnical investigations identified and confirmed a large subsurface
lava tube extended under the proposed aerated lagoons. Further, the community had not been
receptive to the aerated lagoon technology with large open lagoons and the potential for odors
to affect the community.
Based on these considerations, the DEM has determined not to proceed with implementation of
the wastewater treatment and disposal plant concept as previously proposed and to undertake
analysis of the four (4) options / alternatives as set forth in the Amended AOC and the No Action
alternative be evaluated for implementation in the Pāhala community.
The County intends to use funds either in part or in whole, from the Department of Health (DOH)
Clean Water State Revolving Fund (CWSRF) program and American Rescue Plan Act (ARPA) for
the Pāhala collection system and package plant project as was previously contemplated for the
lagoon concept.. Under the CWSRF program, the project consists of two parts: Pāhala Large
Capacity Cesspool Conversion and Pāhala Wastewater Collection System. The CWSRF Program
was created by the federal Water Quality Act of 1987 and authorizes low interest loans for the
construction of publicly owned wastewater treatment works. In 1988, the Hawaiʻi State
Legislature passed Act 365, now Chapter 342D of the Hawaiʻi Revised Statues (HRS), to establish
the State Water Pollution Control Revolving Fund to receive the federal capitalization grant. HRS
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342D, Part V (Water Pollution Control Financing), and, more specifically, HRS § 342D-81 set forth
that the State’s policy is to promote water pollution prevention and control, including the use of
recycled water, by financing eligible projects consistent with applicable federal and state laws.
The State Revolving Fund receives annual funding from EPA, which the State of Hawai‘i DOH is
then responsible for allocating among eligible projects.
1.3 Project Location
The community of Pāhala is located about 52 miles southwest of Hilo, in the Ka‘ū District, Island
of Hawaiʻi. The residential area of Pāhala is located west (mauka) of Māmalahoa Highway (State
Route 11 or called Hawai’i Belt Road) and about 3.8 miles from the shoreline. Most of the
community lies between 980 feet above mean sea level (msl) on the western end and
approximately 800 feet above msl on the eastern end. Figure 1 shows the Pāhala location map.
Even though Ka‘ū was one of the originally settled areas in the Hawaiian Islands, it remains a
vast remote area. Only a fraction of a percent of the Ka‘ū District has been developed with
residential properties, and the remainder is largely used for agricultural purposes or remains
undeveloped. The Ka‘ū District covers about 922 square miles (approximately 590,000 acres),
with over 80 miles of virtually undeveloped coastline. Nearly two-thirds of its total land area is in
the Conservation District. The Ka‘ū District consists of several communities, including the Pāhala
community, which had a population of approximately 2,210 persons according to the US Census
Bureau American Community Survey, 2021. The distance to the communities of Hilo and Kailua-
Kona means that the Ka‘ū District is relatively isolated from the major infrastructure systems
found in those communities, including wastewater treatment and disposal facilities.
The Project Area includes approximately 200 parcels (in whole or in part) and portions of eight
County of Hawai’i streets in Pāhala. The Proposed WWTP Site is located adjacent to the
intersection of Maile Street and Māmalahoa Highway within a 14.9-acre portion of Tax Map Key
(TMK): (3) 9-6-002-018. The Proposed Collection System Area will include five streets in the
western portion of the community (Maile, 'llima, Huapala, Hinano, and Hala Streets) and three
public streets in the eastern portion of the community (Puahala, Pikake, and Kamani Streets).
The two LCCs slated for closure are located within TMKs (3)9-6-002:016 (por.), LCC 1, and 9-6-
016:041 (por.), LCC 2.
1.4 Purpose and Need
A portion of the Pāhala community is serviced by a sewer system that was privately built, owned,
and operated by the C. Brewer Company (C. Brewer). The C. Brewer built sewer system
discharges sewage into two (2) large capacity “gang” cesspools. Around 2006, C. Brewer
requested that the County construct and maintain a new and improved community sewer system.
A County Council Resolution approved the C. Brewer request. In anticipation of C. Brewer's
dissolution, C. Brewer proposed, and the County agreed, to enter into a formal agreement to not
only construct and maintain a new and improved community sewer system but to assume
ownership of the existing system including the LCC's by April 30, 2010.
As part of this agreement, for the majority of Pāhala and Nāʻālehu properties connected to the
LCCs, C. Brewer committed to complete the line (called a lateral) between the residences and the
property line at the edge of the public right-of-way adjacent to the new collection system. It was
Island of Hawaii
Legend
Collection System
Disposal and Treatment Site
Streams
FIGURE 1
PROJECT LOCATION MAP
PAHALA LARGE CAPACITY CESSPOOL CLOSURE PROJECT
1 inch = 2,000 feet.
¯
0 2,000 4,0001,000 Feet
0 500250
Meters Mam alah oa Hig hway
ProjectLocation
Hilo
Pahala
Kailua-Kona
Honokaa
Waiaka Source:
State OP &
ESR I
CollectionSystem
Disposal andTreatment Site
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agreed, if the County did not complete its portion of the work by April 30, 2010, the County would
assume pending and unfinished obligations to connect the new laterals installed by C. Brewer to
the residences and new collection system when complete. Thus, because that date has passed
and the County has not completed installation of the new collection system, this project includes
connecting these C. Brewer laterals, which may now need to be replaced, or installing private
laterals for currently connected properties if authorized by the property owner and approved by
the County Council.
In 1998, the U.S. Environmental Protection Agency (EPA), promulgated regulations, 40 Code of
Federal Regulations (CFR) 144.14, that require the elimination of large capacity “gang” cesspools
(LCCs). In 1999, EPA issued regulations under the Safe Drinking Water Act's (SDWA)
Underground Injection Control (UIC) Program which prohibited the construction of new LCCs as
of April 2000 and required the closure of all existing LCCs by April 5, 2005 (40 C.F.R. § 144.88).
Under federal regulations, an LCC is a cesspool which serves multiple dwellings, or for non-
residential facilities has the capacity to serve 20 or more persons per day.
In June 2017, EPA and the County entered into an Administrative Order on Consent (AOC) to
close the LCCs serving the Pāhala community by June 2021. Options considered by the County
to close the LCCs include construction of a new sewer collection system located within public
right-of-way (ROW) and replacement of the existing LCCs with a wastewater treatment plant
(WWTP) to address the wastewater treatment and disposal needs of the Pāhala community. The
recently Amended AOC that was proposed as of February 14, 2024 requires the LCCs to be closed
no later than January 22, 2027.
The County of Hawai'i and the EPA voluntarily entered into the initial AOC for the purpose of
bringing the County into compliance with the requirements of the Safe Drinking Water Act
(SDWA), 42 U.S.C. § 300f, et seq.
EPA has determined that the County, as the current owner and/or operator of two (2) Large
Capacity Cesspools (“LCCs”) that serve approximately 109 private residences in the community
of Pāhala and three (3) LCCs that serve approximately 164 private residences in the community
of Nā‘ālehu, violated and continues to violate the SDWA and its Underground Injection Control
program requirements for existing LCCs.
A "cesspool" is a "drywell," which in turn is a "well," as those terms are defined in 40 C.F.R. §
144.3. LCCs include "multiple dwelling, community or regional cesspools, or other devices that
receive sanitary wastes, containing human excreta, which have an open bottom and sometimes
perforated sides.
Based on the above, the County has outlined that the purpose and need for the Proposed Action
is to comply with the requirements and mandates of the SDWA and Amended AOC, and to
ultimately close the two LCCs that serve Pāhala. Thus, purpose of this exercise is to evaluate,
gather community input, and make an informed decision on selecting an option or alternative
that will allow the County to close the LCCs, and provide a new, SDWA compliant solution for
handling wastewater generated by the Pāhala Community. Closure of the LCCs will eliminate the
disposal of untreated sewage into the subsurface which will serve County’s mission to protect
underground drinking water sources.
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2. Project Description and Alternatives
2.1 Proposed Action
The Proposed Action is to construct facilities which would allow the County to close the 2 LCCs in
Pāhala and thereby meet the compliance requirements of the Amended AOC and the applicable
portions of the Clean Water Act. The Proposed Action would be achieved by any of the 4
alternatives set forth in the Amended AOC and described below.
2.1.1 Alternative 1: Package Plant with New Collection System
Under this alternative, the County of Hawaiʻi would perform the following actions:
1. Acquire, or otherwise obtain the right to develop and use, a portion of the Tax Map Key:
9-6-002:018, a 42.5-acre parcel currently owned by B. P. Bishop Estate Trustees
(commonly known as Kamehameha Schools), then construct a new secondary wastewater
treatment and disposal facility within a 14.9-acre portion of the parcel; (See Figure 2)
2. Construct a wastewater collection system, primarily within the public right-of-way (ROW)
and three segments within easements in the Pāhala community, to collect and convey
sanitary waste from the currently connected and accessible (in accordance with Hawai’i
County Code) properties to the new treatment and disposal facility;
3. Close and abandon two LCCs, according to DOH closure procedures; and
4. Abandon the existing wastewater collection system in place.
These actions will be applicable to Alternative 1 and Alternative 2.
Package Plant
The Amended AOC allows for construction of a Package Plant to treat sewage currently being
disposed in the 2 LCCs. In addition, after treatment of the incoming sewage flows, disposal of
the treated effluent using a subsurface irrigation system. The following sections describe the
components and facilities which would comprise the package plant to treat the sewage and
dispose the treated effluent which would be applicable to Alternative 1 and Alternative 2.
The April 2023, Preliminary Engineering Report (PER) provides the technical information related
to analysis used by the County to select the package plant to be used to treat incoming sewage
flows and a method to be used for disposal of effluent from the wastewater treatment plant
(WWTP).
As described in the April 2023 PER, the package plant and effluent disposal method would be
accommodated within the 14.9-acre Proposed WWTP Site located near the intersection of Maile
Street and Māmalahoa Highway. For more information, see Appendix A.
Existing Large
Capacity Cesspool
(LCC 1)
Proposed Pahala
WWTP Site
Existing Large
Capacity Cesspool
(LCC 2)MEYER RDMEYER RDHAU STHAU STHA
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TPAKALANA STPAKALANA ST
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HOLEI STHOLEI STKOKIO STKOKIO STKEAHI STKEAHI STOHIA STOHIA STILIAU STILIAU STKAU
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PUAHALA STPUAHALA STPIKAKE STPIKAKE STLEHUA STLEHUA STMAILE STMAILE STHAWAII BELT RDHAWAII BELT RDHALA STHALA STPAAUA STPAAUA STP
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FIGURE 2
PAHALA LARGE CAPACITY CESSPOOL CLOSURE PROJECTPAHALA LARGE CAPACITY CESSPOOL CLOSURE PROJECT
ALTERNATIVE 1 SITE PLANALTERNATIVE 1 SITE PLAN
Ka’u High &
Pahala Elementary
School
Ka’u
Hospital
feet
00 1,0001,000 2,000
N
LEGEND
Lots to WWTP
Newly Accessible Lots to WWTP
Proposed Pahala WWTP Site
Pahala Future County Sewer System
Existing Large Capacity Cesspool (LCC)
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The PER indicated accurately quantifying flow projections for the Pāhala community is necessary
to design an appropriately sized wastewater treatment and disposal facility. The WWTP design
will need to provide sufficient capacity for the existing parcels within the service area, including
newly accessible parcels reflecting currently developed portions of the Pāhala community. This
will allow the County to close the LCCs. The design will provide sufficient area within the WWTP
site for future expansion of the package plant.
HAR Section 11-62-24(b) requires Counties to use their adopted wastewater flow standards to
develop flow projections for WWTPs. Counties are to use the City and County of Honolulu (CCH)
flow standards if they have not adopted their own standards. The County of Hawai'i has not
adopted its own flow standards, so wastewater flow projections were developed using the current
CCH (2017) wastewater standards. However, flow projections based the current wastewater
standards based on urban Honolulu are likely overly conservative for rural communities like
Pāhala.
The PER indicates the amount of wastewater generated within a residence will not exceed the
amount of potable water used by the occupants. Therefore, potable water use records can be
used to estimate wastewater generation rates within existing communities where no combined
sewers are present. The County of Hawaii Department of Water Supply (DWS) provided potable
water use records from January 2015 through June 2021 for the parcels located within the service
area. Analysis of the potable water use records indicates that a 40,000 gpd monthly wastewater
generation rate would reflect the current needs of the service area. Using a 2.5 peaking factor to
estimate the maximum wastewater flow into the collection system results in a maximum
wastewater flow of 100,000 gpd.
As stated in the PER, groundwater can infiltrate into wastewater collection systems during dry
weather, increasing flows to the WWTP. The 2017 CCH standards specify a dry weather infiltration
and inflow (I/I) allowance of 35 gallons per capita per day (gpcd). The previous CCH standards
(dated 1993) specified a dry weather I/I allowance of 5 gpcd for properties located above the
groundwater table. Through the County’s experience at the Honokaa WWTP evaluating dry
weather I/I for a rural collection system located in Hawai'i Island’s well-drained geology, at
elevations hundreds of feet above sea level and a significant distance from the shoreline,
continued use of the 1993 standard for dry weather I/I is appropriate for Pahala and using the
2017 standard would be overly-conservative.
The 2017 CCH standards specify a wet weather I/I allowance of 3,000 gallons per acre per day
(gpad). Due to larger parcels within the Pahala service area, wet weather I/I estimates are
modified as permitted by the 2017 CCH standards. The modified flows are based on a 50-foot-
wide corridor of sewer laterals from existing or assumed building foundations on the property.
These assumptions significantly reduce the wet weather I/I estimates for the collection system.
The PER evaluated the effluent flow records at the County Honokaa WWTP to provide an
appropriate analysis of the wet weather peaking factors expected at the Pahala facility. The results
of the Honokaa WWTP effluent flow analysis have determined that a peak day wet weather
peaking factor of 6.5 is recommended for the Pahala WWTP design.
HAR 11-62-23.1(i) requires the initiation of a facility planning process when the actual wastewater
flows reach 75 percent of the design capacity of the WWTP, and implementation of the facility
plan must be initiated when actual wastewater flows reach 90 percent of the design capacity. In
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anticipation of future development within the Pāhala community, the PER recommend the WWTP
design be rated to treat an average dry weather flow of 95,000 gpd (approximately twice the
projected average dry weather flow) to avoid the potential of having to initiate a facility plan
shortly after the project is constructed. Note, the biological processes in the mechanical WWTP
will need to be sized to treat the peak day dry weather flow of 108,000 gpd, not the average dry
weather flow.
Based on the above analysis the County applied to DOH for a variance from HAR Section 11-62-
24(b). On January 26, 2002, the DOH granted the variance, which must be renewed every five
years. The variance contains the following conditions:
1. As a minimum, the Pahala Wastewater Treatment Plant (WWTP) shall be designed using
an average dry weather flow of 95,000 gallons per day.
2. Plans for the proposed Pahala WWTP shall be designed in accordance with applicable
requirements of HAR Chapter 11-62 and be submitted to the Wastewater Branch for
review and approval. In addition, the WWTP shall be approved in writing before it may be
used.
3. There is no automatic renewal. Should the applicant wish to renew this variance
application, the applicant must submit an Application for Variance for renewal, 180 days
prior to expiration date.
The PER provides a description of the package treatment facility to be implemented at Pāhala.
Note, package plants typically consist of pre-manufactured treatment facilities/components that
may be configured to treat wastewater in small communities or on individual properties. The site
plan for Pāhala WWTP would occupy a 14.9-acre area within an existing macadamia orchard and
1,500-foot long by 25-foot wide utility easement within the 42.5-acre parcel near the intersection
of Maile Street and Māmalahoa Highway. About 4.0 acres of the 14.9-acre area would require
removal of the existing macadamia nut orchard to accommodate the facilities needed to construct
the package plant and related facilities. Thus, about 10.0+ ac res would remain as the macadamia
orchard which would be available subsurface disposal of the treated effluent. A security fence
would surround the 14.9-acre site. The security fence would not include barbed wire stringers.
Figure 3 shows the site plan for the WWTP.
The 4.0-acre package plant includes the headworks, grit drying bed, potable water tank, utility
or operations building which includes a blower room, an emergency generator room, electrical
room with a monitor control center, a maintenance and storage room, and restroom, an above
ground fuel storage tank, and an irrigation control tank. Figure 4 shows the operations building
floor plan.
As discussed below, the Pāhala package plant will include preliminary treatment, odor control and
secondary treatment, and disposal of the treated effluent. The preliminary treatment system will
include influent flow measurement, influent sampling, screening and grit removal.
Influent flow measurement is recommended in the PER to allow assessment of flows and loads
to the biological treatment process, and to assess the biological treatment process performance.
3
4
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A Parshall flume will be provided upstream of the screening system to continuously record influent
flow rates.
An automatic refrigerated composite sampler is recommended to allow influent composite
samples to be collected. Influent composite samples, when combined with influent flow
measurement, can be used to calculate influent mass loading rates to the WWTP to assess the
treatment performance and to optimize aeration rates in the biological treatment process.
Screening is recommended to protect the downstream system operations from large objects,
debris, wipes, and rags that can be present in wastewater. The industry trend is towards finer
screening systems that remove greater amounts of debris from the waste stream; screens with
6-millimeter (mm) (¼-inch) openings are frequently used for activated sludge treatment systems.
Finer screens are used upstream of membrane bioreactors to remove hair that can foul the
membranes.
The PER recommended an in-channel cylindrical screen for this installation. The in-channel
cylindrical screen combines screening, screenings washing, dewatering, compacting, and
bagging/disposal within a single unit as shown in Figure 5. For this installation, the headworks
will include one in-channel cylindrical screen, plus a bypass channel with manually cleaned bar
rack.
The PER stated, removal of grit is very important to help prevent wear to downstream equipment,
costly service interruptions and repair. Grit is comprised of particles that are heavier than the
organic biodegradable matter in wastewater. Grit particles can consist of sand, gravel, pebbles,
silt, cinders, ground bone, eggshells, coffee grounds, and other materials. Grit in the wastewater
collection and treatment system causes abrasive wear to mechanical equipment, piping, and
appurtenances. Grit can also form deposits in pipelines, channels, and tanks, which reduces
hydraulic capacity and can damage equipment.
Figure 5: In-Channel Cylindrical Screen
Source: PER, 2023
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The PER recommended use of aerated grit chambers which are tanks that function specifically to
remove inorganic solids from the wastewater stream as shown in Figure 6. Aerated grit tanks are
designed to induce sufficient vertical velocity to separate organic and inorganic solids. In theory,
inorganic solids have a higher specific gravity than organic solids, and therefore require higher
vertical velocities to keep them in suspension.
Air diffusers placed near one longitudinal tank wall induce a roll in the contents of the grit tank.
This roll creates maximum velocities near the walls and lower velocities at the surface and bottom
of the tank. The lower transverse horizontal velocities allow inorganic particles to settle out and
be transported to the grit hopper by shear-induced currents.
The aerated grit chamber design is based on providing sufficient hydraulic detention time during
peak wet weather flow conditions. The PER stated it is necessary to provide at least 10 minutes
of detention time to achieve satisfactory grit removal.
Aerated grit tanks can provide excellent grit removal with minimal headloss, but the chambers
themselves require a larger footprint than induced vortex systems. Proper operation of aerated
grit tanks can be difficult under varying hydraulic loads due to the need to make fine adjustments
to the air diffusers.
The headworks is a notorious location for foul odor at a wastewater treatment plant. This odor is
caused by hydrogen sulfide (H2S), which is formed under anaerobic conditions found in the
wastewater collection system. Due to H2S low solubility in wastewater, when there is an excessive
concentration of H2S or if there is turbulence, H2S gas escapes into the atmosphere. This release
produces a distinct rotten egg smell. In addition to H2S, there are other foul odorous compounds
that can be released from wastewater, such as ammonia, amines, diamines, mercaptans, skatole,
and organic sulfides.
Figure 6: Aerated Grit Chamber
Source: PER, 2023
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The PER recommended a granular activated carbon (GAC) scrubber be used at the Pahala WWTP
headworks as shown in Figure 7. A GAC scrubber passes odorous air through a bed of activated
carbon, which absorbs the odorous constituents within the pore spaces of the carbon.
Chemical oxidation or reduction of some compounds can also occur. As pore spaces become
occupied, efficiency degrades, and the carbon must be replaced or regenerated. Carbon is most
effective on higher molecular weight molecules such as the organic sulfur compounds, which
makes it the technology of choice. Package GAC scrubbers are available for small headworks and
vessels can be situated vertically, horizontally or radially to optimize footprints and reduce
structure elevation profiles. The County currently operates GAC scrubbers at other facilities and
purchases the GAC media in bulk, which could reduce costs to the County.
Figure 7: Granular Activated Carbon Scrubber
Source: PER, 2023
Secondary treatment process provides 5-day biochemical oxygen demand (BOD5), total
suspended solids (TSS) and nutrient removal via biological treatment. The PER provided
descriptions of various secondary treatment options including advantages, disadvantages and
applicability to the Pahala WWTP. Further, the treatment options were screened to identify
technologies for further evaluation. Based on the analysis, the PER selected membrane bioreactor
(MBR), activated sludge with anoxic selector, and recirculating gravel filter for use as the Pāhala
WWTP.
A membrane bioreactor (MBR) has the smallest footprint of the various biological treatment
systems available and provides the highest quality effluent. An MBR basically combines an
aeration basin with membrane filtration, eliminating the need for tertiary treatment if a very high-
quality effluent is desired for water reuse purposes.
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Membranes provide an absolute barrier to large particles; total suspended solids (TSS)
concentrations of the effluent (also known as “filtrate”) are typically less than 1 mg/L. Effluent
from an MBR process can meet stringent water recycling turbidity requirements without an
additional filtration process.
The main difference between MBRs and other biological treatment technologies is the method of
separating the bacteria from the clean water. MBRs have thin membranes with many thousands
of micro-perforations. Depending on the manufacturer, these perforations are 0.04 to 0.2 microns
(4 to 20 hundred-thousandths of a millimeter) in diameter, too small for the passage of most
microorganisms or other particles present in the wastewater, but large enough to allow the
passage of water molecules.
The MBR facility has a small footprint and the process would produce a high quality effluent.
However, an MBR facility has a relatively high overall capital cost, operation and maintenance
cost and lifecycle costs. Notwithstanding these considerations, the County will use an MBR
package plant at Pāhala.
The proposed effluent management system (subsurface drip irrigation disposal) does not require
a disinfection process to protect human health and the environment because the treated effluent
is dispersed below the ground surface. However, periodic maintenance chlorination of the
subsurface drip system will be required to reduce biofilm fouling within the drip lines.
Calcium hypochlorite is the solid form of hypochlorite used for disinfection. It can be found as a
powder, granules, pellets, or as tablets in concentrations up to 70 percent. Calcium hypochlorite
will degrade in strength at a rate of 3 to 5 percent per year. Once applied to the wastewater, the
chemistry is similar to that for sodium hypochlorite. Calcium hypochlorite decomposes in an
exothermic reaction if exposed to moisture. Figure 8 shows a typical calcium hypochlorite feed
system.
Figure 8: Calcium Hypochlorite Feed System
Source: PER, 2023
Solid calcium hypochlorite is typically applied directly to wastewater at very small WWTPs due to
its ease of use. Specifically, solid calcium hypochlorite is widely available in concentrated form
16 Pāhala Large Capacity Cesspool Closure
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as powder, pellets, or tablets – consequently, transportation and storage of solid calcium
hypochlorite disinfectant is optimal for small WWTPs such as at Pāhala. Moreover, the County
utilizes solid calcium hypochlorite as a disinfectant at other existing treatment plants, so existing
supply chain logistics may be leveraged.
The PER indicates the above processes will require dewatering of the wastewater solids. Use of
screw press is shown in the PER. The thickened sludge conditioned with a polymer is introduced
into the screw press at the head box end and the mixture is conveyed to the outlet end by a
rotating screw. As the material is conveyed along the length of the press it is squeezed between
the tapered screw and the screen drum. The dewatered solids exit the press at discharge end
and fall down the discharge box. The liquid that was forced out through the screen is returned to
the liquid treatment process.
The dewatered solids, grit and screening would need to be trucked to the West Hawai'i Landfill
an estimated once to twice a month. The trucks would use the WWTP access road for access
onto Maile Street above the intersection with Māmalahoa Highway. The trucks could use Highway
to reach the landfill, which means the trucks would not need to travel into the Pāhala community
to reach Māmalahoa Highway.
Disposal of the treated effluent is an important consideration at any WWTP. Although the PER
discusses ocean discharge, use of injection wells, water recycling and slow rate land treatment.
The methods were not deemed feasible due to regulatory issues and high costs, including the
need to remove and dispose of all the macadamia trees growing on the 14.9-acre site.
Based on the selected MBR treatment process, use of subsurface drip irrigation of the existing
macadamia orchard for disposal of the treated effluent, as described below, will be used at Pāhala.
The PER indicated the results of the effluent management investigation have determined that a
subsurface drip irrigation system as the recommended method of effluent disposal for the Pahala
WTTP.
This concept would retain the existing site topography along with the macadamia nut tree orchard
and use subsurface drip irrigation technology to apply the effluent to the existing macadamia nut
trees within the effluent disposal area. The use of subsurface drip irrigation technology to disperse
effluent at the site will allow the County to retain the existing mature macadamia nut trees, and
will significantly reduce the amount of clearing, grubbing, and grading required to construct the
facility. In addition, retaining the existing mature orchard is expected to effectively screen or
block views of the facility from both Maile Street and Māmalahoa Highway.
Drip irrigation technology has evolved to the point where non-clog emitters are available for
subsurface applications of effluent. Non-clog subsurface emitters decrease the potential for the
irrigation components to be clogged by roots. Drip tubing with integral emitters is buried 6 to 9
inches below ground. Effluent emitters are typically designed to operate at a flow rate of 1 gallon
per hour (gph) and are typically spaced every 2 feet along a drip line. Pressure compensating
drip systems typically operate under pressures ranging from 10 to 45 pounds per square inch
(psi). Figure 9 shows the subsurface drip concept.
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Figure 9: Subsurface Drip Concept for Pāhala
Source: PER, 2023
The effluent disposal system will be sized to handle the peak day wet weather flow of 312,000
gpd. An irrigation equalization and control tank are proposed to equalize higher peak flows and
to allow discrete dosing of the orchard in irrigation zones; constant application of water would be
detrimental to the health of the trees.
HAR 11-62 requires a fully redundant subsurface disposal system. The design criteria are based
on providing a subsurface drip system that is two times larger than needed in order to satisfy the
HAR 11-62 requirement for redundancy. The drip system will be divided into two separate systems
so that the peak day wet weather flow can be disposed on the site using one system while the
second system is out of service for maintenance.
The subsurface drip lines are to be located between the existing row of trees and spaced to
disperse effluent evenly throughout the orchard. During high flow conditions the irrigation control
system will open multiple irrigation zones to accommodate the disposal needs.Additional drip lines
will need to be added when the WWTP capacity is expanded. The minimum spacing between drip
lines is 2 feet, so there will be sufficient space between the initial drip lines to add additional drip
lines as part of future expansion project(s).
The PER conducted water balance and nutrient balance to determine the expected nitrogen use
by the macadamia nut orchard. The analysis showed the orchard of mature macadamia nut trees
is expected to use up to 400 lbs. of nitrogen per acre per year (University of Hawaii Agricultural
Experiment Station, January 1959). The effluent will supply approximately 289 lbs./acre/year of
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total nitrogen, assuming an effluent concentration of 10 mg/L. Although the nitrogen uptake of
the orchard is expected to be greater than the total mass of nitrogen applied by the effluent, the
predominant nitrogen species in the effluent is expected to be nitrate, which is soluble and readily
transportable through the soil profile. The trees will only be able to use the nitrate contained
within water that is transpired. The percolate volume is expected to contain approximately 8.5
mg/L of nitrogen as nitrate, because soil denitrification losses of 15 percent can be expected.
Therefore, the land treatment system is expected to remove approximately 21 percent of the
total nitrogen applied to the site from the WWTP effluent.
The PER stated drip irrigation technology has evolved to the point where non-clog emitters are
available for subsurface applications of effluent. Non-clog subsurface emitters decrease the
potential for the irrigation components to be clogged by roots. Tubing with integral emitters is
buried 6 to 9 inches below ground. Effluent emitters are typically designed to operate at a flow
rate of 1 gallon per hour (gph) and are typically spaced every 2 feet along a drip line. Pressure
compensating drip systems typically operate under pressures ranging from 10 to 45 pounds per
square inch (psi).
Subsurface drip irrigation technology incurs greater operation and maintenance cost than a
surface irrigation system. The County will need to periodically flush the drip lines to remove
debris. As described below, a significant number of drip lines will be necessary to accommodate
peak flow rates. In addition, periodic chlorination will be required to remove biological growth
from the drip lines. These operations and maintenance tasks will need to be completed on a
regular schedule, because the drip system will be buried and not readily accessible or observable.
During periods of dry soil conditions, the County will need to inspect the orchard for patches of
wet soil that would indicate a localized failure that requires repair. Flow and pressure monitoring
will also be useful tools for validating the status of the subsurface drip system. The land treatment
area would be divided into multiple irrigation zones, allowing a zone to be taken out of service
for maintenance purposes. A fence will be constructed around the site to deter entry by humans
and ungulates.
Collection System
Under Alternative 1, the County would construct a new sewer collection system in the Pāhala
community to replace the existing system of substandard gravity lines that convey sewage to the
two LCCs and connect it to the proposed wastewater treatment and disposal facility. The new
collection system would consist of a total of approximately 11,500 linear feet (LF) (2.2 miles) of
corrosion-resistant polyvinyl chloride (PVC) piping almost entirely within the public ROW of eight
public streets. This includes five streets in the western portion of the community (Maile, ʻIlima,
Huapala, Hīnano, and Hala Streets) and three public streets in the eastern portion of the
community (Puahala, Pīkake, and Kamani Streets). The new collection system would service a
total of 174 lots (109 existing or previously connected lots, plus 65 newly accessible lots as
described later in this subsection). The specific number being dependent on the results of the
topographic survey and the design of the collection system that will convey sewage to the new
wastewater treatment and disposal facility.
Similar to the treatment and disposal facility, the collection system would be designed not to
preclude expansion to meet the requirements of Policy 120 of the Ka‘ū Community Development
Plan.
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The County would construct the collection system in two phases to ensure that residential units
can maintain access to the sewer system at all times. Phase 1 would construct segments totaling
approximately 1,400 LF of 12-inch line and 700 LF of 8-inch line to divert sewage flows from the
existing LCC collection system to the new treatment and disposal facility and extend laterals to
individual properties making them accessible to this portion of the new collection system.
Specifically, Phase 1 would include the following:
1. A new 1,400-LF, 12-inch diameter line within the Maile Street right-of-way (ROW) to
intercept flows from the existing system serving ʻIlima, Huapala, Hīnano, and Hala Streets
and convey sewage to the new wastewater treatment and disposal facility. This new line
would be sized to accommodate the future flows from the entire community.
2. A new 700-LF, 8-inch diameter line partially within the Pīkake Street ROW that would
connect the existing collection system above LCC 2 to the new line on Maile Street
described above. A 350-LF portion of this line would run through an easement on a
privately owned parcel (TMK 9-6-005:044) to access Maile Street from Huapala Street.
3. Phase 2 would complete the new collection system by constructing segments totaling
approximately 9,400 LF of 8-inch line throughout Pāhala, installing pumps on selected
properties, making individual properties accessible to the new collection system and re-
connecting individual properties currently serviced by the existing collection system to the
new collection system. These main lines would range from a 14-inch line on Pīkake Street
to mostly 8-inch lines on the remaining streets and would run primarily within County
ROWs for ease of access. However, an approximately 1,100-LF segment would follow the
existing system alignment in the industrial area between ʻIlima and Maile Streets. The
property (TMK 9-6-005:036) is owned by Edmund Olsen and leased to M L Macadamia
Orchards. The County would obtain an easement for the work proposed within this area.
Construction of the new collection system would involve temporary impacts within the
public ROWs of eight streets.
The streets within the community are under the jurisdiction of the County, with the
exception of a privately owned portion of Pīkake Street for which the County would obtain
an easement. The streets have been improved with asphaltic concrete (AC) surfaces
approximately 22 to 24 feet wide (plus shoulders), and do not have curbs or gutters. Most
of the streets have two travel lanes and have overhead utility poles located outside the
travel lanes. Residential lots along the streets have driveways with direct access to the
travel lanes. Most shoulder areas have been improved or consist of grassy swales.
Typical sewer trenches would be about 3 feet wide and at least 6 feet deep to allow the
placement of the lines to meet County standards. The existing pavement would be sawcut,
the trench would be excavated (which could require removal of bedrock), the PVC pipe
installed, and then the trench would be backfilled and compacted. The cut portion of the
AC pavement would then be resurfaced with new AC material. Additional resurfacing may
be required where trenches parallel the streets. The collection system would be installed
with the proper horizontal and vertical clearances from existing water system facilities and
concrete jacketing at waterline crossings, where necessary, as recommended by the
County of Hawai‘i DWS Water System Standards.
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4. In April 2007, the County entered into an agreement with C. Brewer to eliminate LCCs
from the existing community sewer systems and connect properties discharging to them
to new County collection, treatment, and disposal system. Once the actual costs are
determined, County Council action is still required to approve the expenditure of funds on
private property for existing connections.
All accessible properties would be required to connect to the new wastewater collection system
in accordance with Hawai'i County Code, HCC, § 21-5. The new collection system would be subject
to HCC 21 (Sewers). Specifically, HCC § 21-5 states the following:
“(a) Owners of all dwellings, buildings, or properties used for human occupancy,
employment, recreation, or other purposes, which are accessible to a sewer are required at
their expense to connect directly with the public sewer within 180 days after date of official
notice.
(b) If, due to rock, wastewater collection system depth, or other construction problems, a
building cannot be practically served, the owner shall install, operate and maintain a
residential pumping station.
(c) The director may grant a variance/exemption of the foregoing connection requirements
to owners of single-family dwellings existing at the time of installation of the public
wastewater system, if the following is found:
(1) There are special or unusual circumstances applying to the subject real property
which exist that render the ability to connect to a wastewater system an extreme
physical or financial hardship; and
(2) There are no other reasonable alternatives; and
(3) The variance is consistent with the general purpose of the chapter and will not be
materially detrimental to public health, safety, or welfare.”
Accordingly, additional newly accessible lots in Pāhala would be required to connect to the new
wastewater collection system after it becomes operational. These other lots are near the existing
service area and are presently connected to individual wastewater systems or cesspools. The
design of the new collection system would include stub-outs to accommodate the eventual
connection of these newly accessible lots. However, the respective lot owners would be
responsible for the design and completion of these connections and for the proper closure of their
individual wastewater systems.
The State of Hawaiʻi Department of Education (DOE) would connect the Ka‘ū High School and
Pāhala Elementary School and the recently completed Ka‘ū Gymnasium and Shelter to the new
collection system. As stated in Section 4.7.2 of the County of Hawai‘i, Department of Public Works,
Final Environmental Assessment and Finding of No Significant Impact, Ka‘ū Gym and Shelter,
Pāhala, Ka‘ū District, April 2012: “In accordance with Section 21-5, Hawai‘i County Code (HCC),
Ka’ū High and Pāhala Elementary School, including the Ka’ū District Gym and Shelter, will be
required to connect to the County sewer system when access becomes available. The State
Department of Education will be responsible for coordinating and constructing the connection to
the sewer system via a branch main on Hala Street and properly closing their onsite system.
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2.1.2 Alternative 2: Package Plant with Existing Collection System
Alternative 2 would construct a new package plant and effluent disposal system, as previously
described, and then connect the existing collection system to the package plant. (The package
plant would be the same as previously described in Alternative 1.)
Existing Collection System
In 2004, C. Brewer Company contracted M&E Pacific to perform a sewer system evaluation for
the town of Pāhala. The scope of the study was to investigate and evaluate the physical condition
of the system, compliance with County sewer standards and identify problems associated with
the existing Pāhala system. The findings were documented in The Ka‘ū Sewer System Evaluation
dated December 2004. Figure 10 shows the existing collection system.
The 2004 study stated, it was estimated that the existing sewer system was built around the
1940s, or over 80+ years ago. The system consists mainly of cast iron pipes and the manholes
of square concrete boxes. The 2004 study found the residential laterals connect to 4-inch lines
which discharge into 6-inch lines that transmit the sewage to the LCCs. The system has 3 to 5
manholes on Maile Street and Pikake Street and one on the commercial parcel on Pikake Street.
The system does not contain pump stations and does not collect storm water.
The 2004 study indicates the Pāhala community sewer system consists of about 3,058 linear feet
of 6-inch diameter and 10,000 linear feet of 4-i nch diameter pipelines. T he house laterals in
Pāhala connect to the 4-inch lines which discharge into the 6-inch lines that transmit t h e
untreated sewag e to the LCCs. The relatively steep grades of the residential subdivision mean
the lines are laid at shallow depths. Further, the results of the investigation determined that the
existing sewer lines and manholes do not conform to the County sewer design standards.
As part of the investigation, a smoke test was conducted of the existing system to determine the
location of any fract ures, open joints, holes and sources of inflow. Smoke testi ng involves t he
blowing of smoke into the sewers normally th rough a manhole or other accessible junction.
The smoke used is a non-toxic substance that will not harm humans. pets. food, plants or
other material goods. It will be visible from manhole covers. roof vents and from t he ground
where sewer line tweaks or defects may exist. The purpose of the smoke is to assist in locati ng
pipe defects and t he entry points of storm and other surface waters into the sewers.
Residents of t he specific area for testi ng were notified via a public notice at least one week
prior to the actual testing.
The results of a smoke test performed during the 2004 sewer system evaluation identified 14
locations of line breaks and/or pipe defects and 7 household units with defective sewer vents.
Also, there is evidence of wastewater spill occurring from a manhole located directly
downstream of the commercial property on Pikake St reet. The manhole contained some
accumulation of debris in the well and evidence of wastewater overflow on the adjacent
ground by the existence of particles of tissue and other solids on the ground surrounding t he
manhole. The owner of the residential lot directly downstream of the commercial property
confirmed t he occasional overflow of wastewater from the subject manhole.
The 2004 sewer system report did not discuss any subsequent work related to repairs or other
corrections to the reported findings.
Existing Large
Capacity Cesspool
(LCC 1)
Proposed Pahala
WWTP Site
Existing Large
Capacity Cesspool
(LCC 2)MEYER RDMEYER RDHAU STHAU STHA
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FIGURE 10
PAHALA LARGE CAPACITY CESSPOOL CLOSURE PROJECTPAHALA LARGE CAPACITY CESSPOOL CLOSURE PROJECT
ALTERNATIVE 2 SITE PLANALTERNATIVE 2 SITE PLAN
Ka’u High &
Pahala Elementary
School
Ka’u
Hospital
feet
00 1,0001,000 2,000
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LEGEND
Lots to WWTP
Proposed Pahala WWTP Site
Existing Sewer Manhole
Existing Sewer Mains
Existing Large Capacity Cesspool (LCC)
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Nearly 20 years have passed since the 2004 study was completed. In order to reuse the existing
collection system in the future, an updated condition assessment study is recommended to further
identify system deficiencies. Substantial improvements will likely be necessary due to the age of
the system. Also, reusing the existing collection system would require constructing the Phase 1
collection system project described above to tie into the WWTP and close the LCCs.
The April 2023 PER, indicated the existing sewer system is over 80 years old, long surpassing its
expected lifespan of the system. Further, if chosen to be reused, the system will require extensive
repair and rehabilitation.
The April 2023 PER stated, although reusing the existing collection system appears to incur lower
life-cycle costs than the other alternatives, reusing the system is not recommended for
implementation. The advanced age of the existing collection system means the County would
incur substantial financial and other risks:
•The pipes are at the end of their useful service life, and catastrophic failures are likely to
increase in frequency, creating increased risk to public health and the environment.
•Most of the system is located in backyards within easements, making it difficult to access
and maintain the lines.
•The option does not address the AOC requirement to connect additional properties, which
are currently not connected to the collection system, to the WWTP.
•System expansion to accommodate sewer flows in additional areas of the town (in
accordance with the Kau Community Development Plan) would not be feasible.
2.1.3 Alternative 3 – Individual Wastewater System-Maintenance Contract Model
Hawai'i Revised Statutes, Title 14, Taxation, Chapter 235, Income Tax Law, § 235-16.5 defines a
septic system as an IWS that typically consists of a septic tank, piping, and a drainage field where
there is natural biological decontamination as wastewater discharged into the system is filtered
through soil.
The April 2023 PER, stated the State DOH Wastewater Branch is responsible for regulating IWS
systems. The Amended AOC sets forth that the County Hawai‘i must administer a more active
management strategy than is typically found in Hawai'i IWS. The Amended AOC states either a
Model 2 (Maintenance Contract) or a Model 3 (Operating Permit) must be used IWS systems at
Pahala. Figure 11 shows the site plan for both Alternative 3 and 4.
The April 2023 PER indicates for a Model 2 Alternative, the County is to:
•Fund design and manage project construction of the IWS systems;
•Administer and manage a maintenance program for IWS;
•Develop a maintenance program would entail establishing rules and regulations for
monthly fees/penalties, County monitoring and reporting, and IWS educational
information for homeowners;
Existing Large
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(LCC 1)
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TPAKALANA STPAKALANA ST
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HOLEI STHOLEI STKOKIO STKOKIO STKEAHI STKEAHI STOHIA STOHIA STILIAU STILIAU STKAU
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KAM
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PUAHALA STPUAHALA STPIKAKE STPIKAKE STLEHUA STLEHUA STMAILE STMAILE STHAWAII BELT RDHAWAII BELT RDHALA STHALA STPAAUA STPAAUA STP
A
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FIGURE 11
PAHALA LARGE CAPACITY CESSPOOL CLOSURE PROJECTPAHALA LARGE CAPACITY CESSPOOL CLOSURE PROJECT
ALTERNATIVES 3 & 4 SITE PLANALTERNATIVES 3 & 4 SITE PLAN
Ka’u High &
Pahala Elementary
School
Ka’u
Hospital
feet
00 1,0001,000 2,000
N
LEGEND
Lots for IWS
Existing Large Capacity Cesspool (LCC)
25 Pāhala Large Capacity Cesspool Closure
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• Operate the system and conduct routine maintenance, and respond to any related trouble
calls; and
• Prepare and submit related notices and reports.
2.1.4 Alternative 4 – Individual Wastewater System-Operating Permit to
Homeowners
The April 2023 PER indicates for a Model 3 Alternative, the County is to:
• Fund design and construction of the IWS systems;
• Administer an operating permit program for the IWS system to the homeowners;
• Issues maintenance notice to the homeowner.
Under Alternative 4, the homeowners would be responsible for maintenance scheduling,
contracting and paying for a service provider to conduct the necessary maintenance and/or
responding to trouble calls, monitoring and record keeping of maintenance.
Under Alternative 4, County is evaluating the possibility of either completing the project as a
conventional Design/ Bid/ Build process, or under a voucher program, which the County would
administer. This voucher program the County will grant homeowners with funds to hire
Professional Engineer to design new IWS and, then hire a Contractor to construct IWS. Under the
voucher program homeowners will be responsible to hire and coordinate with a professional
engineer for overall design and placement of the IWS.
Based on the above , regardless of the maintenance responsibility, the County will fund the design
of the IWS systems for Pāhala. The PER identifies two key considerations to ensure the IWS
functions as intended;(1) system size, including the number of bedrooms or flow rate and (2) site
considerations including soil type, slope, drainage patterns and accessibility to the IWS site.
The PER indicated the median residential parcel in Pāhala is about 10,500 square feet (0.24
acres), with some as small as 5,200 square feet (0.12 acres). HAR 11 -62-3.1 (2)(A) states 10,000
square feet (0.23 acres) of usable land must be available for each IWS. Of the 174 properties to
be served in this project, 81 have less than 10,000 square feet of total area. Space available for
IWS installation on these properties may be further limited by the presence of existing structures.
Further, the actual placement of the IWS system is limited by setback requirements from property
lines of 5 to 9 feet and structure walls of 5 feet. From a system design perspective, the PER
recommended that systems should also be a minimum of 20 feet from any cut-face slopes present
on a site to avoid surfacing of treated effluent. This is a particularly a constriction to heavily
sloped sites.
The PER noted the Pāhala has a roughly 10 percent grade, although the slopes will vary from
parcel to parcel. HAR 11-62-34 states absorption beds shall not be installed on lands with a slope
gradient of greater than 8 percent. Absorption trenches are permitted on slopes of up to 12
percent. Generally, the various setback and slope requirements mean that the IWS system will
need to be specifically designed for each parcel.
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The PER noted it is generally not good practice to install an IWS under an area with traffic loads
or covered with a concrete covered. The presence of traffic loads or concrete pavement will
compress the soil in distribution/effluent disposal system and affects the accessibility of the
system for maintenance. However, it is sometimes unavoidable particularly on parcels with limited
space. In these instances, a system may be installed underneath a driveway or patio provided
the system is designed with traffic rated treatment components. These may include products such
as concrete septic tanks and/or H-20 traffic related chambered disposal beds.
S eptic Tanks
The PER stated septic tanks are the most common conversion treatment technology installed in
Hawai‘i. A septic tank is an underground chamber made of concrete, fiberglass reinforced
polyester, or plastic, and used for treating and disposing of household wastewater. The tank
contains a mixture of untreated sewage and anaerobic bacteria, which break down the waste and
separate it into three layers: a top layer of scum, a middle layer of liquid effluent, and a bottom
layer of sludge. Septic tanks operate without the need for electrical power. Contractors are
familiar with the process of installing IWS systems.
The septic tank can have two chambers with sewage flows from the home flowing into the first
chamber where the heavy solids will settle to the bottom as sludge and the remaining liquid and
lighter solids floating to the top as scum. The floating liquid will flow to the second chamber
through an opening in the wall where any remaining solids will settle to the bottom and then
effluent will flow to disposal system. Access to the tank will be sealed to retain the anerobic
conditions which will help to control odor.
The liquid effluent flows out of the tank and into a means of disposal, where it is further treated
and dispersed into the soil. According to the PER, the sludge and scum remain in the tank and
must be periodically pumped out by a professional septic service approximately once every three
to five years, depending on usage. Figure 12 shows a typical septic tank.
The April 2023 PER stated there are several types of septic tanks from suppliers in Hawai‘i. The
tanks can be made from concrete, plastic, and reinforced fiberglass polyester which come at of a
variety of price points, each with a set of advantages and disadvantages and materials. Where a
septic tank is located beneath a vehicular traffic area, a traffic rated concrete septic tank can be
used or a structural concrete slab designed for H-20 loading spanning a non-traffic tank may be
used.
Concrete tanks are durable and less susceptible to collapse. However, concrete tanks can be more
expensive than plastic or reinforced fiberglass tanks and typically require a crane for installation
and can corrode from the effects of acidic sewer gases.
Plastic or polyethylene tanks are less expensive than concrete; resistant to corrosion and may not
require a crane for installation. However, plastic tanks may deform and, if not properly installed,
can float if flooded.
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Figure 12: Typical Septic Tank System
Source: PER, 2023
Fiberglass reinforced polyester (FRP) tanks are less expensive than precast concrete tanks,
primarily due to lower shipping and installation costs, typically resistant to corrosion, more rigid
than plastic tanks, and may not require use of a crane for installation.
The April PER indicated the choice of septic tank material will depend on availability, budget, and
site constraints. At a minimum, septic tanks in Hawai‘i must comply with International Association
of Plumbing and Mechanical Officials (IAPMO) material and property standards for septic tanks.
Further, sizing and installation criteria are regulated by HAR 11-62-33. The minimum septic tank
capacity is 1,000 gallons for a household of 4 bedrooms or less and 1,250 gallons minimum for
households of 5 bedrooms. Septic tanks serving households greater than 5 bedrooms will require
a variance from the DOH.
The PER discusses two commonly used IWS effluent disposal methods found in Hawai'i,
absorption bed and absorption trench. Absorption beds are the most common form of IWS
disposal method installed in Hawai‘i today. The absorption bed will require excavation of 6 to 7
feet below grade to accommodate the network of perforated pipes, each a maximum of 100 feet
long and laid in trenches 1.5-3 feet below the finished grade 4-6 feet apart. Each line is laid level
to allow the gravity dispersal of the treated effluent through the length of the pipe before it filters
out and percolates down into the soil. A minimum of 6 inches of gravel is provided below each
pipe. If the percolation rate is faster than one minute per inch, a 3-foot soil replacement layer is
installed under the entire absorption bed. The s oil replacement is to be washed #4 sand or cinder -
soil mix with a percolation rate not faster than one minute per inch. The excavated material from
the absorption bed will need to be removed off the site.
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These systems are easy to maintain when connected to an effective treatment system and will
rely on microorganisms in the soil for an added degree of treatment to the effluent as it filters
through the upper oxic layers of the soil matrix. However, absorption beds have a significant
space requirement with current Hawaiian regulations requiring a minimum of 350 square feet for
a 4-bedroom home. This space requirement increases with decreasing hydraulic conductivity of
the soil. Additionally, absorption beds can only be installed on a grade of less than 8 percent.
An absorption trench is a type of subsurface wastewater disposal system that utilizes a trench
filled with gravel or other porous material to filter and distribute wastewater effluent into the
ground. Wastewater is distributed into the trench through a network of pipes, typically made of
PVC or other durable materials. The gravel in the trench acts as a natural filter, allowing the water
to slowly seep into the surrounding soil while also removing impurities with adsorbed beneficial
bacteria. The trench may be lined with a layer of filter fabric to prevent the gravel from becoming
clogged with soil or other debris. Figure 13 shows a typical IWS site plan with an absorption bed.
The PER indicated, although not as common as an absorption bed or trench, use of a seepage
pit should be considered for use in Pāhala. Seepage pits are a vertical means of achieving the
percolation area requirements for a disposal system. These systems typically consist of a 15-30-
foot-deep pit lined with stacked precast perforated concrete rings or CMUs, to an internal diameter
of 6-8 ft. Seepage pits are both less land area intensive and less expensive than absorption beds.
Figure 14 shows typical IWS site plan with seepage pit.
A seepage pit must include a cover which extends at least 12 inches beyond the seepage pit
excavation or over a provided concrete lining. An access hatch must be provided in the concrete
cover to allow inspection and maintenance of the pit. The seepage pit may be designed to be
traffic rated by providing the sufficient strength required in the design of the concrete lining and
cover.
The effective area of the seepage pit is equal to the vertical wall area corresponding to the
effective depth of the pit. Slow percolation rates translate to a larger required absorption area or
deeper pit.
While seepage pits are an approved means of disposal in Hawai‘i, they are often only permitted
when it can be demonstrated that an alternative means of disposal was not possible , i.e.
insufficient land area, steep terrain (greater than 12 percent) or very slow percolation rates (less
than 60 min/inch). Where slow percolation rates present, seepage pits will need to be dug through
the basalt rock layer to reach more porous soils or a variance will be required from HAR 11-62-
34 d(1)b:
Seepage pits shall not be constructed in soils having a percolation rate slower than ten minutes
per inch (weighted average) or where rapid percolation through such soils may result in
contamination of water-bearing formations or surface water.
A-41
FIGURE 13
A-42
FIGURE 14
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The PER provides information related to land area needed for IWS systems, which is affected by
the percolation rate of the soil. The information shows the slower the percolation rate, the larger
the land area needed for the IWS system, or in the case of a seepage pit, the deeper the pit
required. The total area for a septic tank and absorption field ranges from about 480 to 765
square feet. In comparison, the land area for septic tank and seepage pit would be about 120
square feet. The Table 1.1 below from the PER shows the percolation rate and the affected area
required for an IWS system.
Table 1.1: IWS Percolation Rate and Required Area
The PER discussed the installation of an IWS can be a relatively invasive process requiring large
equipment like excavators and cranes. Accommodating this equipment often requires the removal
of fencing, destruction of existing trees, landscaping and, in some cases, small structures. Building
footprints as well as overhanging soffits need to be considered in the design and placement of
the IWS. Also, the access path to the IWS needs to be considered when selecting appropriate
IWS system design as well as for future maintenance activities.
Opportunities/methods to resolve access issue include:
• Placement of the IWS system in the front-yard is recommended for parcels without
sufficient paths to accommodate equipment access into the backyard.
• The use of a large crane can be avoided by specifying cast-in-place concrete traffic slab
with a plastic tank instead of a precast traffic-rated concrete tank, especially for
inaccessible locations and vehicle traffic is anticipated.
• Also, it might be possible to access a backyard from a neighbors’ property by temporarily
removing an adjoining fence.
The P ER identified a number of cost implications from an IWS system that a homeowner will face:
• Homeowners currently connected to the LCCs are paying a reduced sewer fee of about
50 percent of the standard sewer rate (Hawai‘i County, 2023). An IWS will either introduce
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a full-rate monthly sewer fee or a bill for private maintenance provider to maintain their
new system. It is quite likely that some homeowners don’t see a need to upgrade from
the current system. However, initial opposition to the project has largely been addressed
through the County’s engagement efforts.
• Most homeowners are protective of their private property. Homeowner permission is not
trivial for a project that poses a risk to their landscaping, fences and buildings. Homeowner
satisfaction with the project will be closely linked with the speed and care with which their
properties are upgraded and restored to pre-construction conditions or better.
The PER discussed several issues related to IWS systems as they relate to the Pāhala community
which include: 1) there are several septic tank pumping service in the Hilo and Kailua-Kona area
that could service Pāhala; 2) the typical pumping truck has a capacity of 2,500 to 3,000 gallons
which means a one truck could pump out two to three septic tanks during one visit; 3) the septic
tank should be pumped out every 3 to 5 years, not necessarily regularly; 4) the trucks are
equipped hoses such that the truck does not have to direct access the tank; 5) the pumping
should take 1 to 2 hours; 6) the cost to the homeowner could range from $500.00 to $900.00
part of the cost is the need to empty the tanks at a WWTP plant, in Hilo or Kealakehe; 7) root
barriers could be placed to minimize root intrusion into the absorption bed or the perf orated pipe.
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3. Cumulative Effects
The Proposed Action (construction of a new wastewater treatment and disposal facility and a new
collection system, closure of existing large capacity cesspools (LCCs), and connection of newly
accessible properties to the sewer system), in combination with other past, present, or reasonably
foreseeable actions at or near Pāhala, could contribute to cumulative improvements and impacts
on certain environmental resources. Cumulative effects can result from individually minor but
collectively significant actions taking place over a period of time.
3.1 Scope of Analysis
This section identifies the other past, present, or reasonably foreseeable actions at or near Pāhala
that were considered and evaluated in this cumulative improvements and impacts analysis as
related to Alternative 1 and Alternative 2. Since Alternative 3 and Alternative 4 would affect the
individual parcels, these two alternatives are not included in the analysis.
3.1.1 Geographic Scope of Analysis
The extent of the cumulative effects analysis is generally limited to the geographic/natural
boundaries of the affected resource areas. The Council on Environmental Quality (CEQ)
handbook on Considering Cumulative Effects Under the National Environmental Policy Act
indicates that the geographic extent for this analysis should be defined on a case-by-case basis
and is dependent on the affected resources (CEQ, 1997).
In defining the geographic scope for consideration of cumulative effects, the DOH and County
considered the resources that would be affected by the Proposed Action (i.e., within the project
impact zone); the type and intensity of those effects; and whether those affected resources
extend beyond the project impact zone. the effects of the Proposed Action would generally be
limited to the immediate vicinity of the WWTP project site and related improvements
plus minor transportation-related impacts during construction; the Proposed Action would not
adversely affect historic properties or protected species; it would not adversely affect surface
waters that are part of a larger watershed (other than potential for temporary, minor
construction-related runoff impacts that would be mitigated by adherence to BMPs); and the
affected macadamia nut orchard.. Based on these considerations, the DOH and County limited this
cumulative effects assessment to include past, present, and reasonably foreseeable actions
located within the Pāhala community or within 1 mile of the proposed location of the wastewater
treatment and disposal facility and related improvements. This scope is expected to more than
fully encompass the full extent of resource areas that would potentially experience discernable
effects from the Proposed Action and is commensurate with the type and intensity of the effects
of the Proposed Action.
The community of Nā‘ālehu, located approximately 11 miles southwest of Pāhala, is also
considering options for closure of LCCs and development of a new wastewater treatment system.
The Nā‘ālehu Large Capacity Cesspools Closure Project (Nā‘ālehu Project) is similar in concept
to the Proposed Action in that it proposes the closure of existing LCCs and the construction of a
new system for a similarly sized community. The DOH and County analyzed whether this and other
similar projects throughout the Kaʻū District would have the potential to affect the same resources
as the Proposed Action. A typical, similar construction project would be expected to result in
temporary, localized impacts during construction including impacts from the use of construction-
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related vehicles and equipment (e.g., changes in traffic patterns and increases in noise and air
emissions), disturbance of soil and vegetation, and generation of construction and demolition
debris; and potential long- term, localized impacts including changes in stormwater runoff and
infiltration, removal of vegetation, and changes in visual resources. These direct and indirect
effects, if managed in accordance with applicable environmental regulations, would not be
expected to extend beyond the vicinity of the project construction sites and local communities.
For these reasons, the future Nā‘ālehu Project, while located in the Kaʻū District, is outside the
geographic scope of this cumulative effects analysis and, for the reasons described above, is not
expected to have a significant cause-and-effect relationship with the direct and indirect effects
of the Proposed Action due to its distance from Pāhala. In addition, the National
Environmental Policy Act (NEPA) does not require consideration of socioeconomic impacts that
are unrelated to an impact on the physical environment (40 CFR § 1508.14). Therefore,
cumulative economic effects of the Nā‘ālehu Project combined with the Proposed Action on the
County-wide economy, tax base, and borrowing capacity were not analyzed in this environmental
assessment.
3.1.2 Past, Present, and Reasonably Foreseeable Actions within Geographic Scope
of Analysis
Only one significant project has occurred within the geographic scope of analysis in the recent
past – specifically, the construction of a new gymnasium at Kaʻū High School and Pāhala
Elementary School in the center of the Pāhala community, more than one-half mile north
of the site of the wastewater treatment and disposal facility. The gym was constructed to also
serve as a community shelter during emergencies. Construction began in October 2012 and
was completed in early 2016.
The school’s LCC was previously replaced with a Department of Health (DOH)-approved septic
system that included two new laterals at the property line on Hala Street and Kamani Street
to allow eventual connection to the new collection system. Following completion of the
Proposed Action, the State Department of Education will connect the Kaʻū High School
and Pāhala Elementary School (including the Kaʻū District Gym and Shelter) to the new collection
system and will properly close the onsite septic system.
There are no current projects in or around Pāhala, and no reasonably foreseeable actions (other
than connection of the Kaʻū High School and Pāhala Elementary School to the new collection
system) are planned based on review of the County’s Capital Improvement Plan and the Kaʻū
Community Development Plan (CDP). The CDP includes policies for long-term improvements
regarding the extension of wastewater systems in the Pāhala community in the Kaʻū District.
These long-term goals were considered in preliminary design of the Proposed Action; the
wastewater treatment and disposal facility and collection system would be designed to be
expandable should the County or community decide in the future that expansion is necessary.
However, the CDP does not present a timeline for this expansion; no substantial planning or
scoping of a collection system expansion has been conducted, and this expansion is unlikely to
occur within the next 10 to 20 years. This action therefore is not considered reasonably
foreseeable for purposes of the cumulative effects discussion and is not included in the
analysis below.
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3.2 Cumulative Improvements and Impacts Analysis
This analysis identified the following potential cumulative effects resulting from the Proposed
Action, construction of the Kaʻū District Gym and Shelter, and connection of the Kaʻū High School
and Pāhala Elementary School to the new collection system:
• Installation of new exterior lighting, resulting in potential nighttime light pollution
and distraction to night-flying birds;
• Removal of vegetation and construction of new impervious surfaces, resulting in
a potential increase in stormwater runoff; and
• Increase in influent flows from the Kaʻū High School and Pāhala Elementary School to
the new wastewater treatment and disposal facility.
Both the Proposed Action and the Kaʻū District Gym and Shelter construction have incorporated
mitigation measures to reduce nighttime light pollution and impacts to night-flying birds.
Specifically, the Kaʻū District Gym and Shelter incorporated minimal use of security lighting, which
are shielded in accordance with the County’s exterior lighting standards, and outdoor parking
lights are turned off at 11:00 p.m. to avoid impacts to birds and bats. the Proposed Action
would incorporate lighting that complies with the County’s exterior lighting standards and FWS
guidance, and the new facility would generally be dark at night, with exterior lighting used only
for emergency maintenance purposes. Adherence to these requirements would minimize the
potential cumulative light pollution impacts from these projects.
To reduce stormwater impacts, the Kaʻū District Gym and Shelter incorporated new dry wells and
grass parking, instead of paved parking, to the extent allowable by the Hawaiʻi Planning
Department. The Proposed Action would incorporate permanent BMPs such as subsurface linear
infiltration or depressed detention basins to detain flows and volumes to their pre-development
conditions. Additionally, due to the relatively young and porous geology of the Kaʻū district, any
increases in stormwater runoff generated by these projects are anticipated to infiltrate to
groundwater without presenting cumulative erosion concerns.
Finally, while the connection of the Kaʻū High School and Pāhala Elementary School to the new
wastewater treatment and disposal facility would increase the treatment capacity requirements
for the wastewater treatment and disposal facility, this was accounted for in the facility’s
preliminary design. Based on the above, the Proposed Action is not expected to result in any
significant cumulative improvements or impacts to the environment in combination with other
past, present, or reasonably foreseeable actions.
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4. Legal Framework and Regulatory Authorities
As described above, the County may use CWSFR for construction of the Pahala Large Capacity
Closure project. Since the State Revolving Fund receives annual funding from EPA, the National
Environmental Policy Act (NEPA) of 1969, as amended (42 U.S.C. §§ 4321 – 4347), requires a
federal agency proposing to undertake a project to consider the potential environmental impacts
of the proposed project. Use of federal funds for a project is among the criteria set forth in NEPA
that require preparation of environmental review documentation under NEPA and procedural
requirements at 40 CFR Parts 1500-1508 (Council on Environmental Quality (CEQ) regulations),
and 40 CFR Part 6 (U.S. Environmental Protection Agency (EPA) regulations. This Environmental
Information Document (EID) has been prepared under these guidelines.
The following regulatory requirements apply to this EID and to federal cross cutting regulations
necessary for compliance with the CWSRF program.
4.1 National Environmental Policy Act (NEPA) of 1969 (as Amended)
NEPA was passed in 1969 “to assure that all branches of government give proper consideration
to the environment prior to undertaking any major federal action that significantly affects the
environment.” NEPA requires all federal agencies to prepare Environmental Information
Documents (EIDs), Environmental Assessments (EA) and/or Environmental Impact Statements
(EISs) to assess environmental impacts from project alternatives.
The purpose of NEPA is “to declare a national policy which will encourage productive and
enjoyable harmony between man and his environment; to promote efforts which will prevent or
eliminate damage to the environment and biosphere and stimulate the health and welfare of man,
to enrich the understanding of the ecological systems and natural resources important to the
Nation; and to establish a Council on Environmental Quality,” Sec. 2 [42 USC § 4321].
According to NEPA, it is the continuing responsibility of the federal government to use all
practicable means, consistent with other essential considerations of national policy, to improve
and coordinate federal plans, functions, programs, and resources. NEPA, as amended in 1970,
requires federal agencies to: (a) utilize a systematic, interdisciplinary approach which will ensure
the integrated use of the natural and social sciences and the environmental design arts in planning
and in decision making which may have an impact on man’s environment; (b) identify and develop
methods and procedures, in consultation with the Council on Environmental Quality established
by Title II of this Act, which will ensure that presently un-quantifies environmental amenities and
values may be given appropriate consideration in decision-making along with economic and
technical considerations; and (c) include in every recommendation a detailed statement on the
environmental impact of the Proposed Action; any adverse environmental effects which cannot
be avoided should the proposal be implemented; alternatives to the Proposed Action; the
relationship between local short-term uses of man’s environment and the maintenance and
enhancement of long-term productivity, and; any irreversible and irretrievable commitments of
resources which would be involved in the Proposed Action should it be implemented, Sec. 102
[42 USC § 4332].
This project may be funded by federal funds provided by U.S. Environmental Protection Agency
(EPA) through the State of Hawai‘i's Clean Water State Revolving Fund (CWSRF) Program. As
such, the State of Hawai‘i Department of Health (DOH) must conduct an environmental review of
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projects funded under the CWSRF as required under the Code of Federal Regulations (CFR), using
the EPA-approved State Environmental Review Process. In addition, the State must comply with
the federal cross-cutting authorities set forth in 40 CFR § 35.3145 for the CWSRF.
The CWSRF requirements are set forth as “cross cutters” described as follows.
In addition to the cross cutters required by the EPA-approved State Environmental Review
Process, EPA guidance for conducting environmental reviews, and the Clean Water Act have been
included.
4.2 Archaeological and Historic Preservation Act (54 U.S.C. § 312502)
The Archaeological and Historic Preservation Act (AHPA), also known as the Archaeological
Recovery Act and the Moss-Bennett bill, was passed and signed into law in 1974. It amended and
expanded the Reservoir Salvage Act of 1960. The AHPA built upon the national policy, set out in
the Historic Sites Act of 1935, "to provide for the preservation of historic American sites, buildings,
objects, and antiquities of national significance." The AHPA expanded the policy by focusing
attention on significant resources and data but does not require that they be shown to be of
"national" significance. The AHPA required that federal agencies provide for "...the preservation
of historical and archeological data (including relics and specimens) which might otherwise be
irreparably lost or destroyed as the result of...any alteration of the terrain caused as a result of
any Federal construction project of federally licensed activity or program.”
54 United States Code (U.S.C.) § 312502 (a)(1) states: “When any Federal agency finds, or is
notified, in writing, by an appropriate historical or archeological authority, that its activities in
connection with any Federal construction project or federally licensed project, activity, or program
may cause irreparable loss or destruction of significant scientific, prehistorical, historical, or
archeological data, the agency shall notify the Secretary, in writing, and shall provide the
Secretary with appropriate information concerning the project, program, or activity.”
54 U.S.C. § 312502 (b)(1) states: “When any Federal agency provides financial assistance by
loan, grant, or otherwise to any private person, association, or public entity, the Secretary, if the
Secretary determines that significant scientific, prehistorical, historical, or archeological data
might be irrevocably lost or destroyed, may, with funds appropriated expressly for this purpose -
(A) Conduct, with the consent of all persons, associations, or public entities having a legal
interest in the property, a survey of the affected site; and
(B) Undertake the recovery, protection, and preservation of the data (including analysis and
publication).”
The proposed collection system will be constructed primarily within existing County streets and
two short segments within private easements in the Pāhala community that have been previously
disturbed when the streets were constructed. Preliminary analysis shows the proposed treatment
and disposal facility will be constructed in an area that does not contain archaeological resources.
In 2018/2019, an Archaeological Inventory Survey (AIS), which included subsurface testing, was
conducted for the previously design of the project.. The AIS served to confirm the
presence/absence of archaeological resources on the proposed 14.9-acre site for the Pāhala
WWTP and Sewer System project. The AIS confirmed no significant artifacts or cultural deposits
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were observed on the ground surface within the Proposed WWTP Site as the area experiences
ongoing disturbance by macadamia harvesting operations and stormwater runoff. Further, no
cultural deposits or lava tubes were encountered during the subsurface trenching.
In 2023, an Archeological Literature Review Report was conducted to determine the likelihood
that historic properties may be affected by the project and, based on the findings, consider
cultural resource management recommendations. The literature review concluded that surface
pre-Contact sites are not expected within the Project Area given the known traditional land use
in this area and the impacts of continued agricultural and residential development. The modern
development of the macadamia nut orchard has likely also obliterated any plantation-era sites
once present in that part of the Project Area. Historic surface features associated with the sugar
plantation and associated village may be present. Furthermore, there is potential for pre- or post-
Contact subsurface archaeological features within the Project Area, which may or may not be
located within lava tubes. It should be noted that the literature review is intended to support the
project's historic and environmental review process; however, the report does not fulfill the
requirements of an archeological inventory survey investigation as set forth in federal and State
of Hawai'i historic preservation review requirements. For more information, please refer to
Appendix B.
The contract drawings will state that, should archaeological sites such as walls, platforms,
pavements or mounds, or remains such as artifacts, burials, concentrations of shell or charcoal
be encountered during construction activities, work shall cease immediately and the find shall be
protected from further damage. The contractor shall immediately contact the State Historic
Preservation Division (SHPD), who will assess the significance of the find and recommend an
appropriate mitigation measure, if necessary.
4.3 Bald and Golden Eagle Protection Act (16 U.S.C. § 668-668c)
The Bald Eagle Protection Act (16 U.S.C. § 668-668c) prohibits any act to take, possess, sell,
purchase, barter, offer to sell, purchase or barter, transport, export or import, at any time or in
any manner any bald eagle commonly known as the American eagle or any golden eagle, alive
or dead, or any part, nest, or egg thereof of the foregoing eagles.
No bald or golden eagles are found in Hawai‘i.
4.4 Clean Air Act (42 U.S.C. § 7401 et seq.)
Over the years, there have been a series of legislations affecting air quality and a number
amendments adopted related to air quality. The Air Pollution Control Act of 1955 was the first
federal legislation involving air pollution and was followed by the Clean Air Acts of 1963 and 1970.
The Clean Air Act of 1970 (1970 CAA, 42 U.S.C. § 7401 et seq.) authorized the development of
comprehensive federal and state regulations to limit emissions from both stationary (industrial)
sources and mobile sources.
The 1970 CAA set forth four major regulatory programs affecting stationary sources: the National
Ambient Air Quality Standards (NAAQS), State Implementation Plans (SIPs), New Source
Performance Standards, and National Emission Standards for Hazardous Air Pollutants. In Hawai‘i,
the DOH, Clean Air Branch, Air Quality program is defined by Hawai‘i Administrative Rules (HAR)
11-60.1 and serves as the SIP approved by EPA.
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The State DOH maintains 10 air monitoring stations on the island of Hawai‘i. Established in 2007,
the DOH maintains a monitoring station on the grounds of the Ka‘ū High School and Pāhala
Elementary School to monitor SO2 and PM2.5 (in terms of micrograms per cubic meter (μg/m3))
from emissions from volcanic activities.
In September 2023, the DOH issued the Annual Summary 2022 Air Quality Data report which
provides the results from the network of air quality monitoring stations. In 2022, Pahala was in
violation of the 1-hour SO2 NAAQS standard. The 2022 report stated volcanic eruptions are
considered natural events and therefore EPA may exclude the exceedances of the 1-hour NAAQS
from attainment determinations.
The quality of air in the general Pāhala area is considered "Good." The rural nature of the Pāhala
area has no major stationary sources of air pollution. Existing sources of air pollution are
emissions from motor vehicles traveling along Māmalahoa Highway and on the streets in the
community; the low level of vehicle traffic tends to limit mobile sources of emissions.
Potential short-term effects from dust and exhaust due to construction activities will be minimized
with BMPs such as water sprinkling and proper equipment maintenance. No long-term impacts
on air quality resulting from operation of the collection system, the wastewater treatment and
disposal facility, or the IWS are anticipated.
The DOH operates a network of air quality monitoring stations at various locations around the
state. In September 2023, the DOH issued the Annual Summary 2022 Air Quality Data report (the
most recent report) which provides the results from the network of air quality monitoring stations.
The DOH maintains a monitoring station on the grounds of the Ka‘ū High and Pāhala Elementary
School. Established August 2007, the station was placed to monitor SO2 and PM2.5 from volcanic
emissions. In 2022, Hawai‘i was in attainment of the state annual SO2 standard. In 2015, Hawai‘i
was in attainment with the annual NAAQS for particulate matter with a diameter of 2.5
micrometers or less (PM2.5).
Volcanic eruptions are considered natural events and therefore EPA may exclude the exceedances
of the 1-hour NAAQS from attainment determinations.
The quality of air in the general Pāhala area is considered "Good." The rural nature of the Pāhala
area has no major stationary sources of air pollution. Existing sources of air pollution are
emissions from motor vehicles traveling along Māmalahoa Highway and on the streets in the
community; the low level of vehicle traffic tends to limit mobile sources of emissions.
Potential short-term effects from dust and exhaust due to construction activities will be minimized
with BMPs such as water sprinkling and proper equipment maintenance. No long-term impacts
on air quality resulting from operation of the collection system, the wastewater treatment and
disposal facility, or the IWS are anticipated.
4.5 Coastal Barrier Resources Act (16 U.S.C. § 3501)
In 1982, Congress passed the Coastal Barrier Resources Act (CBRA) (16 U.S.C. § 3501) to
minimize the loss of human life; wasteful expenditure of federal revenues; and the damage to
fish, wildlife, and other natural resources associated with the coastal barriers along the Atlantic
and Gulf coasts and along the Great Lakes by restricting future federal expenditures and financial
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assistance which have the effect of encouraging development of coastal barriers, such as federal
flood insurance through the National Flood Insurance Program.
The Coastal Barrier Resources Reauthorization Act of 2000 reauthorized the CBRA and directed
the U.S. Fish and Wildlife Service (FWS) to complete a Digital Mapping Pilot Project that includes
digitally produced draft maps for up to 75 John H. Chafee Coastal Barrier Resources System
(CBRS) areas and a report to Congress that describes the feasibility and costs for completing
digital maps for all CBRS areas.
Based on its location, the CBRA is not applicable to Hawaiʻi.
4.6 Coastal Zone Management Act (16 U.S.C. § 1451)
The Coastal Zone Management Act of 1972 (CZMA) (16 U.S.C §§ 1451-1464) was passed to
establish a national policy to preserve, protect, develop, and where possible, restore or enhance,
the resources of the Nation's coastal zone for this and succeeding generations and to encourage
coastal states to develop and implement coastal zone management (CZM) programs. Each federal
agency activity within or outside the coastal zone that affects any land or water use or natural
resource of the coastal zone shall be carried out in a manner which is consistent to the maximum
extent practicable with the enforceable policies of approved state management programs. Each
federal agency carrying out an activity subject to the Act shall provide a consistency determination
to the relevant state agency designated under § 1455(d)(6) of this title at the earliest practicable
time.
In 1977, Hawaiʻi enacted HRS 205A (Coastal Zone Management). The CZM area encompasses
the entire state, including all marine waters seaward to the extent of the state’s police power and
management authority, including the 12-mile U.S. territorial sea and all archipelagic waters. The
objective and policies of the CZM Program are set forth in HRS § 205A-2 and detailed below:
(1) Recreational Resources
Objective:
(A) Provide coastal recreational opportunities accessible to the public.
Policies:
(A) Improve coordination and funding of coastal recreational planning and management;
and
(i) Provide adequate, accessible, and diverse recreational opportunities in the coastal
zone management area by: Protecting coastal resources uniquely suited for
recreational activities that cannot be provided in other areas;
(ii) Requiring replacement of coastal resources having significant recreational value,
including but not limited to surfing sites, fishponds, and sand beaches, when such
resources will be unavoidably damaged by development; or requiring reasonable
monetary compensation to the state for recreation when replacement is not
feasible or desirable;
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(iii) Providing and managing adequate public access, consistent with conservation of
natural resources, to and along shorelines with recreational value;
(iv) Providing an adequate supply of shoreline parks and other recreational facilities
suitable for public recreation;
(v) Ensuring public recreational use of county, state, and federally owned or controlled
shoreline lands and waters having recreational value consistent with public safety
standards and conservation of natural resources;
(vi) Adopting water quality standards and regulating point and nonpoint sources of
pollution to protect, and where feasible, restore the recreational value of coastal
waters.
(vii) Developing new shoreline recreational opportunities, where appropriate, such as
artificial lagoons, artificial beaches, and artificial reefs for surfing and fishing; and
(viii) Encouraging reasonable dedication of shoreline areas with recreational value for
public use as part of discretionary approvals or permits by the land use
commission, board of land and natural resources, and county authorities; and
crediting such dedication against the requirements of section 46-6.
All project locations are at least 3.3 miles from the shoreline and, as such, the Proposed Action
will not affect coastal recreational resources under any of the Proposed Alternatives.
(2) Historic Resources
Objective:
(A) Protect, preserve and, where desirable, restore those natural and manmade historic and
prehistoric resources in the coastal zone management area that are significant in Hawaiian
and American history and culture.
Policies:
(A) Identify and analyze significant archaeological resources;
(B) Maximize information retention through preservation of remains and artifacts or salvage
operations; and
(C) Support state goals for protection, restoration, interpretation, and display of historic
resources.
Under Alternative 1 and 2, The proposed wastewater collection system will be constructed along
the existing County streets and two short segments within easements in the Pāhala community
that have been previously disturbed when the streets were constructed. Preliminary analysis
shows the treatment and disposal facility will be constructed in an area that does not contain
archaeological resources. An AIS, which included subsurface testing, was conducted to confirm
the presence or absence of archaeological resources on the proposed collection system area. The
AIS confirmed no significant artifacts or cultural deposits were observed on the ground surface
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within the Proposed WWTP Site as the area experiences ongoing disturbance by macadamia
harvesting operations and stormwater runoff. Further, no cultural deposits or lava tubes were
encountered during the subsurface trenching.
In 2023, an Archeological Literature Review Report was conducted to determine the likelihood
that historic properties may be affected by any of the Proposed Alternatives and based on the
findings, consider cultural resource management recommendations. The literature review
concluded that surface pre-Contact sites are not expected within the Project Area given the known
traditional land use in this area and the impacts of continued agricultural and residential
development. The modern development of the macadamia nut orchard has likely also obliterated
any plantation-era sites once present in that part of the Project Area. Historic surface features
associated with the sugar plantation and associated village may be present. Furthermore, there
is potential for pre- or post-Contact subsurface archaeological features within the Project Area,
which may or may not be located within lava tubes. It should be noted that the literature review
is intended to support the project's historic and environmental review process; however, the
report does not fulfill the requirements of an archeological inventory survey investigation as set
forth in federal and State of Hawai'i historic preservation review requirements. For more
information, please refer to Appendix B.
The contract drawings will state that, should archaeological sites such as walls, platforms,
pavements or mounds, or remains such as artifacts, burials, concentrations of shell or charcoal
be encountered during construction activities, work will cease immediately, and the find will be
protected from further damage. The contractor will immediately contact SHPD, who will assess
the significance of the find and recommend an appropriate mitigation measure, if necessary.
(3) Scenic and Open Space Resources
Objective:
(A) Protect, preserve, and where desirable, restore or improve the quality of coastal scenic
and open space resources.
Policies:
(A) Identify valued scenic resources in the coastal zone management area;
(B) Ensure that new developments are compatible with their visual environment by
designing and locating such developments to minimize the alteration of natural
landforms and existing public views to and along the shoreline;
(C) Preserve, maintain, and, where desirable, improve and restore shoreline open space
and scenic resources; and
(D) Encourage those developments which are not coastal dependent to locate in inland
areas.
All project locations are at least 3.3 miles from the shoreline and, as such, coastal scenic and
open space resources will not be affected under any of the Proposed Alternatives.
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(4) Coastal Ecosystems
Objective:
(A) Protect valuable coastal ecosystems, including reefs, from disruption and minimize
adverse impacts on all coastal ecosystems.
Policies:
(A) Exercise an overall conservation ethic, and practice stewardship in the protection, use,
and development of marine and coastal resources;
(B) Improve the technical basis for natural resource management; \
(C) Preserve valuable coastal ecosystems, including reefs, of significant biological or
economic importance;
(D) Minimize disruption or degradation of coastal water ecosystems by effective regulation
of stream diversions, channelization, and similar land and water uses, recognizing
competing water needs; and
(E) Promote water quantity and quality planning and management practices that reflect the
tolerance of fresh water and marine ecosystems and maintain and enhance water quality
through the development and implementation of point and nonpoint source water
pollution control measures.
All project locations are at least 3.3 miles from the shoreline and, as such, coastal ecosystems
will not be adversely affected under any of the Proposed Alternatives.
(5) Economic Uses
Objective:
(A) Provide public or private facilities and improvements important to the State’s economy
in suitable locations.
Policies:
(A) Concentrate coastal dependent development in appropriate areas;
(B) Ensure that coastal dependent developments such as harbors and ports, and coastal
related development such as visitor facilities and energy generating facilities, are
located, designed, and constructed to minimize adverse social, visual, and
environmental impacts in the coastal zone management area; and
(C) Direct the location and expansion of coastal dependent developments to areas presently
designated and used for such developments and permit reasonable long-term growth
at such areas, and permit coastal dependent development outside of presently
designated areas when:
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(i) Use of presently designated locations is not feasible;
(ii) Adverse environmental effects are minimized; and
(iii) The development is important to the State’s economy.
All project locations are at least 3.3 miles from the shoreline. The collection system and the
treatment and disposal facility will be sited in suitable locations to serve the Pāhala community.
(6)Coastal Hazards
Objectives:
(A) Reduce hazard to life and property from tsunami, storm waves, stream flooding, erosion,
subsidence, and pollution.
Policies:
(A) Develop and communicate adequate information about storm wave, tsunami, flood,
erosion, subsidence, and point and nonpoint source pollution hazards;
(B) Control development in areas subject to storm wave, tsunami, flood, erosion, hurricane,
wind, subsidence, and point and nonpoint pollution hazards;
(C) Ensure that developments comply with requirements of the Federal Flood Insurance
Program;
(D) Prevent coastal flooding from inland projects.
All project locations are at least 3.3 miles from the shoreline and at least 580 feet above mean
sea level (msl). Based on the location, the Proposed Action will not be subject to (and will not
exacerbate) coastal hazards and do not include improvements related to tsunami, storm waves,
stream flooding erosion, subsidence and pollution under any of the Proposed Alternatives.
(7)Managing Development
Objective:
(A) Improve the development review process, communication, and public participation in
the management of coastal resource and hazards.
Policies:
(A) Use, implement, and enforce existing law effectively to the maximum extent possible in
managing present and future coastal zone development;
(B) Facilitate timely processing of applications for development permits and resolve
overlapping or conflicting permit requirements; and
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(C) Communicate the potential short- and long-term impacts of proposed significant coastal
developments early in their life cycle and in terms understandable to the public to
facilitate public participation in the planning and review process.
A public information meeting for the Draft EA was held in October 2018. A total of six
community outreach sessions to discuss the Amended AOC were conducted in the Pahala and
Naalehu communities between March 2022 and September 2023. The sixth session,
held on December 14, 2023, was conducted specifically to inform the community of the
preparation of this Draft EID and the public comment period.
A semi-annual community informational meeting in Pāhala on February 29, 2024 to give an
update regarding the closures of the large capacity cesspools in Pāhala and Nā‘ālehu. The next
semi-annual community informational meeting will be held in August 2024 in Nā‘ālehu. In
addition to the semi-annual community meetings, the County held a community meeting on
April 10, 2024 at the Pāhala Community Center to provide comments on the Amended Draft
EID.
The Project Area is located at least 3.3 miles from the coast, at least 580 feet above msl, and do
not involve management of coastal resources and hazards under any of the Proposed Alternatives.
(8) Public Participation
Objective:
(A) Stimulate public awareness, education, and participation in coastal management.
Policies:
(A) Promote public involvement in coastal zone management processes;
(B) Disseminate information on coastal management issues by means of educational
materials, published reports, staff contact, and public workshops for persons and
organizations concerned with coastal issues, developments, and government activities;
and
(C) Organize workshops, policy dialogues, and site-specific mediations to respond to coastal
issues and conflicts.
A public information meeting for the Draft EA was held in October 2018. A total of eight
community outreach sessions to discuss the Amended AOC were conducted in the Pahala and
Naalehu communities between March 2022 and April 2024. The next semi-annual community
informational meeting will be held in August 2024 in
Nā‘ālehu.
(9) Beach Protection
Objective:
(A) Protect beaches for public use and recreation.
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Policies:
(A) Locate new structures inland from the shoreline setback to conserve open space,
minimize interference with natural shoreline processes, and minimize loss of
improvements due to erosion;
(B) Prohibit construction of private erosion-protection structures seaward of the shoreline,
except when they result in improved aesthetic and engineering solutions to erosion at
the sites and do not interfere with existing recreational and waterline activities; and
(C) Minimize the construction of public erosion-protection structures seaward of the
shoreline.
All project locations are at least 3.3 miles from the shoreline. Proposed Action does not include
improvements that would affect public use beaches under any of the Proposed Alternatives.
(10) Marine Resources
Objective:
(A) Promote the protection, use, and development of marine and coastal resources to assure
their sustainability.
Policies:
(A) Ensure that the use and development of marine and coastal resources are ecologically
and environmentally sound and economically beneficial;
(B) Coordinate the management of marine and coastal resources and activities to improve
effectiveness and efficiency;
(C) Assert and articulate the interests of the State as a partner with federal agencies in the
sound management of ocean resources within the United States exclusive economic
zone;
(D) Promote research, study, and understanding of ocean processes, marine life, and other
ocean resources in order to acquire and inventory information necessary to understand
how ocean development activities relate to and impact upon ocean and coastal
resources; and
(E) Encourage research and development of new, innovative technologies for exploring,
using, or protecting marine and coastal resources.
All project locations are at least 3.3 miles from the shoreline. The Proposed Action does not
include improvements that would affect development of marine and coastal resources under any
of the Proposed Alternatives.
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4.7 Endangered Species Act (16 U.S.C. § 1531)
On December 28, 1973, the Endangered Species Act (16 U.S.C. § 1531) was passed and, over
the years, has been amended a number of times. The stated purpose of the original Act was to
provide a means whereby the ecosystems upon which endangered species and threatened
species depend may be conserved, to provide a program for the conservation of such endangered
species and threatened species, and to take such steps as may be appropriate to achieve the
purposes of various related treaties and conventions. The provisions of the Act are administered
by the FWS and the National Oceanic and Atmospheric Administration (NOAA), National Marine
Fisheries Service (NMFS). The FWS has primary responsibility for terrestrial and freshwater
organisms, while NOAA/NMFS is mainly responsible for marine wildlife.
Section 7 of the Act, Interagency Cooperation (16 U.S.C. § 1536), states each federal agency
shall, in consultation with and with the assistance of the Secretary of the Interior, ensure that
any action authorized, funded, or carried out by such agency (an "agency action") is not likely to
jeopardize the continued existence of any endangered species or threatened species or result in
the destruction or adverse modification of habitat of such species which is determined, after
consultation as appropriate with affected states, to be critical, unless such agency has been
granted an exemption for such action.
In August 2018, a biological resources field survey was conducted on the 14.9-acre WWTP Site
and the collection system. The results of the survey show that, due to the proposed alignment of
the collection system along existing roadways, vegetation in the collection system area consists
entirely of maintained yards with ornamental plants.
The field survey of the 14.9-acre WWTP Site indicates that the site is comprised of a macadamia
nut orchard of mature trees, unmaintained areas outside the orchard dominated by Guinea grass,
lanes of windbreak trees oriented between orchard units, and (mostly) mowed road verge areas.
A total of 52 species of vascular plants: two ferns, one gymnosperm, and 49 species of
angiosperms (flowering plants) were identified during the survey. Only two species (4 percent)
identified during the survey are regarded as native to the Hawaiian Islands and both are
indigenous (native, but also distributed elsewhere in the Pacific). Being widely distributed
indigenous species, neither is listed as threatened or endangered or of any special concern.
The August 2018 field survey included assessment of mammalian species. With the exception of
the endangered Hawaiian hoary bat (Lasiurus cinereus semotus), or ‘ōpe‘ape‘a as it is known
locally, all terrestrial mammals currently found on the Island of Hawaiʻi are alien species, and
most are ubiquitous. The field survey reported no mammalian species within the survey area.
This also included no indication that pigs (Sus scrofa) utilize the survey area.
The field survey also included an assessment of avian species, and recorded a total of 175
individual birds of 13 species, representing nine separate families, during station counts. Avian
diversity and densities were very low, in keeping with the current usage of the site as a mature
macadamia nut orchard, with minimal ground cover and few weedy or shrubby species. All of the
avian species recorded during the course of the survey are established alien species. No native
avian species were recorded during the course of the survey. The field survey recorded no species
of plants or animals currently listed or proposed for listing under either the federal or State of
Hawai‘i endangered species statutes.
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On December 21, 2018, the designated non-federal representative for consultations under Section
7 of the Endangered Species Act, on behalf of EPA and the County of Hawaiʻi, requested
concurrence from the FWS that the Pāhala LCC Replacement Project is not likely to adversely
affect federally listed threatened and endangered species or critical habitat located within the
Project Area.
On February 15, 2019, the FWS provided a letter that concluded: "The Service has analyzed
potential impacts to listed species due to the implementation of [the] project. Based on the
inclusion of the avoidance and minimization measures listed above, the Service anticipates that
any potential impacts will be discountable or insignificant and therefore we concur that the Pāhala
LCC Replacement Project may affect, but is not likely to adversely affect the endangered Hawaiian
hoary bat, Hawaiian Hawk, Hawaiian goose, Hawaiian Petrel, Band-rumped Storm-Petrel,
Hawaiian Stilt, and Hawaiian Coot, and the threatened Newell’s Shearwater” (See Appendix C-1
of the FEA). The Proposed Action will incorporate the avoidance and minimization measures cited
in the FWS letter, including (but not limited to) avoiding impacts to potential Hawaiian hoary bat
habitat during the bat birthing and pup rearing season; conducting a Hawaiian hawk nest survey
prior to any work during the nesting season; avoiding activities near active nests; and avoiding
nighttime construction during the seabird fledging period.
On February 23, 2024, the designated non-federal representative for consultations under Section
7 of the Endangered Species Act, on behalf of EPA and the County of Hawaiʻi, provided a letter
to the FWS which provided an updated description of the project and acknowledged that the
project area has remained consistent with previous consultation efforts. The intent of this letter
was to determine if Section 7 consultation would need to be re-initiated due to the project
updates. On March 11, 2024, FWS provided an email which concluded that the project would not
need to undergo further Section 7 consultation as there were no significant changes to the project
footprint or associated activities.
4.8 Environmental Justice Executive Order 12898
Executive Order 12898, Environmental Justice (full title Federal Actions to Address Environmental
Justice to Minority and Low Income Populations), was signed on February 11, 1994. The intent
of Executive Order 12898 is to avoid disproportionately high adverse human health or
environmental effects of projects on minority and low income populations. Executive Order 12898
also requires federal agencies ensure that minority and low-income communities have adequate
access to public information related to health and the environment.
The 2021 American Community Survey (ACS) (5-Year Estimates) is the most recent information
related to socioeconomic conditions in the state and County. The 2021 ACS includes Hawai‘i
Geographic Area Profiles – Census Designated Places: Neighbor Islands. The ACS noted it is the
Census Bureau's Population Estimates Program that produces and disseminates the official
estimates of the population for the nation, states, counties, cities and towns and estimates of
housing units for states and counties.
For purposes of this assessment, and to correspond with the available ACS demographic
characteristics data, “low income” is defined as having a household income of less than $24,999;
“minority” is defined as any race population other than White; and “children” is defined as the
“Under 5 to 19” age category.
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Pāhala has more households in the “less than $24,999” income bracket (25.0 percent) than the
County as a whole (18.9 percent).
Overall, Pāhala is characterized by a racial composition that includes a greater proportion of
minorities ( 82.4 percent non-White) than the County at large (67.4 percent non-White). The
racial distribution includes a much lower proportion of White residents, a much higher proportion
of Filipino residents, and lower populations of other minority groups, including Native Hawaiians
when compared to the County. There are also more residents of two or more races in Pāhala
than in the County.
Pāhala has a similar age distribution to the County, although Pāhala has a higher proportion of
individuals in the “Under 5 to 19” age category (33.0 percent) compared to the County as a whole
(23.6 percent).
Based on the above, Pāhala has a higher proportion of low-income, minority, and children
residents as compared to the County as a whole. However, the Proposed Action will not result in
disproportionately high and adverse human health or environmental effects on these sensitive
populations under any of the Proposed Alternatives. The design and location of the WWTP facility
will minimize odor and air quality impacts. Construction of the wastewater collection system will
result in intermittent and unavoidable noise from construction vehicles and equipment within the
Pāhala community, including noise associated with the removal of bedrock. However, construction
activities within the community will comply with provisions of HAR 11-46 (Community Noise
Control). This includes obtaining a noise permit for any activities that will generate noise
exceeding the permissible sound levels specified in HAR 11-46. The permit will limit excessive
noise sources to daytime hours; will require the use of best available control technology to control
noise levels from excessive noise sources; and will require the applicant to notify affected
members of the public in advance of any planned nighttime construction activity (which must not
exceed the permissible sound levels). Overall, the Proposed Action is expected to result in positive
human health and environmental effects to Pāhala residents by providing a cleaner and longer-
lasting wastewater treatment system.
4.9 Farmland Protection Policy Act (7 U.S.C. § 4201)
The Agriculture and Food Act was passed in 1981 and contained the Farmland Protection Policy
Act (FPPA) (7 U.S.C. § 4201). The stated purposes of the FPPA are to: 1) minimize the extent to
which federal programs contribute to the unnecessary and irreversible conversion of farmland to
nonagricultural uses; and 2) assure that federal programs are administered in a manner that, to
the extent practicable, will be compatible with state, unit of local government, and private
programs and policies to protect farmland. “Farmland” subject to FPPA requirements does not
have to be currently used for cropland.
The FPPA is administered by the U.S. Department of Agriculture (USDA), National Resources
Conservation Service (NRCS). “Farmland”, as used in the FPPA, includes prime farmland, unique
farmland, and land of statewide or local importance, as defined by the State of Hawai‘i
Department of Agriculture.
Per the Agricultural Lands of Importance to the State of Hawai‘i (ALISH) Classification System,
the collection system is located in “unclassified” lands and the proposed WWTP package plant
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and effluent disposal facility will be located on approximately 20 percent “prime”, 40 percent
“other” and 40 percent “unclassified” land.
Under Alternatives 1 and 2, The proposed collection system will be located primarily within the
streets and shoulders in Pāhala and therefore will not affect farmlands. The 14.9-acre WWTP
package plant and effluent disposal facility is located within an existing macadamia nut orchard.
The 2012 Census Agriculture shows about 17,378 acres in the County are planted with macadamia
nuts. As such, the removal of the 14.9-acre area required for the Pāhala WWTP Site will not
significantly affect macadamia nut production in the state or the County. Additionally, the
construction of the IWS under Alternatives 3 and 4 would occur on a total of 174 residential lots
and would not affect macadamia nut production in the state or the County.
In accordance with the implementation procedures for the FPPA site assessment criteria (7 CFR
658), EPA is coordinating with the local NRCS field office to complete a Farmland Conversion
Impact Rating Form for the Pāhala LCC Closure Project. This form is used to assess the potential
adverse effects on the protection of farmland; support the consideration of alternative actions;
and assess compatibility with state and local programs and policies to protect farmland. After the
alternative is selected, EPA will finalize the document and provide a copy of the form to the NRCS
field office in accordance with 7 CFR 658.4(g).
4.10 Fish and Wildlife Coordination Act (16 U.S.C § 661)
The Fish and Wildlife Coordination Act (16 U.S.C § 661), enacted on March 10, 1934, was
amended on August 12, 1958. The purpose of the Act is to recognize the vital contribution of
wildlife resources to the Nation, the increasing public interest and significance, and to provide
that wildlife conservation shall receive equal consideration and be coordinated with other features
of water-resource development programs through the effectual and harmonious planning,
development, maintenance, and coordination of wildlife conservation. The Act defines wildlife and
wildlife resources as birds, fishes, mammals and all other classes of wild animals, and all types of
aquatic and land vegetation upon which wildlife is dependent (16 U.S.C. § 666b).
The Secretary of the Interior is authorized (1) to provide assistance to, and cooperate with,
federal, state, and public or private agencies and organizations in the development, protection,
rearing, and stocking of all species of wildlife, and their habitat; in controlling losses of the from
disease or other causes; in minimizing damages from overabundant species; and in providing
public shooting and fishing areas, including easements across public lands; (2) to make surveys
and investigations of the wildlife of the public domain, including lands and waters acquired or
controlled by any agency; and (3) to accept donations of land and contributions of funds in
furtherance of the purposes of the Act.
Specifically, the Act states that “whenever the waters of any stream or other body of water are
proposed or authorized to be impounded, diverted, the channel deepened, or the stream or other
body of water otherwise controlled or modified for any purpose whatever, including navigation
and drainage, by any department or agency of the United States, or by any public or private
agency under Federal permit or license, such department or agency first shall consult with the
United States Fish and Wildlife Service” (16 U.S.C. § 662(a)). The consultation may result in a
report of recommendations by FWS that should be adopted to prevent the loss of or damage to
wildlife resources. The provisions of the Act do not apply to impoundments of water less than 10
acres.
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The Proposed Action does not include any impoundment of water and therefore a Fish and Wildlife
Coordination Act review and/or consultation pursuant to 16 U.S.C. § 662 is not required under
any of the Proposed Alternatives.
4.11 Floodplain Management (Executive Order 11988, as amended by
Executive Orders 12148 and 13690)
Executive Order 11988, Floodplain Management, dated May 24, 1977 requires federal agencies
to avoid, to the extent possible, the long- and short-term adverse impacts associated with the
occupancy and modification of floodplains and to avoid direct and indirect support of floodplain
development wherever there is a practicable alternative.
In accomplishing this objective, "each agency shall provide leadership and shall take action to
reduce the risk of flood loss, to minimize the impact of floods on human safety, health, and
welfare, and to restore and preserve the natural and beneficial values served by floodplains in
carrying out its responsibilities.”
The Proposed Action is not located within a 100-year floodplain area, will incorporate stormwater
BMPs to manage runoff in accordance with state requirements, and will be designed to ensure
sufficient capacity for assimilation of peak effluent flow rates and precipitation from the design
storm event. The Proposed Action therefore will not have an adverse impact on floodplains and
will minimize the risk of flood-related impacts on surrounding properties under any of the
Proposed Alternatives.
4.12 Magnuson-Stevens Fishery Conservation and Management Act (16
U.S.C. § 1801)
The 1996 Sustainable Fishery Act amendments to the Magnuson-Stevens Fishery Conservation
and Management Act and subsequent Essential Fish Habitat (EFH) Regulatory Guidelines (NOAA,
2002) describe provisions to identify and protect habitats of federally managed marine and
anadromous fish species. Under the various provisions, federal agencies that fund, permit, or
undertake activities that may adversely affect EFH are required to consult with the NMFS.
Congress defines EFH as “those waters and substrate necessary to fish for spawning, breeding,
feeding, or growth to maturity.” EFH is further defined by the existing regulations (NOAA-NMFS,
2007; NOAA, 2002). “Waters” include aquatic areas and their associated physical, chemical, and
biological properties that are used by fish and may include aquatic areas historically used by fish
where appropriate; “substrate” includes sediment, hard bottom, structures underlying the waters,
and associated biological communities; “necessary” means the habitat required to support a
sustainable fishery and the managed species’ contribution to a healthy ecosystem; and
“spawning, breeding, feeding, or growth to maturity” covers a species’ full life cycle.
All project locations are at least 3.3 miles from the shoreline. The Proposed Action will not
adversely impact EFH under any of the Proposed Alternatives.
4.13 Marine Mammal Protection Act (16 U.S.C. §§ 1361 et seq.)
The Marine Mammal Protection Act (MMPA) (16 U.S.C. §§ 1361 et seq.), protects all marine
mammals. The MMPA includes a general moratorium on the taking and importing of marine
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mammals, and prohibits, with certain exceptions, the “take” of marine mammals in U.S. waters
and by U.S. citizens on the high seas, and the importation of marine mammals and marine
mammal products into the U.S. Jurisdiction for MMPA is shared by the FWS and NMFS. The FWS
Branch of Permits is responsible for issuing take permits when exceptions are made to MMPA.
Under the exception for incidental taking, the FWS or the NMFS must find that the total taking
over the five-year period will have a “negligible impact” and will not adversely affect the
availability of the marine mammal species or stock for subsistence use by natives.
All project locations are at least 3.3 miles from the shoreline. The Proposed Action will not
adversely impact marine mammal communities and will not encourage any “take” of marine
mammals under any of the Proposed Alternatives.
4.14 Migratory Bird Treaty Act (16 U.S.C. §§ 703 et seq.)
The Migratory Bird Treaty Act (MBTA) and Executive Order 13186 (Responsibilities of Federal
Agencies to Protect Migratory Birds) provide for the protection of migratory birds. The MBTA of
1918, as amended (16 U.S.C. §§ 703-712) makes it unlawful to, among other things, pursue,
hunt, take, capture, kill, transport or import any species listed under the Act. The Act implements
conventions between the U.S., Great Britain, Mexico, Japan, and the former Soviet Union.
Executive Order 13186 was issued to assist federal agencies with their efforts to comply with the
MBTA. It should be noted that the Executive Order does not constitute any legal authorization
that in any way supersedes the requirements outlined in the MBTA. The Executive Order directs
federal agencies undertaking actions that have or are likely to have a measurable adverse impact
on migratory bird populations to develop and implement a Memorandum of Agreement with the
FWS addressing the conservation of these populations.
The initial field survey at the collection system and the 14.9 acre WWTP site found a total of 175
individual birds of 13 species, none of which are native to the Hawaiian Islands. Avian diversity
and densities were very low, which is consistent with the current site use as a mature macadamia
nut orchard with limited ground cover and few weedy or shrubby species. The field survey did
indicate that endemic Hawaiian Petrel (Pterodroma sandwichensis) and Newell’s Shearwater
(Puffinus newelli) have been recorded flying over the general area between April and the end of
November each year. Impact avoidance and minimization measures will be implemented,
including down-shielding of lights and avoiding nighttime construction during the seabird fledging
period. The Proposed Action will also avoid impacts to potential Hawaiian hoary bat habitat
(woody plants greater than 15 ft tall) during the bat birthing and pup rearing season (June 1
through September 15), which in turn will also reduce the potential take of migratory birds due
to tree clearing during that period.
A secondary field survey of the Project Area in 2023 noted that one additional species, the
Hawaiian Hawk (Buteo solitarius) was recorded as an incidental observation. It is
recommended that a nesting hawk survey be conducted by a qualified biologist within three
days ahead of any large stature trees are trimmed or felled to ensure that no active nest is
disturbed. It is presently unclear if any such action will occur as part of this Project.
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4.15 National Historic Preservation Act (54 U.S.C. § 300101)
The National Historic Preservation Act (NHPA) of 1966 (54 U.S.C. § 300101) requires a federal
agency undertaking an action/project consider of the effect of the project on any historic property
defined as a district, site, building, structure, or object that is included in or eligible for inclusion
in the National Register of Historic Places.
Section 106 of the NHPA (54 U.S.C. § 306108) requires a federal agency having direct or indirect
jurisdiction over a federal or federally assisted undertaking to take into account the effect of the
undertaking on any historic property. An “undertaking” includes a “project, activity, or program
funded in whole or in part under the direct or indirect jurisdiction of a Federal agency” (54 U.S.C.
§ 300320). Because the Pāhala LCC Replacement Project will be funded using federal funds, it is
considered an “undertaking” and is subject to the NHPA.
The Act requires the federal agency’s preservation-related activities to be carried out in
consultation with other federal, state, and local agencies, Indian tribes, Native Hawaiian
organizations (54 U.S.C § 306102).
The proposed collection system will be constructed along the existing County streets and two
short segments within private easements in the Pāhala community that have been previously
disturbed when the streets were constructed. Preliminary analysis shows the proposed treatment
and disposal facility will be constructed in an area that does not contain archaeological resources.
An AIS, which included pedestrian surveys and subsurface testing, was conducted to confirm the
presence or absence of archaeological resources on the 14.9-acre WWTP Site and Collection
System Area. Based on the AIS, no properties eligible for inclusion on the National Register of
Historic Places are present within the area of potential effects for the 14.9-acre WWTP Site and
Collection System Area, and no significant artifacts or cultural deposits on the ground surface and
no cultural deposits or lava tubes were encountered during subsurface testing.
Based on the above and in accordance with 36 CFR § 800.4(d), EPA reached a finding of “no
historic properties affected for the project or undertaking.” On September 26, 2019, EPA sent a
letter to SHPD to document their determination that no historic properties will be affected by the
undertaking and to request concurrence from SHPD. The potential for encountering unexpected
archeological resources within the Proposed WWTP Site is low due to historical ground
modifications and ongoing harvesting activities; however, the Proposed Action will incorporate
appropriate mitigation measures should archeological resources be discovered during
construction. Specifically, the contract drawings will state that, should archaeological sites such
as walls, platforms, pavements or mounds, or remains such as artifacts, burials, concentrations
of shell or charcoal be encountered during construction activities, work will cease immediately
and the find will be protected from further damage. The contractor will immediately contact SHPD,
who will assess the significance of the find and recommend appropriate mitigation measures, if
necessary.
As part of previous Environmental Assessment efforts, the County conducted an AIS of the 14.9-
acre treatment and disposal facility, including subsurface testing of the effluent disposal area. To
carry out this AIS, SHPD approved an AIS plan. To meet this requirement, the County submitted
the AIS plan to SHPD on March 22, 2018. On April 25, 2018, SHPD requested clarification, and
responses, including findings from the 2016 field survey report and a map of the proposed
wastewater treatment and disposal facility, were submitted to SHPD on July 31, 2018. SHPD
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approved the AIS plan on August 20, 2018, and the County conducted the AIS of the 14.9-acre
WWTP in September 2018.
In addition to the AIS, the County is obligated to comply with the National Historic Preservation
Act (NHPA). On March 29, 2018, the County initiated consultation for this project in accordance
with Section 106 of the NHPA. Consultation letters were sent to various Native Hawaiian
Organizations, totaling 15 letters, inviting comments from organizations that may attach religious
or cultural significance to properties affected by the proposed actions. A letter dated February 20,
2020 from the SHPD provides concurrence that no historic properties at the Proposed WWTP Site
shall be affected, under HRS 63-8 and section 106. The AIS and NHPA Section 106 consultation
correspondence can be found in Appendix D and Appendix D-1 of the FEA, respectively.
On March 28, 2024, the designated non-federal representative for consultations under Section
106 of the NHPA, on behalf of EPA and the County of Hawaiʻi, provided a letter to the SHPD which
included an updated description of the project and acknowledged that the project area has
remained consistent with previous consultation efforts. The intent of this letter was to determine
if Section 106 consultation would need to be re-initiated due to the project updates. On April 4,
2024, SHPD provided an email which concluded that the project would not need to undergo
further Section 106 consultation as the project updates under Alternatives 1 and 2 would not
change the previous concurrence that no historic properties shall be affected and the agreement
for archeological monitoring for identification purposes.
As NHPA requirements have been completed under Alternatives 1 and 2, it is advised that the
County seek to consult with SHPD in regards to Alternatives 3 and 4 in accordance with HRS
Chapter 6E requirements, and in relation to Section 106 of the National Historic Preservation Act
(NHPA) – if triggered – and, to incorporate additional impact avoidance and minimization
measures if required for the construction of the IWS.
4.16 Protection of Wetlands (Executive Order 11990 (1977), as amended by
Executive Order 12608 (1997))
Executive Order 11990, Protection of Wetlands, dated 1977 requires federal agencies to avoid,
preserve, or mitigate effects of new construction projects on lands which have been designated
wetlands. Executive Order 11990 states in order to avoid to the extent possible the long- and
short-term adverse impacts associated with the destruction or modification of wetlands and to
avoid direct or indirect support of new construction in wetlands wherever there is a practicable
alternative, it is hereby ordered as follows: Section 1. (a) Each agency shall provide leadership
and shall take action to minimize the destruction, loss or degradation of wetlands, and to preserve
and enhance the natural and beneficial values of wetlands in carrying out the agency's
responsibilities for (1) acquiring, managing, and disposing of federal lands and facilities; and (2)
providing federally undertaken, financed, or assisted construction and improvements; and (3)
conducting federal activities and programs affecting land use, including but not limited to water
and related land resources planning, regulating, and licensing activities.
The National Wetlands Inventory (NWI) Wetlands Mapper and U.S. Geological Survey (USGS)
topographic maps identify no wetland features or streams within the Proposed WWTP Site, at the
two LCCs, or within the Proposed Collection System Area. Biological and archeological field survey
reports do not indicate any standing water or evident wetland vegetation within the area. On
August 2018, a biological field survey was conducted at the 14.9-acre WWTP Site and results of
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the field work indicated that no wetlands were observed on the site (See Appendix C of the FEA).
The man-made drainage feature along Māmalahoa Highway along the edge of the parcel conducts
flow generated from surface runoff underneath the highway and downslope to the east.
Conditions within the ditch itself close to or on the 14.9-acre project site will not likely satisfy the
hydric soil requirement to be defined as a wetland. Streams in the Pāhala area do not flow all the
way to the sea, but terminate on Keone‘ele‘ele Flat to the southwest. Based on this information,
the Proposed Action is not expected to impact wetland resources under any of the Proposed
Alternatives.
4.17 Rivers and Harbors (33 U.S.C. § 403)
Originally enacted on March 3, 1899, the Rivers and Harbors Appropriation Act of 1899 affects
navigable waters of the U.S. Section 10 of the Act states the creation of any obstruction not
affirmatively authorized by Congress, to the navigable capacity of any of the waters of the United
States is prohibited; and it shall not be lawful to build or commence the building of any wharf,
pier, dolphin, boom, weir, breakwater, bulkhead, jetty, or other structures in any port, roadstead,
haven, harbor, canal, navigable river, or other water of the United States, outside established
harbor lines, or where no harbor lines have been established, except on plans recommended by
the Chief of Engineers and authorized by the Secretary of the Army; and it shall not be lawful to
excavate or fill, or in any manner to alter or modify the course, location, condition, or capacity
of, any port, roadstead, haven, harbor, canal, lake, harbor or refuge, or enclosure within the
limits of any breakwater, or of the channel of any navigable water of the United States, unless
the work has been recommended by the Chief of Engineers and authorized by the Secretary of
the Army prior to beginning the same (33 U.S.C. § 403).
All project locations are at least 3.3 miles from the shoreline. The Pāhala WWTP package plant
and effluent disposal facility is situated about 1,500 feet east of the center line of Hi‘onamoa
Gulch. The USGS topographic map shows the gulch stops about 5,500 feet from the shoreline.
The Proposed Action will not affect any streams or gulches. Based on this, Proposed Action will
not affect navigable waters under any of the Proposed Alternatives.
4.18 Safe Drinking Water Act (42 U.S.C. § 300f)
The Safe Drinking Water Act (SDWA) of 1974 (42 U.S.C. § 300f) was established to protect the
quality of all waters actually or potentially designed for drinking use from both underground and
aboveground sources. The SDWA authorizes EPA to establish minimum standards to protect
potable water with which all owners or operators of public water systems must comply; to oversee
the agencies which can be approved to implement these rules on EPA's behalf, such as state
governments; and to encourage attainment of secondary standards (nuisance-related). Section
1424(e) of the SDWA of 1974 (Public Law 93-523, 42 U.S.C. 300 et. seq also established the Sole
Source Aquifer program which states that no commitment for federal financial assistance (through
a grant, contract, loan guarantee, or otherwise) may be entered into for any project which the
EPA Administrator determines may contaminate such aquifer through a recharge zone so as to
create a significant hazard to public health.
The Proposed Action does not establish a drinking water system, and no Sole Source Aquifers are
present on the Island of Hawai‘i. The Proposed Action will provide the infrastructure necessary to
enable the County to comply with the SDWA by replacing the existing outdated and federally
banned wastewater systems that pose a threat to underground sources of drinking water.
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4.19 Wild and Scenic Rivers Act (16 U.S.C. §§ 1271-1287)
The Wild and Scenic Rivers Act, 16 U.S.C. §§ 1271 -1287, declares that certain selected rivers with
their immediate environments, which possess outstandingly remarkable scenic, recreational,
geologic, fish and wildlife, historical, cultural, or other similar values, shall be preserved in their
free-flowing condition for the enjoyment of present and future generations. The State of Hawai‘i
has no designated wild and scenic rivers.
The Wild and Scenic Rivers Act is not applicable to this project.
4.20 Clean Water Act (33 U.S.C. § 1251 et seq.)
The Clean Water Act established the basis for regulating discharges of pollutants into waters of
the U.S. Enacted in 1948, it was originally called the Federal Water Pollution Control Act but
became known as the Clean Water Act with the amendments of 1972. Section 404 of the Clean
Water Act regulates the discharge of dredged or fill material into waters of the U.S. and adjacent
wetlands from development, water resource projects, mining or other infrastructure projects.
Activities are regulated through a permit process that is administered under the responsibility of
the U.S. Army Corps of Engineers. Permits may be issued as either Individual Permits for projects
with potentially significant impacts or general permits for projects with only minimal adverse
effects.
The NWI Wetlands Mapper and USGS topographic maps identify no wetland features or streams
within the WWTP Site, at the two LCCs, within the Proposed Collection System Area, or within
the future IWS lots. Biological and archeological field survey reports do not indicate any standing
water or evident wetland vegetation within the WWTP Site and Collection System Area. On August
2018, a biological field survey was conducted for the proposed WWTP and collection system and
results of the field work indicated that no wetlands were observed on the site. The man-made
drainage feature along Māmalahoa Highway along the edge of the parcel conducts flow generated
from surface runoff underneath the highway and downslope to the east. Conditions within the
ditch itself close to or on the property would not likely satisfy the hydric soil requirement to be
defined as a wetland.
Because no wetland resources are present and no impacts to wetlands are anticipated due to
the nature and design of the WWTP and collection, a Clean Water Act Section 404 permit is not
required.
In addition to the above, the Clean Water Act was amended by the Federal Water Quality Act of
1987 which established provisions for a Clean Water State Revolving Fund (33 U.S.C. § 1383), a
financial assistance program for water infrastructure projects. The program capitalizes on a
partnership between EPA and states to provide loans to eligible recipients through state
programs that act as environmental infrastructure banks providing low-interest loans. As stated
in Section 2.1.2, the Pāhala LCC Replacement Project is being funded in part by the State of
Hawaiʻi DOH Clean Water State Revolving Fund.
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5. Existing Environment, Impacts, and Mitigation Measures
5.1 Climate
Climate on the Island of Hawai‘i and more broadly throughout the state can be characterized as
having low day-to-day and month-to-month variability. Differences in the climate of various areas
are generally attributed to local differences in geology and topography that create microclimates
with different temperature, humidity, wind, and rainfall, and associated local ecosystems
(Department of Geography, 1998).
The climate of Pāhala is typical of the predominantly dry condition found in the Kaʻū District. The
National Oceanic and Atmospheric Administration (NOAA) designates the Kaʻū area as a Humid
Tropical Zone with transitional lowland areas in locations between windward and leeward regions.
The area receives less orographic rainfall since it is not oriented normal to trade wind flow and
exhibits a distinctive summer dry season.
Temperatures in the Kaʻū District generally range between 70 and 80 degrees Fahrenheit during
daylight hours and between 60 and 70 degrees Fahrenheit during night hours. The National
Weather Service maintains a rainfall gauge at Pāhala.
Prevailing trade winds in the Kaʻū District area are from the southeast and usually dominate from
April to November. Wind speeds average about 15 miles per hour and vary between
approximately 10 to 20 miles per hour. Winds from the southwest occur less frequently, mainly
during the winter associated with “Kona” storms (Department of Geography, 1998).
Climate conditions in the Kaʻū District are most likely to change in coming decades. Average
annual precipitation is also likely to change, but climate models are undertain in projections for
Hawaiʻi. Based on ensemble model projections available through the U.S. Environmental
Protection Agencyʻs (EPAʻs) Climate Resilience Evaluation and Awareness Tool (CREAT) Climate
Scenarios Projection Map, projections for the area surrounding the Pāhala range from a minor
decrease in annual precipitation up to considerable increases in annual precipitation by 2060,
depending on the model scenario (hot/dry vs. warm/wet). Other climate concerns include sea
level rise to coastal areas.
Impacts and Mitigation Measures:
Alternatives 1 and 2 - Package Plant:
Under these alternatives, the construction phase may result in temporary greenhouse gas
emissions due to heavy equipment operations and the transportation of supplies to the
WWTP project site and along the streets for the new collection system. However, these
emissions will be temporary during the construction period. Once, construction has been
completed, emissions and green house gases should return to current conditions.
Regarding long-term climate impacts, the project's wastewater treatment and disposal
facility does not discharge to surface water sources, and therefore, it is unlikely to
significantly affect local temperature or precipitation patterns. Climate models suggest
some variability in precipitation, but this is not expected to be substantially influenced by
the project.
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The project's design takes into consideration the potential for increased storm intensity
due to climate change. Berms will be constructed at the 14.9-acre WWTP project site to
contain stormwater during intense weather events, ensuring the facility's resilience to
changing storm patterns.
Alternatives 3 and 4 - Individual Wastewater System Program:
Alternatives 3 and 4 involves the implementation of an IWS Maintenance Contract Model
or Operating Permit model. This alternative would require construction activities on
individual parcels including measures to contain storm water runoff during storm events.
The climate impacts are like those in Alternatives 1 and 2, with the project not significantly
affecting local climate conditions. The design includes measures to address potential
changes in storm intensity, ensuring the facility's resilience.
No-Action Alternative:
Under the No-Action Alternative, the existing LCCs continue to operate without any
modifications. These LCCs are at risk of impacts due to climate change, specifically
changes in precipitation patterns, increased storm intensity, and potential sea level rise.
Climate change-related impacts on the existing LCCs could result in risks to groundwater
and surface water quality. Increased storm intensity and altered precipitation patterns
may exacerbate the challenges of managing wastewater in these LCCs, potentially leading
to overflows or groundwater contamination.
Note, the No-Action Alternative does not involve any mitigation measures to address
climate-related risks.
5.2 Physiography
5.2.1 Topography
The Pāhala community is situated on the slope of Mauna Loa, located west (mauka) of Māmalahoa
Highway. The community encompasses an area of approximately 0.61 square miles. The
developed region of Pāhala exhibits a gradual slope, sloping at approximately 6 percent from the
northwest to the southeast. The community spans from an elevation of 1,000 feet above mean
sea level (msl) to 800 feet above msl, covering a horizontal distance of roughly 3,500 feet.
The streets within the community are designed to follow the natural contours of the terrain,
maintaining level or appropriately sloped grades to facilitate vehicular travel. Consequently, on
certain streets, residential lots on the downhill side of the road are situated several feet below
the road surface, while those on the uphill side are elevated several feet above it.
The existing topography in Pāhala is characterized by these gently sloping to moderately steep
terrains, which play a significant role in the community's layout and land use patterns.
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Impacts and Mitigation Measures:
Alternatives 1 and 2 - Package Plant:
The topographical conditions under Alternative 1 are consistent with the existing
conditions. Construction activities for the new collection system and treatment facility will
involve grading and earthwork primarily at the 4.0-acre package plant site. Erosion control
measures will be implemented to prevent soil erosion and maintain the existing
topographic conditions. Excavation depths of 4 to 10 feet would be needed to place the
various components of the package plant. The effluent disposal facility would require
excavation of trenches of up to 3 to 4 feet would be needed to place the subsurface drip
irrigation lines. The affected areas would be restore d to approximately existing conditions.
The wastewater collection system would be constructed within the right-of way of the
public streets plus three segments within easements. The trenches are typically about 3
feet wide and at least 6 feet deep. Due to the existing topography, several parcels may
require installations of pumps to pump the flows to the street level. Once the line is placed
in the trench, the affected area would be backfilled to restore the area to existing
conditions which means minimal effect on the topographic conditions of the area. Proper
erosion control measures will be implemented to prevent potential soil erosion during the
construction period. Construction of the package plant, subsurface irrigation system and
collection system would not create significant changes to the existing topographic
conditions of the Pāhala area.
Alternatives 3 and 4 - Individual Wastewater System Program:
The topography for Alternatives 3 and 4 aligns with the existing conditions in Pāhala.
Construction activities for the IWS will involve excavation for placement of the septic tank
and absorption bed. Once the tank and effluent disposal system have been put into place,
minor grading will be needed to restore the affected area. Erosion control measures will
be implemented during construction to prevent runoff and soil erosion during storm
events. These measures will be designed to protect the existing topographic conditions of
the surrounding area.
No-Action Alternative:
Under the No-Action Alternative, the existing LCCs are situated within the existing
topography. There are no modifications or construction activities associated with this
alternative, and the topography remains unchanged.
Proper erosion control measures will be implemented to minimize potential impacts on the
topography during construction activities, ensuring its preservation. Overall, the
topography in the Pāhala area is not anticipated to undergo significant alterations as a
result of the proposed project alternatives.
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5.2.2 Geology
The Island of Hawai‘i was formed by the activity of five shield volcanoes. These shield volcanoes
are Kohala (extinct), Mauna Kea (has had activity during recent geologic time), Hualalai (last
erupted in 1801), and Mauna Loa and Kilauea (both of which are still active).
The project site is situated at the eastern end of the island and on the lower, southeastern flank
of the Mauna Loa Volcano. This volcano appears to be made up of at least two huge shield
volcanoes built around two separate eruptive centers, referred to as the Mauna Loa shield. The
Mauna Loa shield has been built principally by eruptions along two rift zones that extend in a
southwest and east-northeast direction from the caldera. Rift zones are elongated areas of ground
fissures where volcanic activity such as earthquakes and volcanic eruptions are concentrated. In
contrast, few eruptions have taken place along the lower northeast rift zone.
Pāhala is situated on the slopes of Mauna Loa. The surrounding area consists of several inter-
stratified beds of volcanic ash that sit upon the exposed bedrock. The Pāhala area is known to
contain lava tubes, which often occur in many places around the Island of Hawai‘i. Generally, a
lava tube is a natural conduit or a void that forms when molten lava flows beneath the hardened
surface of a previous lava flow. When the volcanic eruption stops, and the lava drains out, a lava
tube forms in the void. Lava tubes can range in size from a few inches to more than 25 feet in
diameter. The tubes are generally not visible from the surface, and the diameter and length can
usually be identified only through subsurface probing or geophysical surveys.
Impacts and Mitigation Measures:
Alternatives 1 and 2 - Package Plant:
A geotechnical investigation of the 14.9-acre WWTP project site showed the presence of
a lava tube on a portion the plant site. However, the approximately 4.0-acre package plant
has been sited to avoid the lava tube. The effluent irrigation system would only require
relatively shallow excavation for placement of the effluent disposal lines which would not
affect the geological characteristics of this area of Pāhala.
Grading, excavating, and fill activities during construction of the WWTP package plant and
effluent disposal system and the new collection system would occur no deeper than
approximately 10 feet below grade and thus would not have significant impacts on the
geology in the Pāhala area. If/when bedrock is encountered during excavation for the
proposed actions, removal would be accomplished using excavators or hydraulic hoe rams
and/or pneumatic drill hammers consistent with other construction activities on the
Hawaiian Islands.
Alternatives 3 and 4 - Individual Wastewater System Program:
Alternatives 3 and 4 involves the installation and maintenance of the IWS. While this
alternative may require construction activities that could disturb deeper geological layers
(possibly up to 8 to 10 feet), this depth of excavation should not affect the geology of the
Pahala area. Notwithstanding these activities, the April 2023 PER indicated
construction/installation of an IWS can be a relatively invasive process to a homeowner,
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involving large equipment such as excavators and cranes and removal of fencing, trees
and landscaping and, in some cases, small structures. Moreover, determining a path to
bring large equipment to the IWS site would need to account for building/structures
footprints and roof overhangs and soffits.
No-Action Alternative:
Under the No-Action Alternative, the existing LCCs continue to operate without any
modifications. This alternative does not involve any construction activities or modification
to the existing conditions, and therefore would not cause any impacts to geology in the
Pāhala area.
5.2.3 Soils
According to the U.S. Department of Agriculture Natural Resource Conservation Service (NRCS)
Soil Survey of the island, soils types within the Pāhala area possess moderately high to high
permeability characteristics and consist of well-drained soils formed of volcanic ash. Specifically,
the area includes the following soil profiles:
• Map Unit Symbol (MUSYM) 521 – Nāʻālehu medial silty clay loam, 3 to 10 percent slopes
• MUSYM 522 – Nāʻālehu medial silty clay loam, 10 to 20 percent slopes
• MUSYM 567 – Puʻuʻeo – Nāʻālehu complex, 3 to 10 percent slopes
Impacts and Mitigation Measures:
All Proposed Alternatives
Construction of the new collection system would occur below the travelways or shoulders
of the streets in the Pāhala community. As these areas were previously distrurbed upon
construction of the streets, the collection system would not create adverse impacts to soils
in the area.
Construction of the any of the alternatives would require vegetation removal, clearing,
and excavation. These activities would involve subsurface and surface disturbance to the
soils of the affected areas. These impacts can bela mitigated through incorporating
appropriate stormwater and erosion control measures to ensure that soil erosion and
transport during construction activities are minimized. Typically, the construction plans
and documents would include erosion control plans which the construction contractor
would need to follow.
No-Action Alternative
Under the No-Action Alternative, the existing LCCs would continue to operate without any
modifications. This alternative does not involve any construction activities or modification
to the existing conditions, and therefore would not cause any impacts to soils in the Pāhala
area.
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5.3 Water Resources
5.3.1 Surface Waters
The Pāhala community is situated between two surface water sources, with Pāʻauʻau Gulch to the
north and east and an unnamed branch of Hionamoa Gulch to the south and west. According to
USGS topographic maps, the flows from Pāʻauʻau Gulch terminate about 6,500 feet from the
coast, while the unnamed branch joins Hionamoa Gulch approximately 3,000 feet southwest of
Maile Street. The flows from Hionamoa Gulch also cease about 6,000 feet from the coast.
Water resources in the area are crucial for both the existing wastewater treatment systems and
the local community. Groundwater and surface water sources play a vital role in sustaining the
environment and supporting agriculture.
According to the April 2023 PER, the DOH Wastewater Branch has assigned three-priority levels
to each of the 88,000 cesspools across the state of Hawai‘i. These priority levels ranged from
Priority 1: Significant Risk of Human Health Impacts, Drinking Water Impacts, or Draining to
Sensitive Waters to Priority 4: Impacts Not Identified. Priority 1 and 2 areas would be required to
upgrade sooner and to higher levels of treatment. Under this priority classification system, the
Pāhala area fell under Priority 4, the lowest of those available, as an area for which health and
environmental risks had not been assessed or appeared low. Subsequently, a more
comprehensive 2021 study that explored Hawai‘i’s cesspool prioritization, factoring in a total of
15 risk factors, reached a similar conclusion.
Impacts and Mitigation Measures:
Alternatives 1 and 2 - Package Plant:
Under Alternative 1, construction activities may temporarily impact water resources. The
cumulative areal extent of disturbance for the wastewater treatment and disposal facility
and the new collection system would require coverage under a National Pollutant
Discharge Elimination System (NPDES) construction stormwater permit. Normally, this
permit would mandate the implementation of best management practice (BMP) measures,
such as silt fences, filter socks, and sediment traps to control sediment runoff. Since the
NPDES permit requires detail information about the means and method of construction,
the selected contractor would need to submit the plans and documents to the DOH.
Construction trenches would be designed not to extend deeper than approximately 10
feet below grade when feasible, minimizing disturbance to the geology in the Pāhala area.
It should be noted that construction trenches may need to exceed 10 feet in depth in
some design locations. A Site-Specific Construction BMP plan would be developed to
prevent stormwater runoff along the collection system during construction.
The on-site drainage plan, as per Hawai‘i County Code, Chapter 27, Section 20, would
ensure that runoff caused by the construction activities in the 14.9-acre package plant
and effluent disposal area would need to account for expected one-hour, ten-year storm
event, is retained within the site boundaries. Landscape buffers with dirt berms would act
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as secondary containment during large storm events, further safeguarding against
adverse impacts on adjacent or downstream properties.
Overall, construction-related impacts on surface water resources under Alternatives 1 and
2 are expected to be temporary, with BMPs effectively minimizing potential impacts.
Alternative 3 - Individual Wastewater System-Maintenance Contract Model:
Alternative 3 entails the implementation of an IWS Maintenance Contract Model which,
when properly designed and operated, can be an effective means of wastewater
management; however, IWS that are poorly designed and maintained have been
nationally recognized as having high failure rates. In order to ensure that the systems
function as intended, the design must take into account a variety of technical
considerations including system size, site conditions, location, subsurface soil
characteristics, influent characteristics, and level of treatment.
Should the IWS begin to fail, untreated sewage containing pathogens (e.g., E. coli),
nutrients and other harmful substances could be discharged into the groundwater or into
nearby surface waters.
In the event that the County opts to pursue the IWS Alternatives, the implementation of
BMP measures, including silt fences, filter socks, and sediment traps, would be required
during construction at each IWS site to control sediment runoff. Construction trenches
would generally not extend deeper than approximately 10 feet below grade.
Overall, construction-related impacts on surface water resources under Alternative 3 are
anticipated to be temporary and localized, with BMPs effectively minimizing potential
impacts.
Alternative 4 - Individual Wastewater System-Operating Permit to Homeowners:
Alternative 4 involves the implementation of an IWS Operating Permit model. As noted
under Alternative 3, a properly designed and operated IWS can be an effective means of
wastewater management; however, IWS that are poorly designed and maintained have
been nationally recognized as having high failure rates and have been linked to
contaminated groundwater resources. Under Alternative 4, the homeowner will be
responsible for operating and maintaining the IWS while the County is responsible for
issuing maintenance notifications to the homeowner.
Like the other alternatives, construction activities may temporarily impact water resources.
The implementation of BMP measures, including silt fences, filter socks, and sediment
traps, would be required during construction to control sediment runoff. Construction
trenches would generally not exceed approximately 10 feet below grade.
Construction-related impacts on surface water resources under Alternative 4 are expected
to be temporary and localized, with BMPs effectively minimizing potential impacts.
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No-Action Alternative:
Under the No-Action Alternative, which involves the continued operation of the existing
LCCs without modifications, there would be no construction activities or modifications to
existing conditions. Therefore, this alternative would not cause any impacts to geology or
surface water resources in the Pāhala area.
It's important to note that the No-Action Alternative does not involve any mitigation
measures to address potential stormwater-related risks associated with the existing LCCs.
5.3.2 Groundwater
Groundwater occurs within portions of geologic formations where aquifers receive and store
water. Depending on the geologic conditions of the area, many communities and areas on the
island rely on groundwater wells to obtain drinking water. To protect the quality of underground
sources of drinking water from contamination by subsurface disposal of fluids, Hawai‘i has
adopted the Underground Injection Control (UIC) program administered by the DOH Safe
Drinking Water Branch. Hawai‘i Revised Statues (HRS) 340 E and Hawai‘i Administrative Rules
(HAR) 11-23 (Underground Injection Control) set forth the requirements related to protection of
underground sources of drinking water.
Under HAR 11-62, Appendix F, a minimum separation of 1,000 feet from existing wells is required
for wastewater treatment sites.
On April 3, 2018, in response to the previously issued Draft EA pre-assessment notification, the
DOH Safe Drinking Water Branch indicated that the proposed WWTP Site is located above the
UIC line and, as such, on top of underground sources of drinking water. To avoid impacts to
drinking water wells, sewage injection wells cannot be constructed above the UIC line.
The CWRM indicated that one County and one private well are located in the Pāhala area. The
CWRM confirmed that the County well and storage tank are located approximately 5,300 feet
north of the WWTP Site. The tank lies at about 1,120 feet above msl, which is approximately 480
feet higher in elevation than Pāhala WWTP site. A private well is located within TMK 9 -6-002:016,
the parcel that contains the existing LCC 1 and lies adjacent to the WWTP Site. The CWRM has
indicated this well is used for agricultural purposes, not for domestic purposes.
Impacts and Mitigation Measures
Alternatives 1 and 2 - Package Plant:
The approximately 6-foot trenches needed to support the collection system would be
relatively shallow in relation to groundwater resources in the Pāhala area. Thus,
construction of the collection system would not affect groundwater resources in the area.
The separation (both elevation and horizontal distance) between the Pāhala WWTP site
and the upgradient location of the County drinking water well, would mean construction
and operation of the treatment and disposal facility would not affect potable groundwater
resources in the Pāhala area.
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While use of the two existing LCCs has not resulted in documented impacts to
groundwater or drinking water resources, abandonment of the LCCs would remove a
potential source of such impacts. Abandonment of the existing wastewater collection
system would not affect groundwater within the affected areas.
Alternative 3 and 4 - Individual Wastewater System Program:
Alternatives 3 and 4 entail the implementation of an IWS program which, when properly
designed and operated, can be an effective means of wastewater management; however,
IWS that are poorly designed and maintained have been nationally recognized as having
high failure rates. To ensure that the systems function as intended, the design must take
into account a variety of technical considerations including system size, site conditions,
location, influent characteristics, and level of treatment.
Should the IWS begin to fail, untreated sewage containing pathogens (e.g., E. coli),
nutrients and other harmful substances can be discharged into the groundwater or into
nearby surface waters.
In the event that the County opts to pursue the IWS Alternatives, the implementation of
BMP measures would be required at each site, including silt fences, filter socks, and
sediment traps to control sediment runoff.
Overall, construction-related impacts on groundwater water resources under Alternatives
3 and 4 are anticipated to be temporary and localized, with BMPs effectively minimizing
potential impacts.
No-Action Alternative:
The No-Action Alternative has the potential to adversely impact groundwater resources
due to the continued operation of the existing LCCs. EPA regulations mandate the closure
of LCCs to prevent potential impacts on groundwater resources.
5.4 Agricultural Lands
On November 1965, the Land Study Bureau (LSB) at the University of Hawai‘i issued L.S. Bulletin
No. 6, Detailed Land Classification–Island of Hawai‘i. The LSB compiled and interpreted data on
geology, topography, climate, water resources, soils, and crops and conducted field investigations
to create a land classification for the island. Bulletin No. 6 assigned two types of ratings for each
land type: the overall or master productivity rating, which reflects degree of overall suitability for
agricultural use, ranging from A (Very Good) to E (Very Poor); and selected use ratings, which
indicate the degree of suitability for selected use alternatives. Bulletin No. 6 has not been revised
or re-issued and remains as the reference document for lands classified by the LSB.
In addition to the LSB rating, the State of Hawai‘i has developed the Agricultural Lands of
Importance to the State of Hawai‘i (ALISH) Classification System. This system was developed and
compiled in 1977 by the State Department of Agriculture with assistance from the NCRS, U.S.
Department of Agriculture (formerly the Soil Conservation Service) and the College of Tropical
Agriculture at the University of Hawai‘i as part of a national effort to inventory important
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farmlands. Lands not considered for classification within this system are developed urban lands
(over ten acres), natural or artificial bodies of water (over ten acres), public use lands, forest
reserves, lands with slopes in excess of thirty-five percent, and military installations (except
undeveloped areas over ten acres). The ALISH Classification System identifies the following three
categories of land (equivalent NRCS categories in parentheses):
• Prime Agricultural Lands (Prime Farmlands) – Land that has the soil quality, growing
season, and moisture supply needed to produce sustained high yields of crops
economically when treated and managed according to modern farming methods.
• Unique Agricultural Lands (Unique Farmlands) – Land that has a special combination of
soil quality, location, growing season, and moisture supply, and is used to produce
sustained high-quality yields of a specific crop when treated and managed according to
modern farming methods.
• Other Important Agricultural Land (Additional Farmland of Statewide and Local
Importance) – Land other than Prime or Unique Agricultural Land that is also of statewide
or local importance to agricultural use.
The 2017 US Census Bureau, Census of Agriculture-County Data provides the most recent
information related to acreage planted for various fruits and nuts across the state and for each
county. The 2017 data show a total of 18,170 acres of macadamia nuts were planted in the state,
with 17,504 acres planted in the County, comprising about 96.3 percent of the state total.
Impacts and Mitigation Measures
Alternatives 1 and 2 – Package Plant
The LSB rating indicates the collection system project site as “not rated”, the rating
assigned to developed communities, and a master productivity rating of “D 129” (poor)
for about 50 percent of the proposed wastewater treatment and disposal facility at the
WWTP Site, with the remainder “B” (good). D 129 includes soils from the Māmalahoa
series, deep depth, volcanic ash, stony, well drained, and very poorly suited for mechanical
agitation / tilling. The ALISH map shows the collection system is located in “unclassified”
lands. The ALISH map shows the proposed wastewater treatment and disposal facility
would be located on approximately 20 percent “prime”, 40 percent “other” and 40 percent
“unclassified” land.
Construction of the collection system within the County roads would not affect agricultural
lands or the acreage utilized for the macadamia nut orchard.
Construction of the Pāhala WWTP package plant would require removal of approximately
4.0-acres of macadamia nut trees. Although the remaining macadamia nut orchard would
not be removed, use of the trees for effluent disposal means the lands could not be used
as a productive macadamia orchard. This removal would amount to less than 0.1 percent
of the total County lands planted with macadamia nut trees, which would not substantially
affect the total macadamia nut acreage in the state or the County.
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Abandonment of the two LCCs would reduce the potential for contamination of
groundwater that is used for irrigation of agricultural lands. Otherwise, abandonment of
the LCCs and the existing wastewater collection system would not affect agricultural lands
within the affected areas.
Alternatives 3 and 4 – Individual Wastewater System Program:
As indicated by the LSB rating system, the lots identified for the IWS installation are “not
rated” which is assigned to developed communities. Installation of the IWS would not
affect agricultural lands.
No-Action Alternative
The No-Action Alternative would not impact agricultural lands. Continued operation of the
existing LCCs could introduce pathogens and other contaminants to groundwater sources
used for irrigation of agricultural lands.
5.5 Natural Hazards
The Disaster Mitigation Act of 2000, (Federal Emergency Management Agency (FEMA), 44 Code
of Federal Regulations, Hazards Mitigation Planning required States and Counties to have
approved hazard mitigation plans as of November 1, 2004 to receive Pre-Disaster Mitigation
funding. The development of State and local hazard mitigation plans is critical for maintaining
eligibility for future FEMA mitigation and disaster recovery funding.
Given Hawai‘i’s vulnerability to natural hazards and history of disasters, the State has maintained
and implemented a comprehensive, multi-hazard mitigation strategy to reduce loss of life and
property damage. This strategy is embodied in the 2018 State Multi-Hazard Mitigation Plan. This
plan identifies the major natural hazards that affect the stateʻs population, property, and
infrastructure to the specific hazard, and recommends actions that can be taken to reduce the
risk and vulnerability to the hazard. The State Hazard Mitigation Plan also contains a description
of programs, policy, statutes, and regulations applicable to hazard mitigation. It should be noted
that the 2023 update to this plan has begun and is expected to be released at the end of 2023.
Identified major natural hazards that could affect the State, as well as the County are Climate
Change Effects (including sea level rise (SLR)/coastal erosion), floods, tsunamis, strong,
windstorms/hurricanes, earthquakes, landslides/rockfalls, volcanic activity, and wildfires.
5.5.1 Sea Level Rise
Sea level is rising at increasing rates due to global warming of the atmosphere and oceans and
melting of the glaciers and ice sheets. Rising sea level and projections of stronger and more
frequent El Niño events and tropical cyclones in waters surrounding Hawai‘i indicate a growing
vulnerability to coastal flooding and erosion. The Hawai‘i Sea Level Rise Vulnerability and
Adaptation Report (2017) modeled exposure to chronic coastal flooding and erosion using
projections from the Intergovernmental Panel on Climate Change (IPCC) 5th Assessment Report
(IPCC, 2014) where the high-end scenario was up to 3.2-ft of sea level rise by the end of the
century (Courtney et al., 2020).
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Impacts and Mitigation Measures:
All Proposed Alternatives
No short- or long-term impacts are anticipated during the construction or operation of any
of the alternatives. The Pāhala community is located approximately 3.3 miles from the
nearest coastline and at elevation from 500 to 1,500 feet above Mean Sea Level (MSL).
The community is not anticipated to be impacted by sea level rise under any of the
proposed alternatives.
5.5.2 Flood and Tsunami Threat
The Pāhala community is located between two surface water sources, Pāʻauʻau Gulch to the north
and east, and an unnamed branch of Hi‘onamoa Gulch to the south and west. The USGS
topographic map shows flows from Pāʻauʻau Gulch end about 6,500 feet from the coast, while
the unnamed branch flows into Hi‘onamoa Gulch about 3,000 feet southwest of Maile Street.
Flows from Hi‘onamoa Gulch end about 6,000 feet from the coast. Figure 3.1 illustrates the known
streams and gulches within the Pāhala area.
The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM),
Community Panel No. 155166 1800F, effective date September 29, 2017, shows no special flood
hazard areas present in the Pāhala WWTP site and that most of the Pāhala area is located in Zone
X, which designates areas determined to be outside the 0.2- percent annual chance (500-year)
floodplain. A small portion of the community of Pāhala, including some land within the collection
system project site, is located within Zone X – Other Flood Areas, indicating areas within the 0.2-
percent annual chance (500-year) floodplain, or areas with a 1-percent annual chance of flooding
with average flood depths less than 1 foot.
According to the FIRM, both existing LCCs are also located within Zone X. However, LCC 1 is very
close to the edge of the 500-year floodplain.
Impacts and Mitigation Measures:
All Proposed Alternatives
Based on the above, no significant impacts on flood hazards are anticipated to occur within
the Pāhala region as a result of any alternative considered.
5.5.3 Hurricane and Wind Hazard
The Hawaiian Islands are seasonally affected by Pacific hurricanes from the late summer to early
winter months. The State has been affected once by the significant hurricane (rated Category 3
and higher) Iniki in 1992. Not all identified hurricane and strong wind storm threats make landfall
in Hawai‘i, and actual hurricane strikes in Hawai‘i are relatively rare in modern record. More
commonly, near misses that generate large swell and moderately high winds causing varying
degrees of damage are the hallmark of hurricanes passing close to the islands.
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During hurricanes and storm conditions, high winds cause strong uplift forces on structures,
particularly on roofs. Wind-driven materials and debris can attain high velocity and cause
devastating property damage and harm to life and limb. Along the coastline, a surge of water,
topped by battering waves can move ashore into low lying coastal areas. Due to differences in
atmospheric pressure, tidal stage, coastal topography, and location relative to the eye of the
hurricane it is difficult to predict how hurricane‐induced storm surge may impact a specific
location. It is difficult to predict these natural occurrences, but it is reasonable to assume that
future events will occur. The Project Area is, however, no more or less vulnerable than the rest
of the island to the destructive winds and torrential rains associated with hurricanes.
Impacts and Mitigation Measures:
All Proposed Alternatives
While rare, the threat of hurricanes is present across the State of Hawaiʻi. Construction
activities could potentially exacerbate the effect of hurricanes if loose materials are not
secured prior to the event of a storm and become flying debris. To minimize this hazard,
construction materials and equipment would be stored properly when not in use,
consistent with construction best management practices.
To safeguard against hurricane damage in the long-term, proposed action improvements
would be designed in compliance with American Society of Civil Engineers and
International Building Code standards for wind exposure.
5.5.4 Seismic Hazard
Seismic hazards are those related to ground shaking. Landslides, ground cracks, rock falls and
tsunamis are all seismic hazards. Thousands of earthquakes occur every year in the State of
Hawai‘i. Earthquakes in the Hawaiian Islands are associated with volcanic eruptions or tectonic
movements. Most of these earthquakes are closely related to volcanic processes and are so small
they can only be detected by seismometers. Volcanic hazards in the area are of particular concern
given to the active status of the islands volcanoes. One of the larger and more recent earthquakes
occurred offshore of Puakō, Hawai‛i in 2006. The earthquake measured 6.7 on the Richter Scale
and caused minor damages to structures and buildings. Although difficult to predict, an
earthquake of sufficient magnitude causing structural or other property damage may occur in the
future.
Impacts and Mitigation Measures:
All Proposed Alternatives:
Hawai‘i County Code (HCC) § 5A indicates the “International Building Code, 2006 Edition”
(IBC) – copyrighted and published in 2018 by the International Code Council, Incorporated
– is adopted by the County. Chapter 5 is the applicable code for the construction of
buildings, structures, and facilities in the County. The purpose of the seismic provisions in
the IBC is primarily to safeguard against major structural failures and loss of life; limiting
damage or maintaining functions is not a primary purpose. At a minimum, structures are
to be designed and constructed to resist the effects of ground motions from seismic
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events. The seismic hazard characteristics described in the IBC are based on the seismic
zone and proximity of the site to active seismic sources.
The proposed improvements would be designed and constructed to meet the
requirements of the 2016 IBC and HCC Chapter 5 and would comply with seismic loadings
established for the County of Hawaiʻi. This would minimize the potential for an
uncontrolled release of untreated or partially treated sanitary wastewater, or diesel fuel
from the tank being held for the emergency generator during a seismic event. The County
would also develop a facility management plan in accordance with applicable rules and
regulations.
No-Action Alternative:
The No-Action Alternative includes no construction or modification to existing conditions,
and therefore would not impact seismic hazards in the Pāhala area.
5.5.5 Volcanic Hazard
The US Geologic Survey (USGS) prepared a volcanic hazard zone map for the island of Hawaiʻi
which was last updated in 1997. The map shows lava flow hazard zones for the five on-island
volcanoes. The map utilizes a 9-point ranking system which classifies zones ranked from 1
(highest hazard) thorugh 9 (lowest hazard) based on the probability of covereage by lava flows.
Pāhala area has been assigned a rating of Zone 3. This designates areas which are less hazardous
due to their distance from recently active vents. One to five percent of areas within the Zone 3
rating have been covered by eruptions since 1800, and 15 to 75 percent have been covered within
the past 750 years.
Impacts and Mitigation Measures:
All Proposed Alternatives
Based on the volcanic hazard map, the potential for damage to buildings and structures
is moderate, given the distance between the Pāhala community and active vents and
hazards. At this time, the County has no construction restrictions in Zone 3 areas. Thus,
the volcanic hazard designation would not affect the construction and operation of the
collection system or the treatment and disposal facilities. Although the potential for
volcanic activity in or around Pāhala is present, the likelihood of that impact is relatively
small. In the event of a volcanic eruption that threatens the Pāhala area, it is likely that
damage would occur to residences, the treatment and disposal facility, the collection
system, and other assets in the area. There are no mitigation measures to prevent the
potential impacts from volcanic activity, and the impacts would be similar regardless of
the location of the treatment and disposal facility or treatment system employed.
No-Action Alternative
The No-Action Alternative includes no construction or modification to existing conditions,
and therefore would not impact volcanic hazards in the Pāhala area.
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5.5.6 Wildfire Hazards
Wildfires can threaten life and property, but they can also harm the environment and threaten
important natural resources such as endangered species. While sometimes caused by lightning,
nine out of ten wildfires are human-caused. Put simply, "wildfire" is the term applied to any
unwanted and unplanned fire burning in forest, shrub or grass regardless of whether it is naturally
or human induced (DEM, 2020).
All of the Hawaiian Islands are susceptible to wildfires, especially during prolonged drought and
high winds. In recent years, the average annual cost to suppress wildfires in Hawaiʽi is about
$1,100,000 - making it a Statewide risk (DEM, 2020). The greatest danger of fire is where
wildlands border urban areas. Through August, 2018, wildfires in Hawaiʽi have burned 30,000
acres (about double the annual average). Historically, the majority of these fires have been
directly caused by humans, either directly or by negligence. The Project Site is not located in an
at risk area for wildfires; however, the community to the north of the Project Site is noted as a
High Risk area for wildfire which may potentially impact the Project Area in the event of a wildfire.
As further evidenced by recent events in West Maui, wildfires pose a significant threat to health
and human safety, and must be taken very seriously.
Impacts and Mitigation Measures:
Alternatives 1 and 2
While the proposed alternatives are not anticipated to have impacts that could result in
wildfire events, the Pāhala area is considered to be an area that is at high risk for wildfires.
The State Department of Land and Natural Resources-Division of Forestry and Wildlife
(DLNR-DOFAW) has adopted a Fire Management Handbook, which specifies its standards
for prevention, pre-suppression, and suppression. The document provides a structured
approach in providing for public/firefighter safety and minimizing damage to Hawaiʽi's
environment. Funding for the fire management program is provided by the State's general
fund and federal cost share programs through the U.S. Forest Service. These programs
include the Rural Community Fire Protection and Rural Fire Protection and Control
programs. Additionally, the DLNR-DOFAW is a key agency within the State who can trigger
provisions of the Stafford Act (Fire Suppression Assistance), which provides for FEMA
funding assistance in situations where forest and grass fires on public or private lands
threaten a major disaster to communities and economies.
The package plant and related facilities would be designed according to National Fire
Prevention Association (NFPA) 820 “Standard for Fire Protection in Wastewater Treatment
and Collection Facilities.” In accordance with Hawaiʻi Fire Department requirements, Fire
Department access and water supply to the proposed WWTP site would be designed to
comply with Chapter 18 of NFPA 2006 Uniform Fire Code as amended by the County.
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Alternatives 3 and 4
The IWS systems do not include construction of facilities which would be susceptible to
fire hazards.
No-Action Alternative
The No-Action Alternative includes no construction or modification to existing conditions,
and therefore would not impact wildfire hazards in the Pāhala area.
5.6 Flora and Fauna
The Pāhala community and its surrounding areas contain a variety of vascular plant species. An
initial botanical field study conducted in August 2018 at the Proposed WTTP site indicated the
presence of various plant species, including ornamental plants in maintained yards. Among the
species observed, only two species (Ipomoea indica and Waltheria indica) are regarded as native
to the Hawaiian Islands, both of which are indigenous and widely distributed. These indigenous
species are not listed as threatened, endangered, or of any special concern. Additionally, the
macadamia nut orchards in the area are valuable commercial botanical resources but are not
considered environmentally sensitive. Cook pines (Araucaria columnaris) lining Maile Street along
the western border are considered important elements of the local landscape.
In October 2023, a second botanical survey was conducted in the Project Area. This survey started
on Maile Street near the intersection with Maoula Road and proceeded along the route of the
proposed IWS lots. For the streets occupied by residential lots, the botanists walked the streets
noting the plants observable in the yards to create a separate list (of mostly landscape species)
to support a conclusion that few if any sensitive species are likely to occur on the Project Area.
Consistent with the 2018 survey, the 2023 survey indicated the presence of various plant species,
including ornamental plants in maintained yards. Among the species observed, only two species
(Ipomoea indica and Waltheria indica) are regarded as native to the Hawaiian Islands, both of
which are indigenous and widely distributed. The survey establish that listed species, indeed
native species as only were observed are unlikely to be encountered in areas subjected to
disturbance during the construction of the Proposed Action.
The general area surrounding Pāhala supports a limited range of mammalian and avian species.
An initial biological field survey conducted in August 2018 at the proposed WWTP site identified
terrestrial mammalian species, with the exception of the endangered Hawaiian hoary bat
(Lasiurus cinereus semotus), as alien species, most of which are widespread and ubiquitous on
the Island of Hawaiʻi. The survey did not record any mammalian species within the surveyed area.
The community reported occasional use of the area for pig hunting, but there was no indication
of pig (Sus scrofa) presence during the survey.
In October 2023, a second biological field survey was conducted for the Project Area. During this
study, sign of pigs were encountered in the undeveloped area just west of the town along Maile
Street. Additionally, in 2023, the study heard and observed numerous dogs (Canis lupus familiaris)
across the neighborhood area. It is likely that one or more of the four Muridae (rats and mice)
found on the Island—roof rat (Rattus rattus), brown rat (Rattus norvegicus), Polynesian rat
(Rattus exulans hawaiiensis), and European house mouse (Mus musculus domesticus) use
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resources within the general Project Area on a seasonal basis. These introduced rodents are
deleterious to native ecosystems and native faunal species.
The initial avian survey conducted in August 2018 at the Proposed WWTP site identified avian
species in the general area. The survey recorded a limited diversity of avian species, primarily
consisting of established alien species. No native avian species were recorded during the survey.
The general area occasionally witnesses the presence of endemic Hawaiian Petrel (Pterodroma
sandwichensis) and Newell’s Shearwater (Puffinus newelli) flying over, mainly between April and
the end of November each year. These seabirds are listed as endangered and threatened,
respectively, under both Federal and State endangered species statutes and are susceptible to
adverse impacts from outdoor lighting, which can lead to disorientation, fallout, and injury or
mortality.
The second avian survey conducted in 2023 identified total of 129 individual birds of 14 species,
representing 10 separate families, was recorded during station counts. One additional species,
Hawaiian Hawk (Buteo solitarius) was recorded as an incidental observation. The remaining 14
species recorded are commonly encountered established introduced species. The avian diversity
and densities observed during the surveys are consistent with the habitats present in the area
and usage of the properties. Four species—House Sparrow (Passer domesticus), Zebra Dove
(Geopilia striata), Northern Cardinal (Cardinalis cardinalis), and Japanese White-eye (Zosterops
japonicus)—accounted for 44% of all birds recorded during station counts over the course of the
two surveys. The most frequently recorded species was House Sparrow, which accounted for
12% of the total number of individual birds recorded during station point-counts.
It is possible that the endangered Hawaiian hoary bat (Lasiurus semotus) uses resources within
the Project vicinity. This bat is regularly seen in the Project area (David, 2023) and tall trees
suitable for roosting are present here. This bat species is solitary and rare but with a widespread
distribution on Hawai‘i. Island. However, the bat uses multiple roosts within a home territory
(Bonaccorso, 2015), so the disturbance associated with removal of any particular tree would be
minimal. An exception might be during the pupping season if a female bat carrying a pup or an
unattended pup is in a tree being felled, these individuals could be unable to flee the tree.
Impacts and Mitigation Measures:
All Proposed Alternatives:
Based on the findings of the botanical and biological field surveys, construction activities
associated with the new collection system and wastewater treatment and disposal facility
are not anticipated to result in adverse impacts to botanical and faunal resources in the
Pāhala area.
The operations building in the 4.0-acre package plant will feature down-shielded light
fixtures to minimize the potential for adverse impacts on avian species.
For Alternatives 1 and 2, the DOH initiated consultation with the U.S. Fish and Wildlife
Service (FWS) pursuant to Section 7 of the Endangered Species Act which was completed
under the 2020 FEA. The Project Description as presented in Section 2 of this EID has
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been slightly modified from the 2020 FEA; however the project area and activities remain
consistent.
On February 23, 2024, the designated non-federal representative for consultations under
Section 7 of the Endangered Species Act, on behalf of EPA and the County of Hawaiʻi,
provided a letter to the FWS which included an updated description of the project and
acknowledged that the project area has remained consistent with previous consultation
efforts. The intent of this letter was to determine if Section 7 consultation would need to
be re -initiated due the project updates. On March 11, 2024, FWS provided an email which
concluded that the project would not need to undergo further Section 7 consultation as
there were no significant changes to the project footprint or associated activities. The
avoidance and mitigation measures provided by the FWS are described below.
It should be noted that for Alternatives 3 and 4, the area of disturbance for the proposed
action will take place on private residential property. However, it is expected that
Alternatives 3 and 4 will result in no impacts to botanical and faunal resources.
Generally speaking, minimization measures discussed herein are intended to minimize any
potential impacts on flora and fauna that could result from the construction and operation
of the wastewater treatment and disposal facility and associated infrastructure. The
proactive consultation with relevant authorities ensures compliance with regulations and
protection of sensitive species. Additionally, the note regarding Alternatives 3 and 4
acknowledges the unique context of disturbance on private residential property while
anticipating minimal impacts.
Seabirds
• The Project can minimize or avoid risks to protected night-flying seabirds by not
conducting night-time construction and ensuring that all associated outdoor lighting is
fully shielded (Night sky compliant; HDLNR-DOFAW, 2016).
Hawaiian Hawk
• It is recommended that a nesting hawk survey be conducted by a qualified biologist
within three days that any large stature trees are trimmed or felled to ensure that no
active nest is disturbed. It is presently unclear if any such action will occur as part of
this Project.
Hawaiian Hoary Bat
Potential adverse impacts to Hawaiian hoary bat can be avoided or minimized by not
clearing woody vegetation taller than 4.6 m (15 ft) between June 1 and September 15,
the bat pupping season.
No-Action Alternative:
The No-Action Alternative involves no modifications to the existing LCC system is not
expected to impact flora or fauna.
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5.7 Cultural, Historical, and Archaeological Resources
A 2016 survey of available information identified the presence of one historic site is in the vicinity
of the proposed wastewater collection system. Iin Pāhala, -- the Kaʻū High and Pāhala Elementary
School, is listed on the State of Hawai‘i register of historic places. No other historic sites are found
within the areas designated for improvements.
In November 2016, as part of the initial planning for LCC closure, a one-day archaeological field
inspection was conducted on the 42.5-acre parcel, which includes the 14.9-acre area for the
wastewater treatment and disposal facility. The inspection involved pedestrian sweeps of the
entire 42.5-acre parcel to determine the presence of historic properties or significant
archaeological features. The inspection report indicated that ground modifications carried out
during the plantation period had destroyed evidence of pre-contact agriculture or settlement
activities. The bulldozing associated with the creation of the macadamia nut orchard appeared to
have leveled any plantation-era land features.
The 2016 inspection identified one surface artifact as the only evidence of past human activity on
the 42.5-acre parcel. Th is surface artifacts included a single traditional artifact and numerous late
post-contact artifacts. The single traditional artifact, a crudely-shaped discoidal hammerstone,
was found on the ground surface near the northern edge of the plant site near Maile Street. No
other cultural material, either traditional or post-contact, was observed in this area, suggesting
that the hammerstone reflects an isolated artifact rather than a buried cultural deposit. Although
historical ground modifications have likely limited the archaeological potential of the site, the
discovery of both pre- and post-contact surface artifacts within the 42.5-acre plant parcel, as well
as evidence from plantation-era documents indicating the opening of a lava tube containing
human remains once existed in the southeastern corner of the parcel, suggests that further
archaeological studies may be necessary before any development can commence. The 2016
inventory report recommended at least an Archaeological Inventory Survey (AIS) to fully
document, map, date, and collect surface artifacts. It may also be necessary to test for the
presence of subsurface cultural deposits through hand excavation or mechanical trenching.
As part of previous Environmental Assessment efforts, the County conducted an AIS of the 14.9-
acre treatment and disposal facility, including subsurface testing of the effluent disposal area. To
carry out this AIS, SHPD approved an AIS plan. To meet this requirement, the County submitted
the AIS plan to SHPD on March 22, 2018. On April 25, 2018, SHPD requested clarification, and
responses, including findings from the 2016 field survey report and a map of the proposed
wastewater treatment and disposal facility, were submitted to SHPD on July 31, 2018. SHPD
approved the AIS plan on August 20, 2018, and the County conducted the AIS of the 14.9-acre
WWTP in September 2018.
In addition to the AIS, the County is obligated to comply with the National Historic Preservation
Act (NHPA). On March 29, 2018, the County initiated consultation for this project in accordance
with Section 106 of the NHPA. Consultation letters were sent to various Native Hawaiian
Organizations, totaling 15 letters, inviting comments from organizations that may attach religious
or cultural significance to properties affected by the proposed actions. A letter dated February 20,
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2020 from the SHPD provides concurrence that no historic properties at the Proposed WWTP Site
shall be affected, under HRS 63-8 and Section 106.
In 2023, an Archeological Literature Review was conducted to determine the likelihood that
historic properties may be affected by the project and, based on the findings, consider cultural
resource management recommendations. The literature review concluded that surface pre-
contact sites are not expected within the project area given the known traditional land use in this
area and the impacts of continued agricultural and residential development. The modern
development of the macadamia nut orchard has likely also obliterated any plantation era sites
once present in that part of the project area. Historic surface features associated with the sugar
plantation and associated village may be present. Furthermore, there is potential for pre- or post-
Contact subsurface archeological features within the project area, which may or may not be
located within lava tubes. It should be noted that the literature review is intended to support the
projects historic and environmental review process; however, the report does not fulfill the
requirements of an archeological inventory survey investigation as set forth in federal and State
Hawai‘i historic preservation review requirements.
Impacts and Mitigation Measures:
All Proposed Alternatives:
Construction activities associated with the Proposed Action may potentially disturb
archaeological and cultural resources in the project area. An Archeological Inventory
Survey was conducted to assess potential impacts. Potential impacts may be avoided or
minimized further by performing subsurface testing to confirm the presence or absence
of resources on the wastewater treatment and disposal facility site. Archaeological
monitoring should also be implemented during IWS installation and maintenance.
If any archaeological sites or remains are encountered during construction, work shall
cease immediately, and SHPD shall be contacted to assess the significance of the find and
recommend appropriate mitigation measures, if necessary.
As part of previous Environmental Assessment efforts, a letter dated February 20, 2020
from the SHPD provides concurrence that no historic properties shall be affected, under
HRS 63-8 and Section 106. O n March 28, 2024, the designated non-federal representative
for consultations under Section 106 of the NHPA, on behalf of EPA and the County of
Hawaiʻi, provided a letter to the SHPD which included an updated description of the project
and acknowledged that the project area has remained consistent with previous
consultation efforts. The intent of this letter was to determine if Section 106 consultation
would need to be re-initiated due to the project updates. On April 4, 2024, SHPD provided
an email which concluded that the project would not need to undergo further Section 106
consultation as the project updates under Alternatives 1 and 2 would not change the
previous concurrence that no historic properties shall be affected and the agreement for
archeological monitoring for identification purposes.
It is advised that the County seek to consult with SHPD in regard to Alternatives 3 and 4
in accordance with HRS Chapter 6E requirements, and in relation to Section 106 of the
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National Historic Preservation Act (NHPA) – if triggered – and, to incorporate additional
impact avoidance and minimization measures if required for the construction of the IWS.
No-Action Alternative:
The No-Action Alternative does not involve any new construction or disturbance of land,
and therefore, it does not result in impacts on archaeological and cultural resources.
No specific mitigation measures related to archaeological and cultural resources are
required for this alternative.
These revised mitigation measures address the potential impact of archaeological and
cultural resources for all five alternatives, including the need for Archaeological Inventory
Surveys (AIS) and archaeological monitoring in Alternatives 3 and 4.
5.8 Air Quality and Odors
The project area falls within the purview of ambient air quality standards (AAQS) at both national
(NAAQS) and state levels, encompassing the criteria pollutants, including carbon monoxide,
nitrogen dioxide, sulfur dioxide, lead, ozone, and particulate matter (PM10 and PM2.5). It is
noteworthy that the State of Hawaii has standards that align with national standards in terms of
stringency. The Hawaii Department of Health (DOH) operates an extensive network of air quality
monitoring stations across the state, ensuring that criteria pollutant levels have consistently
remained below both federal and state AAQS thresholds throughout the state, including the
Pāhala area.
Existing air quality within the Pāhala area is primarily influenced by various sources of air
pollutants, encompassing vehicular emissions, industrial activities, natural processes, and
agricultural practices. Additionally, the region is subject to periodic air quality fluctuations
resulting from volcanic emissions originating from Kīlauea Volcano. The concentration of volcanic
smog, locally known as "vog," within the area hinges on several factors, including the volume of
sulfur dioxide (SO2) emissions from Kīlauea, wind patterns, and prevailing atmospheric conditions.
It is pertinent to note that volcanic emissions are categorized as natural events, and in certain
circumstances, exceedances of the 1-hour NAAQS attributable to volcanic emissions might be
excluded from considerations regarding air quality attainment.
The Pāhala area, characterized by its rural nature, does not feature major stationary sources of
air pollution. Furthermore, the relatively low volume of vehicular traffic along Māmalahoa Highway
and within the community itself serves to limit the contribution of mobile sources of emissions to
air quality concerns.
Impacts and Mitigation Measures:
Alternatives 1 and 2 - Package Plant:
During the construction phase of the wastewater collection system and treatment facility
associated with Alternative 1, short-term impacts on air quality may manifest as fugitive
dust emissions resulting from construction activities. These emissions would be effectively
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managed through the implementation of a comprehensive dust control plan. Measures
within this plan would encompass the application of water to active work areas, the use
of wind screens, vigilant maintenance of adjacent roads to prevent dust buildup, and the
covering of open-bodied trucks. It is plausible that exhaust emissions from mobile
construction equipment, in conjunction with traffic disruptions associated with
construction activities, could exert a minor influence on air quality during this phase.
As previously discussed, the PER recommended a granular activated carbon (GAC)
scrubber be used at the Pahala WWTP headworks. A GAC scrubber passes odorous air
through a bed of activated carbon, which absorbs the odorous constituents within the
pore spaces of the carbon.
Chemical oxidation or reduction of some compounds can also occur. As pore spaces
become occupied, efficiency degrades, and the carbon must be replaced or regenerated.
Carbon is most effective on higher molecular weight molecules such as the organic sulfur
compounds, which makes it the technology of choice. Package GAC scrubbers are
available for small headworks and vessels can be situated vertically, horizontally or radially
to optimize footprints and reduce structure elevation profiles. The County currently
operates GAC scrubbers at other facilities and purchases the GAC media in bulk, which
reduces costs.
Once construction has been completed, emissions will occur from the daily visits to the
WWTP by a plant operator who could be based at the Hilo WWTP or at the Kealakehe
WWTP in Kona. Also, emissions would occur from trucks used to haul the solids to the
County West Hawai‘i Sanitary Landfill at Puuanahulu, located north of Kailua Kona. These
trips are not expected to exceed federal or state ambient air quality standards for criteria
pollutants. The presence of an emergency standby diesel-powered generator, operated
periodically for testing and during power outages, is unlikely to have a significant adverse
impact on air quality.
Alternatives 3 and 4 - Individual Wastewater System Program:
Air quality impacts for Alternatives 3 and 4 primarily relate to the installation and
maintenance of the IWS by homeowners. These activities may yield minor emissions
associated with construction equipment and vehicles. However, any potential air quality
impacts would be transient and localized to specific residential areas. Additionally, there
is a slight ri sk of odors emanating from maintenance activities or system breakages within
the IWS. Homeowners would be responsible for managing and mitigating these potential
odors.
No-Action Alternative:
The No-Action Alternative entails no modifications to the existing LCC system and,
therefore, is not projected to introduce new air quality impacts to the Pāhala area.
Historical air quality records indicate that the area has consistently met ambient standards
during the operation of the existing LCCs.
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5.9 Noise
The existing noise environment in the Pāhala area is primarily characterized by the natural sounds
of the rural surroundings, which include ambient sounds from vegetation, wildlife, and
intermittent vehicular traffic on Māmalahoa Highway and local streets. Noise levels in rural areas
like Pāhala are typically lower than in urban or industrial areas.
Impacts and Mitigation Measures
Alternatives 1 and 2 - Package Plant:
During the construction of the wastewater treatment facilities and collection systems, it is
anticipated that there will be an increase in noise levels associated with the operation of
heavy machinery, construction equipment, and from potential increased vehicle traffic.
These construction activities can generate temporary noise impacts in the project area.
To minimize construction-related noise impacts, the project can implement standard noise
control measures such as scheduling construction activities during daytime hours, avoiding
noisy activities during quiet hours (e.g., evenings and weekends), and employing noise
barriers or sound-reducing equipment where feasible.
While construction may introduce short-term noise, the continuous operational noise from
these facilities is generally localized and can be controlled with noise-reducing measures.
Transportation noise may be minimal as wastewater can be treated onsite.
The operational phase of the wastewater treatment facilities may introduce continuous
noise sources, such as equipment operation, pumps, and mechanical systems. While these
noise sources are generally not excessively loud, they can contribute to ambient noise
levels in the immediate vicinity of the facilities.
To address operational noise, the project can consider noise-reducing designs for the
treatment facilities, such as noise barriers or acoustic enclosures for noisy equipment.
Additionally, maintenance schedules can be optimized to minimize noisy activities during
sensitive times.
Vehicle traffic associated with travel to the Pāhala WWTP by plant operators and with
trucks needed to remove solids, based on the location of package plant would not affect
noise in the residential areas.
Alternatives 3 and 4 - Individual Wastewater System Program:
During construction of the IWS, it is anticipated that there will be an increase in noise
levels associated with the operation of heavy machinery, construction equipment, and due
to vehicle traffic. These construction activities can generate temporary noise impacts in
the project area.
To minimize construction-related noise impacts, the project can implement standard noise
control measures such as scheduling construction activities during daytime hours, avoiding
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noisy activities during quiet hours (e.g., evenings and weekends), and employing noise
barriers or sound-reducing equipment where feasible.
The installation and maintenance of the IWS may result in localized noise during
construction and maintenance activities. However, these impacts are distributed across
multiple resident properties.
No-Action Alternative:
This alternative maintains the existing LCC system. While it avoids construction-related
noise, it may not address long-term noise concerns associated with the aging
infrastructure.
5.10 Energy and Natural Resources
The Pāhala area relies on a mix of energy sources for electricity, including fossil fuels (e.g., oil)
and renewable sources (e.g., solar and wind). The specific energy mix can vary over time and
may be influenced by state and county policies promoting renewable energy.
Although the integration of renewable energy sources to reduce reliance on fossil fuels and
promote sustainability can be considered, WWTP facilities typically rely on a consistent source
power. Also, the package plant site plan has been designed to minimize the affected land area.
Renewable energy sources would require a greater land area which would mean removal of
additional macadamia nut trees.
Impacts and Mitigation Measures
All Proposed Alternatives:
The construction and operation of wastewater treatment facilities will require energy
inputs. Construction equipment, pumps, aeration systems, and other mechanical
components consume energy during installation and operation.
Implementing energy-efficient technologies and practices during facility construction and
operation can help reduce energy consumption.
Additionally, the feasibility of incorporating renewable energy systems into the wastewater
treatment facilities to reduce carbon emissions and energy costs should be evaluated.
No-Action Alternative:
This alternative maintains the existing LCC system which may not address long-term
energy consumption associated with the aging infrastructure.
5.11 Land Use and Land Use Plans
The existing land use in the project area includes residential, agricultural, and undeveloped land.
Agricultural activities, such as macadamia nut farming, are important for the local economy. The
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Project Area is located within the Urban and Agricultural State Land Use Districts. As such, the
Proposed Action would be required to comply with the regulations set forth in the State Land Use
Law (HRS, Chapter 205).
Furthermore, the County of Hawai‘i General Plan calls for the preparation of community
development plans (CDPs) “to translate the broad General Plan statement to specific actions as
they apply to specific geographical areas.”
The Kaʻū CDP is one of nine CDPs for Hawai‘i County. On October 17, 2017, the Ka‘ū CDP was
adopted as Ordinance No. 2017-66. The purpose of CDPs is to implement the broad goals within
the General Plan on a regional basis and to translate the broad General Plan statements into
specific actions. CDPs are the forum for community input into managing growth and coordinating
the delivery of government services to the community. CDPs designate detailed development
patterns and direct physical development and public improvements by detailing land use policies
and infrastructure priorities.
Section 5 of the CDP prioritizes improvements in infrastructure, facilities, and services, including
Section 5.8 applicable to Environmental Management which states:
“Environmental management facilities, including expanded sewer lines, the Ocean View
transfer station, green waste facilities, and improvements in the Pāhala transfer station
Policy 120 Extend the primary wastewater collection lines in Pāhala and Nāʻālehu so that
infill development projects can connect wastewater systems built for new subdivisions to
the County systems.”
The collection system will be consistent with Policy 120 as the improvements for the Pāhala LCC
Replacement Project have been designed not to preclude expansion to accommodate the Pāhala
community. Similarly, the wastewater treatment and disposal facility has been designed not to
preclude expansion to accommodate the future needs of the Pāhala community. Future
subdivisions would be accommodated, as capacity allows, on a first-come, first-served basis.
Impacts and Mitigation Measures
Alternative 1 – Package Plant:
Construction activities will result in land disturbance, affecting natural habitats and
agricultural areas. Minimizing the affected area will act to footprint of construction
activities and implementing erosion control measures can help mitigate land disturbance
impacts. These centralized facilities may require significant energy inputs for treatment
and transportation of wastewater. However, they offer opportunities for energy efficiency
improvements and the integration of renewable energy sources.
The collection system has been designed allow flows from additional residential areas to
the north and east to reach the treatment and disposal facilities. The package plant site
plant has been designed to allow additional treatment capacity. Thus, Alternative 1 would
be consistent with the Ka‘ū CDP.
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Alternative 2
Although the package plant in Alternative 2 would allow additional facilities, u se of existing
collection system would not allow flows from the residential areas to the north and east
to connect to the package plant and treatment disposal system.
Alternatives 3 and 4 – Individual Wastewater System Program:
Construction activities can result in land disturbance, affecting natural habitats and will
affect the residential parcels, including affecting existing buildings, structures and
landscaping. Minimizing the footprint of construction activities and implementing erosion
control measures can help mitigate land disturbance impacts.
These alternatives are designed to use gravity flows which will mean lower energy
demands compared to centralized facilities.
No-Action Alternative:
The existing LCC system will not require energy consumption. No significant changes in
energy use are anticipated with this alternative.
5.12 Roadways and Traffic
The existing roadway and traffic conditions in the Pāhala area provide essential context for
assessing the impacts and mitigation measures associated with the proposed wastewater
treatment project. Key considerations include:
Road Network: Pāhala is served by a network of roadways which are under the jurisdiction of the
County and include Māmalahoa Highway, a state facility. The local streets provide access to
residences, businesses, and community facilities.
Traffic Volume: The traffic volume on Māmalahoa Highway and local roads in Pāhala is generally
low, reflecting the rural nature of the area. Limited vehicular traffic contributes to low levels of
congestion and a relatively peaceful road environment.
Access to Project Sites: The proposed project sites, including the preferred location for the
wastewater treatment and disposal facility, are accessible via the existing road network.
Consideration of the impact of construction and operational traffic on local roads is necessary.
Safety: Road safety is a critical concern in the area. Ensuring the safety of residents, commuters,
and workers during construction and operation is a primary focus. Safety measures may include
signage, flaggers, and traffic control measures as needed.
Impacts and Mitigation Measures:
Alternatives 1 and 2 – Package Plant:
During the construction phase of the wastewater treatment project, temporary disruptions
to traffic flow on local roads may occur. Mitigation measures include the development of
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traffic management plans to minimize construction-related traffic impacts. These plans
may include designated construction access points, scheduling work during off-peak
hours, and flaggers to ensure safe traffic flow.
The influx of construction vehicles, equipment, and workers to the project sites may result
in increased traffic volume on local roads. To mitigate this, construction logistics planning
should aim to minimize the impact on existing road users and ensure the safety of all road
users.
Safety measures, such as signage, temporary speed limits, and traffic control personnel,
will be employed as necessary during construction activities to maintain the safety of both
workers and the local community.
As part of the project, any necessary upgrades or improvements to local roads or
intersections impacted by construction activities will be considered and implemented. This
may include road repairs, resurfacing, or other enhancements to ensure the continued
integrity of roadways.
During the operation of the wastewater treatment facility, regular visits by facility
operators are expected. While these visits would introduce minimal traffic, safety remains
a priority, and any potential traffic impacts will be mitigated through adherence to
established safety protocols.
Continuous monitoring of traffic conditions and adherence to traffic management plans
will be essential to address any unforeseen issues promptly. Compliance with local traffic
regulations and safety standards will be enforced throughout the project's lifecycle.
In summary, the existing road network in Pāhala serves as the backdrop for assessing
potential impacts and mitigation measures associated with the proposed wastewater
treatment project. During both the construction and operation phases, careful planning,
safety measures, and infrastructure improvements will be implemented to minimize
disruptions and maintain the safety and functionality of local roadways.
Additionally, the new collection system or methods of integration with the existing
collection system may require careful planning and engineering to ensure compatibility
and minimize impacts on the existing infrastructure.
Alternatives 3 and 4 - Individual Wastewater System Program:
Unlike the centralized package plant options, this alternative involves the installation and
maintenance of the IWS at each residence within the service area. Logistically, this can
be challenging due to the need for coordination with numerous property owners.
Obtaining access to private properties and ensuring compliance with installation and
maintenance requirements for IWS may pose logistical hurdles. Coordinating schedules
and ensuring proper installation and maintenance become complex tasks; however, it
should be noted that septage trucks would only need to visit each property every three to
five years to pump the septic tanks.
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The ongoing operation and management of multiple individual systems can be logistically
complex. Ensuring that all systems meet required standards and addressing any issues
promptly is a continuous endeavor.
No-Action Alternative:
Maintenance of Existing Infrastructure: Under the No-Action Alternative, there would be
no changes to the existing infrastructure. While this avoids the logistical challenges of new
construction, it doesn't address potential issues with the aging LCC system.
Long-Term Considerations: Continuing with the existing system may provide short-term
stability, but it may not be a sustainable long-term solution for wastewater treatment in
the area.
5.13 Hazardous Materials
The existing conditions in Pāhala regarding hazardous materials primarily pertain to the operation
of the Pāhala LCCs, which historically managed wastewater treatment for the community. No
chemicals are currently being used for treatment at the Pāhala LCCs, however, wastewater
treatment processes generate residual waste, including sludge and biosolids. Proper management
and disposal of these materials are essential to prevent environmental contamination.
Impacts and Mitigation Measures:
All Proposed Alternatives
The impacts and mitigation measures related to hazardous materials are primarily
associated with the closure of the Pāhala LCCs and the transition to alternative wastewater
treatment methods:
• As the LCCs cease operation, residual waste, such as sludge and biosolids, must
be managed appropriately. Mitigation involves planning for the safe removal and
disposal of these materials to prevent adverse environmental impacts.
• Depending on the condition of the LCC sites, remediation efforts may be required
to address any soil or groundwater contamination resulting from historical
operations. Remediation plans and measures will ensure that the sites are restored
to acceptable environmental standards.
• For proposed alternative wastewater treatment methods, any hazardous materials
or chemicals used in the new treatment processes would be subject to stringent
safety protocols, handling procedures, and storage requirements. Mitigation
measures include compliance with safety regulations and ongoing staff training.
Continuous monitoring of the environment by the homeowners, including soil and water
quality, will be essential to detect any potential impacts related to hazardous materials.
Mitigation measures involve the implementation of robust monitoring programs to
promptly address any issues that may arise.
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The closure of the Pāhala LCCs and the transition to alternative wastewater treatment
methods in Pāhala require careful management of hazardous materials and chemicals to
prevent adverse environmental impacts. Proper disposal, remediation, and adherence to
safety protocols are crucial mitigation measures to ensure the safe and responsible
handling of hazardous materials throughout the project's lifecycle.
No-Action Alternative:
The No-Action Alternative does not involve any new construction or modification of the
existing sewage system; however, this would not allow the County to meet the
requirements of the AOC and SDWA.
5.14 Socioeconomics & Environmental Justice
In December 2022, the State of Hawaiʻi Department of Business, Economic Development and
Tourism released 2021 population estimates for the state and counties. This analysis estimates
that Hawaiʻi County had a resident population of 200,648 persons in 2021, which represents an
annual increase of 1.01 percent from the 2016 population.
The U.S. Census Bureau provides the American Community Survey (ACS) for Census Designated
Places, which updates selected demographic, social, and economic information for various years.
The ACS shows age distribution, racial composition, and economic information, including
employment and household income by Census Designated Place for various locations in Hawaiʻi
County. The version of the ACS referenced is the 2021 5-Year Estimates, released in December
2022. See Table 5.1 below.
The ACS shows the Pāhala population has a much younger age distribution compared to Hawai‘i
County, especially in the proportion of individuals in the “Under 5 to 19” age category, 33.0
percent compared to 23.6 percent for the County. This proportion applies to all age groups,
except for the 35 to 59 and the 60 to 74 age groups. The median age for Pāhala is 27.0 years
compared to 43.0 years for the County.
Overall, Pāhala is characterized by a racial composition that includes a greater proportion of
minorities compared to the County. The Pāhala racial distribution includes a much lower
proportion of White residents, a much higher proportion of Filipino residents, and lower
populations of other minority groups, including Native Hawaiians when compared to the County.
There are also more residents of two or more races in Pāhala than in the County.
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Table 5.1
Demographic, Economic and Social Characteristics of Pāhala and Hawai‘i County
Item
Pāhala Hawai‘i County
Total Percent Total Percent
Demographic Characteristics
Total Population 2,210 200,468
Under 5 to 19 years 730 33.0 47,349 23.6
20 to 34 years 602 27.2 33,056 16.5
35 to 59 years 493 22.3 61,169 30.5
60 to 74 years 285 12.9 43,854 21.9
75 years and older 100 4.5 15,040 7.9
Median age 27 43
Race
White 388 17.6 65,306 32.6
African American (inc. American Indian/Alaska Native) 0 0.0 2,608 1.3
Chinese 0 0.0 2,911 1.5
Filipino 555 25.1 19,111 9.5
Japanese 46 2.1 16,179 8.1
Korean 0 0.0 888 0.4
Other Asian 60 2.7 5,172 2.6
Native Hawaiian 65 2.9 18,333 9.1
Other Pacific Islander 33 1.5 5,765 2.9
Some other race 0 0.0 4,586 2.3
2 or more races 1,063 48.1 59,754 29.8
Social/Educational Characteristics
Less than 9th grade 78 6.2 3,289 2.3
High School to High School Graduate 526 42.1 49,116 34.3
Some college to associate degrees 386 30.9 47,704 33.3
Bachelor degree 227 18.2 27,845 19.4
Graduate/professional degree 32 2.6 15,395 10.7
Household Income Characteristics
Less than $24,999 129 25.0 13,462 18.9
$25,000 to $49,999 106 20.5 13,039 18.3
$50,000 to $99,999 156 30.2 21,696 30.4
$100,000 to $199,999 91 17.6 17,775 24.9
$200,000 or more 35 6.8 5,430 7.6
Median household income $54,293 $68,399
Employment Characteristics
Agriculture, forestry, fishing and mining 268 32.4 4,357 4.9
Construction 14 1.7 7,051 7.9
Manufacturing and wholesale trade 188 22.7 3,920 4.4
Retail trade 37 4.5 10,881 12.2
Transportation, warehousing, and utilities 19 2.3 3,679 4.1
Information tech, finance, insurance and real estate 31 3.7 6,140 6.9
Professional, scientific and technical services 41 5.0 10,366 11.6
Education and health care 117 14.1 19,354 21.7
Arts, entertainment and recreation 100 12.1 14,078 15.8
Other services, public administration 12 1.5 9,493 10.6
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Pāhala has a higher proportion of residents that have completed high school and some college
than the County overall, but a slightly lower proportion with college degrees (bachelor’s and
graduate or professional degrees). From an economic perspective, Pāhala generally has more
households in lower income brackets than the County, and a lower median household income.
Lastly, Pāhala had a higher proportion of employment in agriculture, forestry, fishing, hunting,
and construction (32.4 percent), and in manufacturing and wholesale trade (22.7 percent)
compared to the County 4.9 percent and 4.4 percent respectively. Pāhala had a lower proportion
in education and health care (14.1 percent), compared to the County (21.7 percent).
A subset of social resources is environmental justice. Environmental justice considers sensitive
populations, such as children, minorities, and low-income communities. Sensitive populations are
identified in two Executive Orders (EOs):
• EO 12898, Federal Actions to Address Environmental Justice in Minority and Low-Income
Populations, serves to avoid the disproportionate placement of adverse environmental,
economic, social, or health impacts from federal actions and policies on minority and
low-income populations.
• EO 13045, Protection of Children from Environmental Health Risks and Safety Risks,
states that federal agencies will identify and address environmental health and safety
risks from their activities, policies, or programs that may disproportionately affect
children.
As noted above and in Table 4.1, Pāhala has a higher proportion of low-income, minority, and
children residents as compared to the County as a whole. For purposes of this assessment, and
to correspond with the available ACS demographic characteristic data, “low income” is defined as
having a household income of less than $24,999; “minority” is defined as any race population
other than White; and “children” is defined as the “Under 5 to 19” age category.
Impacts and Mitigation Measures:
Alternatives 1 and 2 - Package Plant:
In the short term, construction projects would require a number of contractors and their
subcontractors. Construction contract documents would reference HRS 103B, which
requires the contractor (including subcontractors) to include not less than 80 percent
Hawai‘i residents in the work force. This would limit the importation of workers from
outside the local area and the associated increase in demand for local housing.
The Alternative 1 would generate employment as the contractor would need workers to
undertake construction of the improvements for the wastewater collection system and the
WWTP and effluent disposal facility. This employment would generate wages and salaries
paid to the contractor and subcontractor work forces. The wages and salaries paid to the
work force would in turn generate purchases of goods and services, which would result in
taxes paid to the State of Hawai‘i. In addition, the contractor and their subcontractors
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would need to purchase equipment, supplies, and materials, some of which would be
purchased from local suppliers and vendors. Direct purchases of equipment, supplies, and
materials by the contractor would also generate taxes. Overall, Alternative 1 would result
in positive employment benefits which would result in higher levels of income and overall
economic benefits to the local economy.
The Alternative 1 is not likely to directly impact long -term employment or education trends
since the wastewater plant operator would likely be based in Hilo or Kona, meaning the
project would not involve long-term relocation of any staff to Pāhala. Additionally,
Alternative 1 wastewater collection system and treatment and disposal facility would not
be designed to encourage or accommodate substantial population growth in Pāhala.
Alternatives 3 and 4 - Individual Wastewater System Program:
Construction of the IWS would also create the need for workers construct the septic
system including the absorption bed or seepage pits. Since the IWS would not involve the
complex treatment processes, the level of employment could be lower than Alternative 1
or 2. However, to construct over 100 IWS would require multiple crews or contactors.
Overall, the economic impact may be similar to Alternatives 1 and 2.
No-Action Alternative:
The No-Action Alternative does not involve any new construction or modification of the
existing sewage system, and therefore, it is not expected to impact socioeconomic or
demographic conditions in the Pāhala area.
No specific mitigation measures related to socioeconomic characteristics are required for
this alternative.
These adapted impacts and mitigation measures address the potential socioeconomic
impacts for all five alternatives, emphasizing employment and economic benefits while
considering sensitive populations. Please let me know if you need further adjustments or
information.
All Proposed Alternatives:
Despite the relatively high proportions of low-income, minority, and children residents in
Pāhala compared to the County overall, the proposed alternatives would not result in
disproportionately high and adverse human health or environmental effects on the
minority or low income populations. The design and location of the proposed wastewater
treatment and disposal facility would minimize odor and air quality impacts. Construction
of the wastewater collection system would result in intermittent and unavoidable noise
from construction vehicles and equipment within the Pāhala community, including noise
associated with the removal of bedrock. However, as discussed in Section 3.18.2,
construction activities within the community would comply with provisions of HAR 11-46
(Community Noise Control). This includes obtaining a noise permit for any activities that
would generate noise exceeding the permissible sound levels specified in HAR 11-46. The
permit would limit excessive noise sources to daytime hours; would require the use of
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best available control technology to control noise levels from excessive noise sources; and
would require the applicant to notify affected members of the public in advance of any
planned nighttime construction activity (which must not exceed the permissible sound
levels). Overall, the proposed alternatives are expected to result in positive human health
and environmental effects to Pāhala residents by providing a cleaner and longer-lasting
wastewater treatment system.
Concerns regarding the financial impact of the project on individual newly accessible
property owners (due to the requirement to connect to the new wastewater collection
system, per HCC § 21-5) were raised by the community during the December 2017 public
meetings and also echoed at the the October 2018 public meeting for the previous Draft
EA. Although not required by HAR 11-200, the County voluntarily convened an additional
public meeting on March 21, 2019 to gain further input from newly accessible property
owners and fulfill a County commitment made in October 2018 to research and provide
financing options available to owners of parcels that would become newly accessible to
the County collection system. Available programs discussed included:
• U.S. Department of Housing and Urban Development (HUD) with County of
Hawaiʻi Office of Housing and Community Development Residential Repair
Program – Community Block Grant Program, and
• U.S. Department of Agriculture – Rural Development (USDA-RD) Program.
As noted during the March 2019 presentation, these programs may change in the coming
years and additional options may be added to this preliminary list. Hawaiʻi Legislature,
Senate Bill 221 SD1, which could amend HRS 342D to establish a low-interest loan
program offering financial assistance to cesspool owners to connect to wastewater
treatment systems approved by the DOH, was also discussed; however, this bill was
subsequently not passed during the 2019 legislative session.
Abandonment of the two LCCs, and abandonment of the existing wastewater collection
system would have no impact on socioeconomic resources within Pāhala.
5.15 Sustainability
The concept of sustainability is vital in understanding the environmental, economic, and social
conditions in Pāhala and its surrounding areas. Sustainability encompasses the balance between
meeting the needs of the present without compromising the ability of future generations to meet
their own needs. In the context of Pāhala, several factors influence the existing conditions related
to sustainability:
Pāhala's environmental sustainability is influenced by its unique natural surroundings, including
its proximity to the Kīlauea Volcano and the potential impact of volcanic activity on air and water
quality. The region's lush vegetation and agricultural activities contribute to its environmental
diversity.
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The local economy in Pāhala is characterized by agriculture, including macadamia nut farming,
which has been a significant contributor to the region's economic sustainability. Additionally,
employment opportunities in education and healthcare play a role in the local economy.
Pāhala's community is diverse, with residents from various racial backgrounds, including a
significant Filipino population. The region's social sustainability is influenced by factors such as
education levels, access to healthcare services, and community engagement.
Impacts and Mitigation Measures:
Alternatives 1 and 2 - Package Plant:
The construction of a new wastewater collection system and treatment facility may have
short-term environmental impacts, such as soil disturbance and potential disruption of
local ecosystems. Mitigation measures include adherence to environmental regulations
and best construction practices to minimize ecological disturbances.
The construction phase is expected to generate employment opportunities, contributing
positively to economic sustainability in the short term. Long-term economic impacts
include the potential for increased economic activity due to improved wastewater
infrastructure.
Minimal direct social impacts are expected during construction. The long-term social
benefits include improved access to wastewater services, contributing to the overall
quality of life and social sustainability.
Alternative 3: Individual Wastewater System-Maintenance Contract Model
The installation and maintenance of the IWS may have minimal environmental impacts,
mainly related to construction activities. Mitigation measures involve adherence to
environmental regulations during installation.
This alternative provides opportunities for local residents to participate in the installation
and maintenance of IWS, potentially benefiting economic sustainability at the community
level.
The social impacts are localized, involving homeowners and their immediate surroundings.
The long-term social benefit includes improved wastewater systems for individual
households, enhancing overall social sustainability.
Alternative 4 - Individual Wastewater System-Operating Permit to Homeowners:
Similar to Alternative 3, this alternative's environmental impacts are mainly related to the
installation and operation of the IWS. Mitigation measures include compliance with
environmental regulations.
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The economic impacts are similar to Alternative 3, with opportunities for local participation
in IWS installation and maintenance, supporting economic sustainability at the community
level.
The social impacts are localized, involving homeowners and their immediate communities.
The long-term social benefit includes improved wastewater systems for individual
households, enhancing social sustainability.
No-Action Alternative:
This alternative maintains the existing conditions, resulting in minimal changes to the
environment.
The economic impacts of the No-Action Alternative are limited, as it does not involve new
construction or economic development related to wastewater infrastructure.
This alternative does not introduce significant social changes, as it maintains the status
quo in terms of wastewater services and community conditions.
Overall, each alternative has varying short-term and long-term impacts on environmental,
economic, and social sustainability in Pāhala. Mitigation measures and adherence to
regulations are essential to minimize adverse effects and enhance the region's overall
sustainability.
5.16 Human Health And Safety
In Pāhala, as in any community, access to adequate wastewater treatment services is a
fundamental necessity for maintaining public health and environmental quality. Existing
conditions reveal the following:
• Proper wastewater treatment is vital for safeguarding public health. Inadequate treatment
can result in the contamination of groundwater and surface water, posing risks to drinking
water sources and recreational areas. It can also lead to the spread of waterborne
diseases.
• Effective wastewater treatment is essential for preserving the local environment.
Uncontrolled discharge of untreated sewage can harm aquatic ecosystems, damage coral
reefs, and degrade coastal waters, impacting the region's biodiversity and natural beauty.
• Reliable wastewater treatment infrastructure contributes to the overall well-being of the
community. It ensures that residents can enjoy a safe and healthy environment and
minimizes nuisances such as foul odors and unsightly conditions associated with
inadequate treatment.
The Closure of the LCCs and Improved Services
The closure of the LCCs and the proposed wastewater treatment alternatives aim to address
existing challenges and improve wastewater treatment services in Pāhala:
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• The closure of the LCCs signifies a shift towards more modern and effective wastewater
treatment methods. The proposed alternatives include advanced treatment processes that
can remove a higher percentage of contaminants from wastewater, resulting in cleaner
effluent.
• Improved wastewater treatment aligns with the community's commitment to
environmental stewardship. By ensuring that treated effluent meets stringent quality
standards, the closure of the LCCs supports the conservation of local ecosystems and
marine life.
• The closure of the LCCs and the adoption of alternative wastewater treatment methods
provide significant public health benefits. Treated wastewater reduces the risk of
waterborne diseases and protects the health of residents and visitors.
• Adequate wastewater treatment services contribute to community satisfaction and quality
of life. Residents can enjoy a cleaner and healthier environment, which, in turn, can have
positive social and economic impacts on the community.
The closure of the LCCs represents a critical step toward enhancing wastewater treatment
services in Pāhala. It reflects the community's commitment to protecting public health,
conserving the environment, and improving overall community well-being. The proposed
alternatives offer modern and effective solutions to ensure that wastewater is treated to the
highest standards, addressing the pressing need for adequate wastewater treatment in the
area.
Impacts and Mitigation Measures:
All Proposed Alternatives
The Pāhala LCC Closure project would not result in construction of new above-ground
infrastructure within the 500-year floodplain. Although a small portion of the proposed
collection system is located within the 500-year floodplain, the associated trenching
operations would be temporary and would not alter the 500-year floodplain. Thus, no
impacts to the existing floodplain are expected from the Proposed Action. For
information related to stormwater management and impacts, please refer to Section
3.23.
Abandonment of the two LCCs and the existing wastewater collection system would not
affect floodplains within the affected areas.
No-Action Alternative
The No-Action Alternative, specifically the continued operation of LCC 1, could lead to
impacts during a flooding event. LCC 1 is located very close to an area mapped as within
the 0.2-percent annual chance (500-year) floodplain. The existing collection system is
substandard and in poor condition. A large flood could potentially cause the collection
system and/or LCC to overflow as a result of stormwater inflow and result in an
uncontrolled release of raw sewage, thus potentially contaminating flooded areas and
creating a public health hazard.
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5.17 Unresolved Issues
This EID serves to assess the anticipated environmental impacts of each alternative on various
environmental resources; however, there are still several unresolved issues that may affect the
completion of the project under any of the Proposed Alternatives.
Construction Feasibility
Many of the lots in Pahala may be too small to construct individual septic systems, and for those
that could accommodate a septic tank, the soils may have percolation rates that are too slow to
allow for seepage pits based on HAR 11-62-34 regulations. Residents with insufficient space for
a seepage pit may need to import fill soil to create elevated mound systems or convert to
household aerobic treatment units.
Additionally, as discussed throughout the EID, the IWS recommended by the PER also requires
the installation of a septic tank with an absorption bed. The PER further outlines that this
absorption shall not be installed on lands with a slope gradient of greater than 8 percent. In light
of this, some lots may be better served by an IWS featuring a seepage pit which may only be
permitted when it can be demonstrated that an alternative means of disposal was not possible.
Access to Properties
Under Alternative 3, the County will fund, design, and manage project. Obtaining Right of Entry
(ROE) to private properties for various purposes, such as infrastructure development or land
surveys, can present several challenging issues. The process often involves negotiation, legal
considerations, and respect for property rights. Failing to clarify these issues can lead to legal
disputes and project delays. The most straightforward way to gain ROE is through the voluntary
consent and permission of property owners. However, some property owners may be unwilling
to grant access due to concerns about privacy, property damage, or other reasons.
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6. Selection of a Preferred Alternative
The proposed Amended AOC (Docket No. SDWA-UIC-AOC-2017-0002, proposed February 14,
2024) LCC requirements for Pāhala outlines that an EID must be prepared by the County for US
EPA approval to meet Federal Environmental Review Requirements. The Amended AOC requires
evaluation of four feasible alternatives, evaluation of a No Action alternative, and the tentative
selection of a preferred alternative. In the process of identifying a preferred alternative,
extensive community engagement has taken place, including numerous meetings and
discussions with the EPA. Preliminary Engineering Reports have also been completed to assess
the identified alternatives as discussed in Section 2 of this EID.
The PER initially recommended an IWS alternatives for cost-effectiveness as the alternatives
involving a package plant were found to have overall higher capital costs. However, the EPA
raised concerns with this recommendation, leading to additional public engagement.
Considering factors such as regulatory compliance, community preference, and perceived
environmental impacts, the Department of Environmental Management - Wastewater Division
(DEM - WWD) has tentatively selected Alternative 1 as the preferred alternative. It should be
noted that this selection is subject to change based on public comment.
6.1 Recommendation Factors
6.1.1 Regulatory Compliance
In the development of the PERs, public objections or legal ramifications were not considered in
the recommendation of the IWS alternative. This includes barriers to property access for
construction, existing and/or new agreements, compliance with current County and State codes,
and/or establishing new codes and bill ordinance.
Obtaining Right of Entry (ROE) to private properties for various purposes, such as infrastructure
development or land surveys, can present several challenging issues. The process often involves
negotiation, legal considerations, and respect for property rights. Failing to clarify these issues
can lead to legal disputes and project delays. The most straightforward way to gain ROE is
through the voluntary consent and permission of property owners. However, some property
owners may be unwilling to grant access due to concerns about privacy, property damage, or
other reasons. With Alternative 1 being the favorable option (based on received community
survey), it is likely less resistance from the community will be expected for granting of ROE.
In addition, there is an existing agreement between the County and C. Brewer established on
April 12, 2007, in which the County agreed to construct and maintain new improved community
sewer systems, including new County treatment and disposal systems and elimination of large
capacity cesspools. Following this agreement, the County Council has already approved, and
resolutions (Resolution 72-05 and 290-06) have been obtained for pursuance of WWTP and
new collection system per agreement.
Further, implementation of the IWS alternatives would require significant modifications to the
County code. Current HRS and DOH administrative rules may not support the required
modifications. As such, modification of multiple HRSs and HARs would likely be required,
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including County Council approval and obtaining of new resolutions which could have severe
ramifications for the current project timeline.
6.1.2 Community Factors
Prior to the Amended AOC, extensive amount of community outreach was conducted back from
2017 and earlier. During these previous community outreach correspondences, WWTP and the
new collections system was the alternative that was being pursued and explained to the
community.
Since the AOC has been initiated, the County has held multiple community meetings with the
intention of gathering input and survey responses regarding the community’s preferences
regarding the LCC closures. Survey responses have indicated a strong community preference
for the package plant option. Based on a 40% on survey response rate from homeowners, 92%
have expressed their favor of the package plant with new collection system.
In addition to the recent survey responses, it has been noted that previous efforts led by the
County have promised to design and construct the Pāhala WWTP and collection system.
Short-term Construction activities are expected to create disturbances for the community for
either alternative option. IWS would require construction on every privately owned lot, which
will have extensive amount of land disturbance on the property, as compared to the WWTP
alternative which will be limited construction on private properties of existing accessible lots for
the connection of the existing dwelling to the new collection system. Although the WWTP
alternative will have extensive ROW work that may cause traffic congestion during construction,
the disturbed roadways will be newly paved at the end of the project, benefiting the
Community.
The conventional wastewater system of new collection system and WWTP alternative will be
better suited for the long-term goals and wastewater infrastructure and services within the
Community. In addition County personnel will responsible for maintaining the system from
within ROW roadways and on the WWTP facility parcel, and not being required to access onto
private properties for maintenance purposes, minimizing disturbances to homeowners.
6.1.3 Environmental Risks
Under HAR 11-62-31.1(a), an IWS may be used as a temporary on-site means of wastewater
disposal in lieu of wastewater treatment. IWS efficiency is dependent on having adequate land
area, properly size tanks, and having an adequately sized absorption bed, with proper soil for
percolation and further filtering of bacteria within effluent. Many lots within the Pahala
community are exempted from requiring lots to have 10,000 sf (HAR11-62-31-(c)), but small
lots (<10,000 sf) and/or overbuilt lots may not meet HAR setback and spacing requirements,
which would require DOH variance from setback/spacing requirements and/or usage of seepage
pits. Properties having IWS with multiple variances within proximity of each other, may
potentially have a cumulative impact on the environment.
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The Alternative 1 option will provide the higher level of treated wastewater effluent, as it is
intended to meet HAR 11-62 and DOH guidelines for re-use, which will meet the oxidization,
disinfection, and fecal coliform to State DOH requirements. The intended re-use effluent of
subsurface drip irrigation will minimize disturbance of existing mac-nut trees and contribute
towards conservation of the island resources. WWD personnel are also familiar with operating
and maintaining collection systems and Package WWTP, which WWD will be able to manage the
performance of WWTP and new collection system.
6.1.4 Cost
The PER provided estimated CIP and 30- year life cycle costs of for the different options, which
are summarized below:
o Option #1: $37.3 Million CIP cost / $19.7M O&M Cost / $57.0M Life cycle cost
o Option #2: $23.6 Million CIP Cost / $21.6M O&M Cost / $45.2M Life cycle cost
o Option #3: $17.4 Million CIP Cost / $9.4M O&M Cost / $26.8M Life cycle cost
o Option #4: $17.4 Million CIP Cost / $11.3M O&M Cost / $28.7M Life cycle cost
Option #1 does have a higher capital cost, but there is less risk of encountering unforeseen
features (structures, utilities, etc.) as much of the construction work will be within the roadway
ROW. The IWS options (options #3 & #4) are lower capital improvement cost, but the extents
of the permitted residential structures that will be disturbed and need to be reconstructed, is
unknown at this point, which would potentially increase the overall CIP cost of the project than
expected. Under Options #1, #2, #3 the County will have to establish monthly sewer fees to
help offset the cost of the O&M for the life of the system. Although option #4 may not have
associated monthly sewer fees, the homeowner will be responsible for maintaining, operating,
and repairing the IWS, along with having to report to the County services of records of IWS. In
addition to option #4 the County will need to continue monitoring of and regulate a IWS
program for these homeowners, which will be a financial burden on the County for the life of
the system, which there will be no associated sewer fees to recoup the cost of County
personnel time and efforts in managing this program. Although option #1 has the highest
capital cost, this option provides a conventional wastewater system that will suite the long-term
goals and treatment for wastewater management within the Community.
6.2 Action Items under the Preferred Alternative
Under the Preferred Alternative, the County of Hawaiʻi would perform the following actions:
1. Acquire, or otherwise obtain the right to develop and use, a portion of the Tax Map Key:
9-6-002:018, a 42.5-acre parcel currently owned by B. P. Bishop Estate Trustees
(commonly known as Kamehameha Schools), then construct a new secondary
wastewater treatment and disposal facility within a 14.9-acre portion of the parcel;
2. Construct a wastewater collection system, primarily within the public right-of-way (ROW)
and three segments within easements in the Pāhala community, to collect and convey
sanitary waste from the currently connected and accessible (in accordance with Hawai’i
County Code) properties to the new treatment and disposal facility;
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3. Close and abandon two LCCs, according to DOH closure procedures; and
4. Abandon the existing wastewater collection system in place.
The design consultant will be tasked with completing the WWTP design and implementation
plan within an estimated 6-7 months, followed by the wastewater collection system design
within the same timeframe. The project aims to adhere to an estimated 2-year construction
schedule.
In summary, Alternative 1, which involves the construction of a package plant with a new
collection system, has been selected based on regulatory compliance, community preference
and an assessment of environmental risks.
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7.Consultation
7.1 Early Consultation
The Early Consultation process included efforts to inform the community and solicit input in
scoping the EID for the Proposed Action. The Early Consultation/Pre-Assessment Package for
the Proposed Action was mailed out on October 5, 2023, to the following agencies,
organizations, and stakeholders listed below in preparation of the EID. Parties that formally
replied during the Early Consultation/Pre-Assessment process are indicated by a “” below. All
written comments are reproduced in Appendix C.
Federal Agencies
US Army Corps of Engineers, Honolulu District
US Department of Agriculture Natural Resources Conservation Service
US Fish and Wildlife Service
National Oceanic and Atmospheric Administration
US Department of Transportation Federal Aviation Administration
State Agencies
Department of Agriculture
Department of Accounting and General Services
Department of Business, Economic Development & Tourism (DBED&T)
DBED&T–Strategic Industries Energy Resources and Technology Division
DBED&T Land Use Commission
DBED&T Office of Planning and Sustainable Development
DBED&T State Energy Office
Department of Hawaiian Home Lands (DHHL)
DHHL – East Hawaiʻi District Office
Department of Health (DOH)
DOH – Clean Water Branch
DOH - Environmental Management Office
DOH – Hazard Evaluation and Emergency Response
DOH – Safe Drinking Water Branch
DOH – Wastewater Branch
Department of Land and Natural Resources (DLNR)
DLNR Division of Forestry and Wildlife
DLNR Engineering Division
DLNR Land Division
DLNR State Historic Preservation Division
Department of Transportation
Office of Hawaiian Affairs
University of Hawaiʻi
County of Hawaiʽi
Fire Department
Police Department
Planning Department
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Research and Development
Department of Public Works
Department of Parks and Recreation
Department of Water Supply
Elected Officials
State Senator Dru Mamo Kanuha, Senate District 3
Representative Jeanne Kapela, House District 5
Councilmember Michelle Galimba, Council District 6
Public Utilities
Hawaiian Electric Company
Hawaiian Telcom
Spectrum Hawaiʻi
Hawai'i Gas
Other Parties
Hawaiʽi State Library
Pahala Public Library
Hawaiian Civic Club of Ka'ū
Ka'ū CDP Action Committee
7.2 Community Outreach
The County has conducted numerous public information meeting during the course of designing
and documenting the Proposed Action. Beginning in 2017, a total of five community outreach
sessions were conducted in the Pahala community in regard to the Draft EA. A public
information meeting for the Draft EA was later held in October 2018.
A total of six community outreach sessions to discuss the Revised AOC were conducted in the
Pahala and Naalehu communities between March 2022 and December 2023. The sixth session,
held on December 14, 2023, was conducted specifically to inform the community of the
preparation of this Draft EID and the public comment period.
The County held its semi-annual community informational meeting in Pāhala on February 29,
2024 to give an update regarding the closures of the large capacity cesspools in Pāhala and
Nā‘ālehu. DEM discussed the County’s tentative identification of the preferred option of a
wastewater treatment plant for Pāhala with a new collection system and encouraged public
input. The next semi-annual community informational meeting will be held in August 2024 in
Nā‘ālehu.
In addition to the semi-annual community meetings, the County held a community meeting on
April 10, 2024 at the Pāhala Community Center to provide comments on the Amended Draft
EID. A collection of outreach materials published for this community meeting is provided in
Appendix D.
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7.3 Draft EID Public Review Period
No comments were received during the public and agency comment period for the subject EID.
The comment period began with the publication of the Draft EID at the Pāhala Public Library
and on the DEM website. The public comment period closed on December 22, 2023.
7.4 Amended EID Public Review Period
The Draft EID was amended to discuss the County’s tentative selection of a preferred
alternative as described in Section 6. A second public and agency comment period was opened
with the publication of the Amended EID at the Pāhala Public Library and on the DEM website.
The public comment period closed on April 15, 2024. No comments were received during the
second public and agency comment period for the subject EID.
101 Pāhala Large Capacity Cesspool Closure
Environmental Information Document
8.References
Atlas of Hawaiian Watersheds & Their Aquatic Resources, Island of Hawaii, Bishop Museum &
Division of Aquatic Resources. 1262 p. (3 volumes). Parham, J.E., G. R. Higashi, E. K. Lapp,
D.G. K. Kumolo, R. T. Nishimoto, S. Hau, J. M. Fitzsimons, D. A. Polhemus, and W. S.
Devick. 2008.
C. Brewer Company. Ka‘ū Sewer System Evaluation Report. December 2004.
County of Hawai‘i, Planning Department. County of Hawai‘i General Plan. Ordinance No. 05-025.
February 2005.
County of Hawai‘i, Planning Department. Ka‘ū Community Development Plan, Draft for Public
Review. March 2015.
County of Hawai‘i, Planning Department. 2017 Ka‘ū Community Development Plan, Ordinance
2017-66. October 2017.
County of Hawai‘i, Department of Environmental Management. Final Environmental
Assessment – Finding of No Significant Impact, the Nā‘ālehu-Pāhala Large Capacity
Cesspool Conversion. August 2007.
County of Hawai‘i, Department of Environmental Management. Pāhala Large Capacity
Cesspool Closure Project, Revised Preliminary Engineering Report. April 2023.
County of Hawai‘i, Department of Public Works. Final Environmental Assessment and – Finding
of No Significant Impact, Ka‘ū Gym and Shelter, Pāhala, Ka‘ū District. April 2012.
Executive Order No. 11990, 42 FR 26961, 3 CFR, p. 121, 1977, as amended by Executive Order
No. 12608, 52 FR 2923, 1987.
Executive Order No. 11988, 42 FR 26951, 3 CFR, p. 117, 1977, as amended by Executive Order
Nos. 12148, 44 FR 43239, 3 CFR, p. 412, 1979 and 13690, 81 FR 57401, 44 CFR 9, p.
57401, 2016.
Executive Order No. 12898, 59 FR 7629. 1994.
Hawai‘i County Code 1983 (2016 Edition, as amended). Chapter 21. Sewers.
Hawai‘i County Code 1983 (2016 Edition, as amended). Chapter 25. Zoning.
Hawai‘i Revised Statutes, Chapter 205, Land Use Commission. 2017.
National Oceanic and Atmospheric Administration (NOAA). 2002. Department of Commerce,
National Oceanic and Atmospheric Administration. 50 CFR 600. Magnuson-Stevens Act
Provisions; Essential Fish Habitat (EFH). Federal Register Volume 67, Number 12
(Thursday, January 17, 2002) 2343-2483.
102 Pāhala Large Capacity Cesspool Closure
Environmental Information Document
National Oceanic and Atmospheric Administration – National Marine Fisheries Service (NOAA-
NMFS). 2007. Magnuson-Stevens Fishery Conservation and Management Act, Public Law
94- 265, as amended by the Magnuson-Stevens Fishery Conservation and Management
Reauthorization Act (P.L. 109-479), an act to provide for the conservation and management
of the fisheries, and for other purposes. 16 U.S.C. § 1801-1884.
State of Hawai‘i. Department of Agriculture. U.S. Department of Agriculture, National Agriculture
Statistical Service 2017 Census of Agriculture – County Data 2017.
State of Hawai‘i. Department of Health. Annual Summary 2022 Air Quality Data. September
2023.
State of Hawai‘i. Department of Health. Noise Reference Manual – Big Island Edition. Revised
July 2017.
State of Hawai‘i. Hawai‘i Administrative Rules, Title 11 (Department of Health), Chapter 23
(Underground Injection Control). October 11, 2011.
State of Hawai‘i. Hawai‘i Administrative Rules, Title 11 (Department of Health), Chapter 46
(Community Noise Control). September 1996.
State of Hawai‘i. Hawai‘i Administrative Rules, Title 11 (Department of Health), Chapter 54
(Water Quality Standards). Revised November 15, 2014.
State of Hawai‘i. Hawai‘i Administrative Rules, Title 11 (Department of Health), Chapter 62
(Wastewater Systems). March 21, 2016.
University of Hawai‘i at Hilo, Department of Geography. 1998. Atlas of Hawaii. Third Edition.
U.S. Census Bureau, 2022 American Community Survey 5 year Census Designated Place,
Hawai'i County. U.S. Census Bureau’s American Community Survey Office, September
13, 2023.
U.S. Department of Agriculture Soil Conservation Service. Ka‘ū River Basin Study, County of
Hawai‘i. February 1994.
U.S. Environmental Protection Agency and County of Hawai‘i, Department of Environmental
Management. Final Environmental Assessment for the Pāhala Large Capacity Cesspool
(LCC) Replacement Project, EPA Grant XP-96942401. February 2020.
U.S. Environmental Protection Agency (EPA). Process Design Manual: Land Treatment of
Municipal Wastewater Effluents. EPA/625/R-06/016. Office of Research and
Development. Cincinnati, Ohio. September 2006.
U.S. Environmental Protection Agency (EPA). Climate Resilience Evaluation and Awareness
Tool (CREAT) Climate Scenarios Projection Map. Web. Accessed February 6, 2020.
U.S. Environmental Protection Agency. Environmental Information Document. Douglas
Wastewater Treatment Plant Upgrade and Bay Acres Colonia Wastewater Collection System
Expansion for the City of Douglas, Arizona. December 12, 2013.
103 Pāhala Large Capacity Cesspool Closure
Environmental Information Document
U.S. Environmental Protection Agency. Region IX. Revised Federal Administrative Order on
Consent EPA Docket No. SDWA-UIC-AOC-09-2017-0002, Pāhala and Nā‘ālehu Large
Capacity Cesspool Closure Projects Effective Date: August 22, 2022.
United States Environmental Protection Agency Region IX. Docket No. UIC-AO-2005-0014
County of Hawaii, Consent Agreement Department of Environmental Management, Hilo, Hi
Consent Agreement and Final Order
7 U.S.C. § 4201. 1981.
16 U.S.C. §§ 1271-1287. 1968.
16 U.S.C. §§ 1361 et seq. 1972.
16 U.S.C. §§ 1451-1464. 1972.
16 U.S.C. § 1531. 1973.
16 U.S.C. § 1801. 1976.
16 U.S.C. § 3501. 1982.
16 U.S.C. § 661. 1934.
16 U.S.C. § 668-668c. 1940. 16 U.S.C. § 703 et seq. 1918.
33 U.S.C. § 403. 1899.
33 U.S.C. § 1251 et seq. 1948.
42 U.S.C. § 300f. 1974.
42 U.S.C. § 7401 et seq. 1970.
54 U.S.C. § 300101. 1966.
54 U.S.C. § 312502. 1974.
Appendix A
Preliminary Engineering Report
Pahala Large Capacity
Cesspool Closure Project
Revised Preliminary
Engineering Report
Prepared for
County of Hawaii, Department of
Environmental Management
April 2023
2261 Aupuni Street, Suite 201
Wailuku, Maui, HI 96793
T: 808.244.7005
April 8, 2023
Ms. Brenda Iokepa-Moses
County of Hawaii Wastewater Division
108 Railroad Ave
Hilo, HI 96720 152964.704
Subject: Pahala Wastewater Treatment Plant Revised Preliminary Engineering Report
Dear Ms. Iokepa-Moses,
Brown and Caldwell (BC), in association with Engineering Partners, Inc. (EPI) is pleased
to present the attached Revised Preliminary Engineering Report (PER) for the Pahala
Large Capacity Cesspool (LCC) Closure Project. Preparation of a Revised PER is required
by the Revised Administrative Order on Consent (AOC) that became effective on August
22, 2022. The need for a Revised PER was precipitated by several items:
Geophysical and geotechnical investigations identified and confirmed a large
subsurface lava tube under the proposed aerated lagoons, prompting the need
for a wastewater treatment process with a smaller and shallower footprint.
Mechanical treatment technologies in the form of package plants offer the
opportunity to achieve these goals.
The community has not been receptive to the aerated lagoon technology that
was formerly proposed.
The Revised AOC no longer requires secondary treatment, opening up the
possibility of implementing individual wastewater systems (IWS) to close the
LCCs.
The Revised AOC requires evaluation of four feasible options:
i. A package plant and new collection system.
ii. A package plant connected to the existing collection system.
iii. A maintenance contract model IWS program.
iv. An operating permit model IWS program.
This Revised PER consists of three parts:
This introductory summary that provides comparisons of all four feasible options.
Part A, by BC, which presents updated analysis of feasible options i and ii that are
based on using a package plant-based wastewater treatment plant (WWTP) to service
the Pahala community and close the LCCs. BC is a nation-wide environmental
engineering firm with local Hawaii offices located in Kamuela, Wailuku, and Honolulu.
For over 75 years BC has been planning and designing WWTPs throughout the United
States.
Part B, by EPI, which presents a detailed analysis of feasible options iii and iv that are
based on using IWS to service the Pahala community and close the existing LCCs. EPI
is a multi-discipline engineering and design firm based in Hilo. EPI has successfully
designed IWS systems on Hawaii Island and is well-versed to address implementing
IWS in the unique local soil and subsurface geological conditions in Pahala.
Ms. Brenda Iokepa-Moses
County of Hawaii Wastewater Division
April 8, 2023
Page 2
Throughout this Revised PER the following terms are used:
“Feasible options” refers to the four specific options (i, ii, iii, iv) listed above and in
paragraph V.A.31.a of the Revised AOC.
“Alternatives” and “project alternatives” refer to various combinations of systems or
technologies that are evaluated within this Revised PER to determine preferences for
the feasible options.
1. Comparison of Feasible Options
The four feasible options are compared below,
1.1 Protection of Human Health and the Environment
Table 1 compares the four feasible options with respect to protection of human health
and the environment. The State of Hawaii Department of Health (DOH) regulates both
WWTPs and IWS. All four feasible options are protective of human health and the
environment when implemented in accordance with the applicable Hawaii
Administrative Rules (HAR). Additional discussion is provided in Parts A and B.
Table 1. Protection of Human Health and the Environment
Feasible Option Regulatory
Authority Variances Protective?
i. Package plant and new collection system HAR 11-62
Subchapter 2
Variance granted by DOH for WWTP flow
capacity Yes
ii. Package plant connected to the existing
collection system
HAR 11-62
Subchapter 2
Variance granted by DOH for WWTP flow
capacity Yes
iii. A maintenance contract model IWS
program
HAR 11-62
Subchapter 3
Variances may be required for some lots
for setback distances, etc.Yes
iv. An operating permit model IWS program HAR 11-62
Subchapter 3
Variances may be required for some lots
for setback distances, etc.Yes
Ms. Brenda Iokepa-Moses
County of Hawaii Wastewater Division
April 8, 2023
Page 3
1.2 Capital Cost Comparison of Feasible Options
Table 2 summarizes the capital costs for the four feasible options. Note that the IWS
capital costs per lot are presented as ranges; greater precision will not be available until
designs are complete due to the site-specific nature of IWS implementation on existing
developed properties.
Table 2. Capital Cost Comparison
Feasible Option Capital Cost Cost per Lot
i. Package plant and new collection system $37.3 million $214,000
ii. Package plant connected to the existing collection system $23.6 million $136,000
iii. A maintenance contract model IWS program $5.7 - $17.4 million $33,000 - $100,000
iv. An operating permit model IWS program $5.7 - $17.4 million $33,000 - $100,000
As shown in the table the IWS feasible options incur significantly lower capital costs than
the package plant alternatives.
1.3 Life-cycle cost comparison
A life-cycle cost comparison was prepared for the alternatives. The life-cycle cost is the
net present value of cash flows required to implement the project over a 30-year
planning period, including capital, operation, maintenance, and replacement costs. The
life-cycle cost evaluation includes inflationary effects and the time value of money. Table
3 summarizes the life-cycle cost evaluation results. The IWS approaches assumed the
maximum estimated capital costs presented above; the average cost per lot will likely
fall between the two extremes shown in Table 2.
Table 3. Life-Cycle Cost Evaluation Results
Alternative Capital Cost O&M Costs Life-Cycle Cost
i.Package plant and new collection system $37.3 million $19.7 million $57.0 million
ii. Package plant connected to the existing collection system $23.6 million $21.6 million $45.2 million
iii. A maintenance contract model IWS program $17.4 million $9.4 million
a $26.8 million
iv. An operating permit model IWS program $17.4 million $11.3 million
a $28.7 million
a Includes replacement costs and IWS O&M costs paid directly by homeowners.
Ms. Brenda Iokepa-Moses
County of Hawaii Wastewater Division
April 8, 2023
Page 4
Figure 1 shows the results graphically. The IWS alternatives have significantly lower life-
cycle costs than the package plant alternatives.
Figure 1. Life-Cycle Cost Comparison
1.4 Schedule
The Revised AOC requires the LCCs be closed no later than July 21, 2026. Parts A and B
include preliminary assessments of implementation schedules. Table 4 provides a
summary of the preliminary implementation schedule assessments. As discussed in
Part A, it will be difficult to implement the WWTP approach to close the LCCs by the
deadline, due to entitlement processes, environmental review, land acquisition, and
materials supply challenges currently facing the Hawaii construction industry. A
design/build approach could potentially reduce the implementation timeframe if
equipment procurement and fabrication can occur in parallel with design. However,
compliance with the Revised AOC deadline will be a significant challenge with Feasible
Options i and ii. Per Part B, the IWS approach may be able to be implemented by the
Revised AOC deadline. The IWS approach assumes that the County can address Hawaii
Revised Statues (HRS) 343 environmental review requirement via an exemption, and
that any alterations to County regulations deemed necessary by the County are
achievable within the timeframe.
Ms. Brenda Iokepa-Moses
County of Hawaii Wastewater Division
April 8, 2023
Page 5
Table 4. Summary of Preliminary Implementation Schedule Assessments
Feasible Options
Description i. Package Plant
New Collection
System
ii. Package Plant
Existing Collection
System
iii. Maintenance
Contract Model IWS
Program
iv. Operating
Permit Model IWS
Program
Entitlements and permitting Q3 2024 Q3 2024 Q1 2024 Q1 2024
Design and construction Q4 2027 Q4 2027 Q2 2026 Q2 2026
Estimated LCC closure Q2 2027 Q2 2027 Q2 2026 Q2 2026
Revised AOC LCC closure
milestone July 21, 2026
Risk of missing Revised AOC
LCC closure milestone High High Moderate Moderate
Note: Q = quarter
2. Revised AOC References
The Revised AOC paragraph V.30.A.a lists information that must be included in this
Revised PER. Table 5 provides references to the information within.
Ms. Brenda Iokepa-Moses
County of Hawaii Wastewater Division
April 8, 2023
Page 6
Table 5. Revised AOC Paragraph V.30.A.a Checklist
Report Reference Section for Feasible Options
Revised AOC Paragraph V.30.A.a
Description i. Package Plant
New Collection
System
ii. Package Plant
Existing
Collection System
iii. Maintenance
Contract Model
IWS Program
iv. Operating
Permit Model
IWS Program
Description of project details for each
feasible option Part A, § 2.2 and 8 Part A, § 2.4 and 8 Part B, § 1, pg. 3
Planning area description Part A, Figure 2-1 Part A, Figure 2-1 Part A, Figure 2-1 Part A, Figure 2-1
Planning period Part A, § 7.2.3 Part A, § 7.2.3 Part A, § 7.2.3 Part A, § 7.2.3
Description of planning phases Part A, § 7.2.3 Part A, § 7.2.3 Part A, § 7.2.3 Part A, § 7.2.3
Owner and operator of facilities Part A, § 1-1 Part A, § 1-1
County /In-house
or 3rd party service
provider
Homeowner / 3rd
party service
provider
Location of facilities (including a map) Part A, Figure 2-1 Part A, Figure 2-1 Part A, Figure 2-1 Part A, Figure 2-1
Design parameters for each feasible
option Part A, § 2.2 and 8 Part A, § 2.4 and 8 Part B, Table 1.1 Part B, Table 1.1
Major unit processes: Part A, § 5 Part A, § 5 Part B, § 2 and 3 Part B, § 2 and 3
Flow diagram Part A, Figure 8-2 Part A, Figure 8-2 Part B, Appendix J Part B, Appendix J
Pipe lengths, sizes, and locations Part A, Table 2-2 Part A, Table 2-2 Not applicable Not applicable
Design criteria Part A, § 8.3 Part A, § 8.3
Part B, § 3,
Appendix J
Part B, § 3,
Appendix J
Project costs Part A, § 7 Part A, § 7 Part B, Table 1.2 Part B, Table 1.2
3. Recommended Approach
Based solely on the technical analysis presented in Part A and Part B of this report and
considering the significantly lower capital and lifecycle costs and favorable
implementation schedule associated with of the IWS option, we recommend the County
pursue an IWS approach to close the LCCs by the Revised AOC deadline of July 21,
2026. Implementation and logistics of the IWS options (including issues not addressed
in this report) are concurrently being investigated by the County. If the IWS approach is
selected by the County and approved by the EPA, the next step will be for the County to
develop an Implementation Plan that will include definition of the intended IWS
management model.
Ms. Brenda Iokepa-Moses
County of Hawaii Wastewater Division
April 8, 2023
Page 7
Brown and Caldwell appreciates that the County has requested our services in assisting
with this project. Should you have any questions, please do not hesitate to call Michelle
Sorensen at 808.442.3306.
Very truly yours,
Brown and Caldwell
Michelle Sorensen, Project Manager Craig Lekven, Project Director
Kamuela, Hawaii Wailuku, Hawaii
for P A R T A : W W T P A p p r o a c h
Ka'u High &Pahala ElementarySchoolProposed PahalaWWTP SiteKa'uHospital
P A R T B : I W S A p p r o a c h
4/30/24
Appendix B
Archeological Literature Review Report
O‘ahu Office
P.O. Box 1114
Kailua, Hawai‘i 96734
Ph.: (808) 262-9972
Fax: (808) 262-4950
www.culturalsurveys.com
Hawaiʻi Office
399 Hualani St. #124
Hilo, Hawai‘i 96720
Ph.: (808) 965-6478
Fax: (808) 965-6582
Archaeological Literature Review Report for the
Pāhala Large Capacity Cesspool Closure Project,
Hionamoa, Pālima, and Pāʻauʻau 1 and 2 Ahupuaʻa,
Ka‘ū District, Hawai‘i Island
Multiple Parcels and County Roadways in
TMKs: (3) 9-6-002, 005, 014, 015,
016, 017, 018, 020, and 021
Prepared for
County of Hawaiʻi Department of Environmental Management,
Wastewater Division
Prepared by
Sarah Wilkinson, B.A.,
and
Hallett H. Hammatt, Ph.D.
Cultural Surveys Hawai‘i, Inc.
Kailua, Hawai‘i
(Job Code: HIONAMOA 5)
November 2023
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the LCC Closure
TMKs: multiple
Reference Archaeological Literature Review Report for the
Capacity Cesspool Closure
, Multiple Parcels and
County Roadways in TMKs: (3) 9-6-
(Wilkinson and Hammatt 3)
November
Cultural Surveys Hawai‘i, Inc. (CSH) Job Code: HIONAMOA 5
CSH completed this study under archaeological fieldwork permit
number 3-30, issued by the Hawai‘i State Historic Preservation
--
Project Proponent County of Hawai‘i
Ramzi Mansour
Attention: Mark Grant, Project Coordinator
cohdem@hawaiicounty.gov
Project Location
(3.3
It
-minute topographic quadrangle
(Figure ), Figure and Figure 3 –
Figure ).
The project area includes (in
whole or in part) and portions of multiple
roadways . The proposed treatment plant is located adjacent
within a portion of TMK: (3) 9-6-large-capacity
cesspools (LCCs) slated for closure are located at TMKs: (3) 9-6-
(LCC and 9-6- (LCC . A full list of
TMK parcels within the project area is provided .
Administrative Order on Consent (AOC) to close two
The County currently owns, controls, maintains, and operates the two
LCCs
on or before 5 has identified
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the LCC Closure
TMKs: multiple
four wastewater treatment project options that facilitate closure of the
LCCs:
Wastewater treatment plant and effluent disposal area within a
-acre site, including a package plant and new collection
system.
Wastewater treatment plant and effluent disposal area within a
-acre site, including a package plant
collection system.
3. Individual Wastewater System (IWS) with maintenance
contract.
Individual Wastewater System (IWS) with operating permit
model.
It is anticipated that the project will be undertaken solely with the
The County may pursue the use of funds from the State of Hawai i
Revolving Fund
(CWSRF) program, but that has not been confirmed at this time.
of CWSRF funds will require compliance with Federal Crosscutter
oric Preservation Act.
the IWS improvements associated with the
proposed action are classified as non-point source pursuant to Section
located within portion of TMK: (3) 9-6-. The package plant
would be within the -acre portion of this parcel previously
. The Pahala WWTP and
effluent disposal area and package plant would be the same area as the
prior proposed
acres and the remaining
remain in macadamia nut orchard which will be irrigated using the
treated effluent discharge (Figure 5).
According to a preliminary engineering r
, Alternatives include an
IWS program in lieu of development of a package treatment plant. The
IWS alternatives involve
constructed and installed to close the two describes
disposal of effluent that would generally require an area of between
(sq ft), depending on the percolation rate of the
soil. Figure 6 shows a typical IWS layout plan for an absorption bed.
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the LCC Closure
TMKs: multiple
3
showed an alternative IWS with septic tank and seepage
Figure shows a typical
IWS layout plan for a seepage pit.
The revised AOC further stipulates that the County must administer a
more active management strategy than is typical in Hawai‘i, either a
management strategy for a network of IWS at
P hala. These models reflect varying degrees of responsibility for the
County and homeowner.
Project Area
acres ( hectares)
This investigation was designed—through detailed historical, cultural,
and archaeological background research—to determine the likelihood
that historic properties may be affected by the project and based on
findings, consider cultural resource management recommendations.
This document is intended to facilitate the project’s planning and
support the project’s historic preservation and environmental review
compliance. This investigation does not fulfill the requirements of an
archaeological inventory survey i -
This information also supports the
-
CSH conducted an archaeological inventory survey (AIS) for a prior
iteration of the project
System project) –
addressed a project area and federal area of potential e
comprising the majority of the current project area. The AIS was
Log No.:
the project effect determination of no
historic properties affected and stipulation of archaeological
monitoring for identification purposes. An archaeological monitoring
plan was prepared and accepted by
Log No.: ,
No.: . CSH conducted some monitoring for a
geotechnical survey of the proposed collection system and plant site in
Ja
been put on hold.
the
County voluntarily entered into the revised AOC for closure of the
. The County has proposed several
new project alternatives for the LCC closures, including
alternatives that differ significantly from the project addressed in the
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the LCC Closure
TMKs: multiple
Therefore, the project area has been
would be subject to IWS development under proposed Alternatives 3
are lots connected to the
properties , but were not
included within the AIS project area nor surveyed during that study
(Figure ). A number of additional parcels categorized as newly
accessible have also been incorporated into the current project
these include lots located along the eastern side of Pikake Street and
portions of Huapala Street, H nano Street, ‘Ilima Street, and Maile
Street (see Figure ).
Natural
3 miles) back from
the coast on the southeastern slope of Mauna Loa volcano, at an
–305 m (590–
inches oday supports commercial
agricultural crops like coffee and macadamia nuts and historically
the forest reserve makai
natural waterways are present within the project area. Vegetation
within the potential package treatment plant area consists of a
macadamia (Macadamia integrifolia) orchard with Norfolk Island
pines (Araucaria heterophylla) used for windbreaks. The terrain in this
area is gently sloped to the southwest. The sewer line easement
Landscaped residential yards line the sides of the County roadways in
sloped.
The unique geology of its upper slopes, lined with a string of large
(hills, cinder cones) has protected broad portions of windward
Mauna Loa from relatively recent lava flows. The region is known for
its arable soils formed in volcanic ash, commonly referred to as
ure
) and soil
consist of soils from the Waiaha and Naalehu series (Figure 9). The
(WAC), with two small areas along the edges overlapping Waiaha silt
project area is Waiaha very rocky
The remaining central and southern portions of the project area are
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the LCC Closure
TMKs: multiple
5
-
-Figure 9).
Waiaha soils are described as
shallow, well-drained silt loams that formed in volcanic
ash. These soils are nearly level to moderately steep and
[…] The natural
vegetation consists of kiawe, koa haole, natal redtop,
lantana, guineagrass, and bermudagrass […]
The WAC type which is predominate in the project area has a non-
stony surface layer and “receives more rain during the winter than the
Naalehu soils are described as
well-drained silty clay loams that formed in volcanic
ash. These soils are nearly level to steep […] The
natural vegetation consists of Christmas berry,
bermudagrass, guava, and kaimi cover […] Naalehu
soils are used mostly for sugarcane. Small areas are
The entire project area has been altered by agricultural, commercial,
and residential development. The location of the potential package
treatment plant area is currently an active macadamia nut orchard
operated by Royal Hawaiian Orchards. This portion of the project area
Highway (State Inventory of Historic Places [SIHP] # 50---
by an unimproved jeep road separating the orchard from the Royal
Hawaiian processing facilities. This road is bound to the east by a
mauka-makai (from mountains to sea),
located outside the project area. An unnamed paved roadway forms
road provides access to and from the Royal Hawaiian Orchards
processing facility via Maile Street. Just inside the western boundary
of the parcel parallel to Maile Street is another unimproved road, used
to access the orchard. An earthen ditch is situated between this road
and Maile Street, designed to channel run-off downslope. The orchard
itself is bisected by a large, linear dozer push pile containing a row of
along both sides of this push pile.
The new sewer collection
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the LCC Closure
TMKs: multiple
6
including Maile Street, Pikake Street, ‘Ilima Street, Huapala Street,
H nano Street, Kamani Street, and Puahala Street (see Figure ). These
Town. The portion of Maile Street in which the sewer line would be
placed
mill and associated plantation structures are present on either side of
Maile Street. Some of these structures are within the current project
area.
Three sewer line easements are proposed for
portions of the sewer line not within County roadways. One of these
Street, which crosses privately owned TMK: (3) 9-6-
.
(3) 9-6-
005:036. The maintenance yard property has been completely altered
with the development of the sugar plantation and town. The property
has been graded and contains structures, driveways, parking areas, and
historic structures on this parcel, including at least two large buildings
situated within the current project area that remain in active use. This
easement
theast into TMK: (3) 9-6-
through the macadamia nut orchard where it would connect to the
proposed package plant.
: (3) 9-6-
Street, at the terminus of a sewer easement maintained by the County.
easement is -
lines are located behind a private residence at TMK: (3) 9-6-
This residential property comprises a main dwelling, outbuildings,
driveway, and landscaped yard.
The sewer collection and transmission lines overlap with the known
potential historic property and was designated SIHP # 50--69-
CSH has been unable to obtain any documents (such as a
NRHP nomination form or state inventory form) describing this
district and its contributing elements.
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the LCC Closure
TMKs: multiple
Mission Children’s Society Library and Archives, the Hawai‘i Public
useum
photographs from the CSH library were also consulted. In addition,
se
3).
This research provided the environmental, cultural, historic, and
archaeological background for the project area.
fierce people.
the boundaries of the traditional land divisions or of
. According to Handy and
Handy
used for scattered homesteads with cultivated fields and groves.
In the pre-Contact period, inter-district competition resulted in the
shifting dominance of the ali‘i (chiefly
record their early impressions of the land and its people.
the most horrid and dreary kind
first impression, the rich fishing grounds on the coast and the inland
plantations provided Hawaiians with an abundance of resources,
which supported a substantial population. Later visitors including
voyage of Captain George Vancouver, and t
, , encountered productive
and populous villages along the coast and at inland places such as
, west of the project area. Handy and Handy :595–
596) the village of a similar pre-Contact habitation center.
evidence of a coastal pre-Contact village at Palima Point well makai of
the current project area.
The early post-Contact period was marked by a significant decline in
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the LCC Closure
TMKs: multiple
disease, outmigration to new commercial centers, and natural disasters
–
and the Kuleana Act
In the mid-nineteenth century, the Kingdom of Hawai‘i initiated a
Mid- to late nineteenth century Land Commission Award (LCA)
records provide insight into former land use within the project area.
9
not Figure )
William Pitt
) indicates Moses Keawe claimed five pana
(lots)
“Kau-
northwest of the project area along the “CaneHaul Road
pana were house lots. The three pana
not awarded comprised taro fields.
-
m north of the
provide information about land use. No kuleana are indicated within
-
9) notes that Grant 03533, which also
r quitclaim deed
mauka
(inland) of the “Kau-
Figure ) in
relation to the project area. Figure also indicates a fifth grant in
two separate pana ) as located in
Kopu-Figure indicates the
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the LCC Closure
TMKs: multiple
9
Land Grants are indicated within Hionamoa.
Mid-to-
The middle to late nineteenth century was characterized by the
agricultural products and livestock and cattle ranching. Commercial
production of wheat
pulu (a soft, flossy, yellow wool on the base of tree-
fern leaf stalks [Cibotium spp.] used for stuffing mattresses and
had a negative impact on the native peoples it employed (Shipman
the forces of nature. A sequence of major earthquakes and eruptions of
losses of property and livestock . An
earthquake in early April precipitated a tidal wave that destroyed
emptying the crater’s
lava lake into Punalu‘u and Keauhou . A subsequent lava flow,
great cliff or pali.
, kicking off the era of sugar
-
was established by John Nott and Company. This operation was
9, his name survived in the Hutchinson Sugar Company which
.
Another plantation operation, the Hawaiian Agricultural Company,
businessmen
Hawaiian Agricultural Company sugarcane lands (Figure ) shows
within the southern-central portion of the
project area. The western portions of the project area including the
proposed plant site are indicated to overlap lands already planted in
cane, while the eastern portions of the project area overlap presumably
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the LCC Closure
TMKs: multiple
depicted Figure ) also depicts the location of the mill
Figure curiously depicts the project area
information about these place names was found
3
in the uplands between Punalu u . Figure also
mauka
makai
lso
altering the social landscape. the Chinese
laborers were brought in, followed by Japanese, Portuguese, and other
Filipinos began arriving during the first decade of the
twentieth century –. thnic
workers’ camps were built surrounding
Twentieth Century
Figure
the project area. Figure
of sugar plantation lands (in red) in relation to the forest lands mauka
(in blue) and grazing lands east associated with Kapapala Ranch. The
also depicted, with the addition of mauka-makai and lateral routes
Figure ). The
Figure
shown is labeled “Kau-
Figure ) includes some additional details about
northern portion of the project area and continuing off the map to the
east and west. It is unlikely that any portion of this trail remains within
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the LCC Closure
TMKs: multiple
the town vicinity, which has been completely altered by agricultural
and residential development. Furthermore, a meandering “Plantation
unnamed roadway and then curving back to the east where it stops
abruptly. Presumably this limited railroad was used to carry cut cane
to the mill from some of the nearby fields. More remarkable upon the
physical landscape at this time must have been the systems of flumes
for transporting cane from fields to mi
transporting cane at the time.
Railway development continued, with the establishment of lines
mpany cane fields
(Figure
across through the narrow central portion of the project area and to the
phic map
(Figure
narrow-to the coastal road
which includes additional rows of structures along roadways and
around the mill, as well as the locations of the school (still north of the
present campus), a church, a pipeline, and a large stone wall to the
southeast of the town. The route of the major roadway crossing
the advent of trucking for harvesting and transportation of cane. In the
makai
Figure ) shows this new route and the continued
southwest into the heart of the town, and a landing strip had been
constructed to the northeast. All of the older road alignments are still
depicted, but no
side-
installation of the culvert at the Huapala and ‘Ilima streets intersection.
a portion of an undated
Olson Trust map (Figure -
drawn annotations indicate some land uses in the area dating to the
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the LCC Closure
TMKs: multiple
crosses through a rectangular area labeled “Cane Area Planted Aug.
located east of the proposed WWTP site. This map appears to depict a
portion of the former narrow-
illustration may indicate disturbance to or dismantling of the former
railroad route by the mid-twentieth century in the area crossed by the
easement. The Olson Trust drawing also depicts numerous structures
along Maile Street, many of which are no longer present.
Figure
town to the east amidst large agricultural plots. Note that the proposed
WWTP plant site portion of the project area is not cultivated in
readied for planting of the macadamia orchard that is now fully
matured.
merged with the Hutchinson Sugar Company to form the Kau Sugar
Company, which was renamed the Kau Agribusiness Company in
sugar industry in other parts of the island, Kau Agribusiness Company
predominately agricultural and livestock economies. The town is also
used as a stop-
a-Kona.
Archaeological
Nine previous archaeological studies have been conducted in the
. These previous
archaeological studies are shown Figure and summarized in Table
.
tream Flood Control
ee Figure ). The
-km (-ft) section of
mauka
documented, and no further work was recommended.
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the LCC Closure
TMKs: multiple
Figure -acre
on either side of the bridge along the highway, and adjacent areas to
the east. Significant prior disturbance from agricultural and road
development and a major flooding event were noted. No
archaeological features were documented, and no further work was
recommended.
Figure
prior disturbance from modern and historic agricultural activity dating
back to the latter half of the nineteenth century. One newly recorded
historic property was documented: SIHP # --m-long
section of a historic irrigation flume associated with the former sugar
plantation (Figure ). No traditional sites were identified, and no
further work was recommended.
-
sq-ft portion of TMK: (3) 9-6-
Figure ). Prior disturbance associated with commercial
agriculture was noted. No archaeological features were observed.
As part of a state-
systems improvement project, CSH undertook a literature review and
area
Figure ). The LFRI included
previous archaeological studies in the vicinity and noted that the
school is listed on the Hawai‘i Register of Historic Places (HRHP)
(SIHP # 50--69-Figure ). Hammatt and Shideler
-site archaeological monitoring for the
project.
Figure ). The project
involved the installation of a new leach field, eight septic tanks, and
associated sewer lines. While no subsurface cultural deposits were
located
assigned a site number (SIHP # 50--69-
cultural modifications to the breached portion of the tube system. The
location of SIHP # -Figure .
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the LCC Closure
TMKs: multiple
-acre
ee Figure ). The
SIHP # -
burial site was found within the tube and designated SIHP # 50--69-
Figure ). This burial is located away from the limits of
the current project area.
as follows:
system opening under a modern storm drain grate
[Figure ]. The southern branch does not contain
in the northern and western branches of the tube system,
respectively.
The western branch includes two tubes that are situated
parallel to each other and are connected at two points.
The western branch of the tube system is closed off by
the northern tube of the western branch, roughly
35.0 meters in from the storm grate opening [Figure ].
The northern branch of the tube system is accessed
through an opening in the floor of the western tube
system. The floor of the northern branch is
branch tube [Figure ].
Full descriptions of SIHP #s --
-
non-Figure
, Feature 3 may be situated within a portion of the tube underlying
TMK: (3) 9-6- which is within the current project area.
Feature 3 is described as a low rock alignment located at the northeast
terminus of the northern branch of the lava tube. No other
-acre project area.
-
-
itoring of any
future ground disturbing work “near the northern and western
an archaeological field inspection
of TMK: (3) 9-6-
Figure
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the LCC Closure
TMKs: multiple
disturbance associated with the development of the macadamia nut
orchard was noted. Surface artifacts were encountered within a portion
of the macadamia nut orchard that is no longer within the project area
limits (see Figure ). These artifacts included a single traditional
hammerstone and fragmental historic glass and ceramics. The report
opening to the tube on the processing plant property was filled in
sometime in the past to prevent access. Pacific Legacy recommended
requirements, noting that an AIS would likely be required. It was also
rec
Most recently, CSH undertook an AIS for the prior
Treatment Plant and Sewer System project
Figure -hectare
(-acre)
roadways, and the locations of the two LCCs slated for closure. Two
newly documented historic properties were identified through
background research: SIHP #s 50--69-
--69-
historic Volcano Road corridor (Figure ). Full site descriptions
oth
sites were assessed as significant under Criterion d for yielding
important information for research on former rights-of-way in P hala
history. Constructed elements of the portions of these road alignments
within the project area were determined to have been thoroughly
impacted by the development of modern roadways, becoming Maile
Street and Pikake Street in P hala Town within the original corridors.
, the
AIS determined these historic properties only retain integrity of
location. They were assessed as significant under Criterion d per HAR
--6 for the information they have yielded about primary
and early twentieth centuries. No further work was recommended.
Other historic buildings associated with the former sugar plantation
were noted nearby but outside the AIS project area.
Potential for
Two historic properties were previously located within the project area
: SIHP # -
-
Volcano Road corridor). These sites were determined to retain
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the LCC Closure
TMKs: multiple
integrity of location only and recommended for no further work
–v).
The project area may overlap the northeastern terminus of the northern
branch of lava tube system SIHP # -, previously documented by
previously
documented understood to
lie beneath the campus
(including the portion containing burial site SIHP # -, a small
portion of the system in the vicinity of Feature 3 (rock alignment) may
(3) 9-6-0 :003, which is within
the current project area.
The project area is within the “P
-. CSH has been unable to obtain any documents (such as a
NRHP nomination form or state inventory form) describing this
district and its contributing elements. Several of the historic buildings
within the project area associated with the former plantation village
may be considered contributing architectural elements to this district.
These include:
A plantation-era building containing the offices of Olsen Trust
at TMK: (3) 9-6- at the Pikake Street and Maile Street
intersection (Figure )
Plantation-era buildings and structures in current commercial
use and the Corliss steam engine monument at TMK: (3) 9-6-
005:036 located along Maile Street (Figure through Figure
)
A plantation-era store building located at TMK: (3) 9-6-
along Maile Street (Figure )
A plantation-era shop building remnant foundation
of the old theater building along Maile Street, and other
plantation buildings located along Mill Camp Road within
TMK: (3) 9-6-Figure 30 and Figure )
A plantation-era residence located at TMK: (3) 9-6-
along Maile Street (Figure )
Other plantation-era homes located throughout the project area
The County has stated that none of the buildings or structures within
the project area will be impacted by project development.
this statement and the general nature of the project, no impact on the
“P indicated.
Three other historic properties are located outside but near to the
project area, including:
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the LCC Closure
TMKs: multiple
A burial site (SIHP # -) within lava tube system SIHP #
50--69-
campus
--69-
-eligible historic property
---
Register-eligible historic property south of the project area
Impacts to these historic properties are also not anticipated.
Given the known traditional land use in this area and the impacts of
continued agricultural and residential development, surface pre-
development of the macadamia nut orchard has likely also obliterated
any plantation-era sites once present in that part of the project area.
Historic surface features associated with the sugar plantation and
associated village may be present. Furthermore, there is potential for
pre- or post-Contact subsurface archaeological features within the
project area, which may or may not be located within lava tubes.
configuration of the proposed wastewater treatment system requires
about historic preservation requirements.
The proposed WWTP and effluent disposal site is within the same
-acre plant site covered in the AIS. The
provided concurrence
determination of no historic properties affected based on the findings
.
now includes many individual house lots and
commercial properties, which may contain historic buildings of
architectural importance. The County has indicated no buildings or
structures will be impacted by the project, but the grounds surrounding
an historic structure where the IWS alternatives would be installed
usually contain elements of the historic property.
he
but with amendments. -accepted monitoring plan
(Wilkinson and Hammatt 0) addresses only some elements of the
four proposed alternatives. We believe an amendment could satisfy
any elements of the selected alternative not covered in the plan.
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the LCC Closure
TMKs: multiple
Figure . -minute topographic quadrangle showing the
location of the project area
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5 LR for the Closure TMKs: multiple Figure . TMK: (3) 9-6- ) Cultural Surveys Hawai‘i Job Code: HIONAMOA 5 LR for the Closure TMKs: multiple Figure 3. TMK: (3) 9-6-05 showing the project area (Hawai‘i TMK Service )
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Figure . Aerial photograph –) showing the location of the project area and Cultural Surveys Hawai‘i Job Code: HIONAMOA 5 LR for the Closure TMKs: multiple Figure 5. Overall site plan for proposed package plant (courtesy of client)
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Figure 6. Typical IWS layout plan with absorption bed (courtesy of client)
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Figure . Typical IWS layout plan with seepage pit (courtesy of client)
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Figure configuration of the prior AIS project
area within the greater project
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Figure 9. Overlay of Soil Survey of the Island of Hawaii 3) indicating soil types
within and surrounding th )
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Figure . -Kopu-Makaka Makai Government Tracts, showing the project
area in relation to roads, trails, and the plantation railroad Cultural Surveys Hawai‘i Job Code: HIONAMOA 5 LR for the Closure TMKs: multiple Figure . ane lots
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Figure .
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure 30
TMKs: multiple
Figure .
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5 LR for the Closure TMKs: multiple Figure . mpany cane fields, showing the location of the project area Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Figure . -minute topographic quadrangle showing
vicinity
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure 33
TMKs: multiple
Figure . -minute topographic quadrangle showing the
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Figure . Portion of an undated field map of the Pahala Mill and Camp reprinted in Cleghorn
southern portion of the project area in relation to plantation
features
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure 35
TMKs: multiple
Figure .
the project area and continued
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure 36
TMKs: multiple
Figure . -minute topographic quadrangle showing
previous archaeological studies in the vicinity of the project area
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Table . Previous archaeological studies in the vicinity of the project area
Reference Location -10-69****)
Archaeological
reconnaissance
and Wood Valley Rd,
No historic properties or cultural
materials identified
Archaeological
inventory survey
(recorded as an
archaeological
assessment)
portions TMKs: (3) 9-6-
-6--6-
-6-
No historic properties or cultural
materials identified
Haun and
Archaeological
inventory survey (3) 9-6-
, and 9-6-
One historic property
documented: SIHP # -
historic irrigation flume
associated with sugarcane
cultivation
Jourdane
Archaeological
inventory survey
(recorded as an
archaeological
assessment)
(3) 9-6-
No historic properties or cultural
materials identified
Hammatt and
Literature review
and field
inspection
(3) 9-6-
-5-009:006,
-site archaeological
monitoring recommended
Wilkinson et
Archaeological
monitoring
(3) 9-6-
property documented: SIHP #
-lava tube
Archaeological
inventory survey
(3) 9-6-
previously recorded SIHP #
-
documented one new historic
property, a historic-era burial
(SIHP # -
-
be within a portion of tube
underlying current project area
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Reference Location -10-69****)
Cleghorn
Archaeological
field inspection (3) 9-6- artifacts and a lava tube within
recommended
Archaeological
inventory survey
Former
Treatment Plant and
Sewer System project,
TMKs: (3) 9-6-
-6-005:036
-6-
Rights-of-Way
identified sites: SIHP #s -
(historic Wood Valley
) and
SIHP # -(historic
Volcano Rd corridor)
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure 39
TMKs: multiple
Figure . -minute topographic quadrangle showing
locations of sites documented in previous archaeological studies in the vicinity of the
project area Cultural Surveys Hawai‘i Job Code: HIONAMOA 5 LR for the Closure TMKs: multiple Figure . Map from () documented site locations
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Figure . Survey map of SIHP # --
9 is section of the lava tube is near but outside the current
project area Cultural Surveys Hawai‘i Job Code: HIONAMOA 5 LR for the Closure TMKs: multiple Figure . West pLocation
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Figure showing the locations of historic roadways SIHP
#s 50--69--
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Figure a plantation-era building containing the current Olsen Trust
offices located within the project area at TMK: (3) 9-6-
Figure CSH photo of plantation-era buildings and the Corliss steam engine monument
located at the intersection of Pikake Steet and Maile Street within the project area at
TMK: (3) 9-6-west
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Figure a plantation-era building located within the project area at TMK:
(3) 9-6-
Figure a plantation-era building located within the project area at TMK:
(3) 9-6-east
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Figure -era store building located along Maile Street within
the project area at TMK: (3) 9-6-
Figure 30 plantation-era shop building located along Maile Street
overlapping the project area at TMK: (3) 9-6-
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Figure 9) street view photo of the intersection of Maile Street with Mill
TMK: (3) 9-6-
to southeast
Figure . 9) street view photo of a plantation-era residence located near the
project area at TMK: (3) 9-6-
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5 References Cited
LR for the Closure
TMKs: multiple
Ahlo, Jr., Hamilton M.
. Science Management, Inc., Honolulu.
t
-6--6-
-6--of-. Cultural
-6-. Letter report.
. Glenwood Publishers, Felton,
California.
Honolulu.
Sugar -Year Story of Sugar in Hawai‘i. Mutual Publishing,
Honolulu.
–6–
Advertising Publishing Company, Honolulu.
-Acre Portion of
-6-. Scientific
–
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5 References Cited
LR for the Closure
TMKs: multiple
--
Online Rainfall Atlas of Hawai‘i. Bulletin of the American Meteorological Society
--D--
.
Aerial photographs of Hawai‘i. Google Inc., Mountain View, California.
-
-6--
. Letter report. Haun
-6--6-
Hawai‘i TMK Service
: (3) 9-6-and 9-6-05. Hawai‘i TMK Service, Honolulu.
. G. Nicol and T. Cadell, London.
-
Hawaii Press, Honolulu.
Map of Hawaiian Agricultural Company Sugar Cane Lands. F.S. Lyman, Surveyor.
of Accounting and General Services, Honolulu. Available online at
3 An Archaeological Survey of the Palima Point Project Site, Ahupua a of Makaka,
Hionamoa, Pa au au I, Pa au u, Hawai i Island
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5 References Cited
LR for the Closure 50
TMKs: multiple
. W.F. Wilson, editor. New Freedom Press, Honolulu.
National Park Service
-loa-.
Pierce, R.F.
Map of Kaalaala and Moaula-Kopu-
Accounting and General Services, Honolulu. Available online at
Soil Survey of the Island of Hawaii, State of Hawaii.
-collection.
9
-
Soil Sur
.
USGS ()
30 Palima Point -
Pahala -
Pahala, Punaluu, Naalehu and Wood Valley -minute series topographic
Waihona ‘Aina
3
Wall, W.A.
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5 References Cited
LR for the Closure
TMKs: multiple
-6--6-
-6--of-. Cultural
, Ro
Hawai‘i Inter-
-6-
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Project Area TMK
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure 53
TMKs: multiple
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure 55
TMKs: multiple
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure 56
TMKs: multiple
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure 59
TMKs: multiple
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure 60
TMKs: multiple
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
SIHP # 50-10-69-27570 (21–30)
27570
Historic and Modern
Fair
Altered by weathering
Modern Trash and Marine Shell
None
3) constructed in the northern branch of a lava tube system [see Figure ].
Feature lava tube system. Feature
tube. Feature 3 is a rock
opening of the lava tube system [Figure 33]. A storm drain was constructed in the
Figure and Figure 35]. Feature
3.0 meters high in places. Trash washed along the bottom of the tube continues as
a light scatter throughout the northern branch of the lava tube. Items of trash include
primarily bottle glass, fragments of sheet metal, plate ware, plastic items, and a
truck frame and rims [Figure 36 and Figure ]. Small amounts of burned wood,
including cow and goat)
impacted by drainage and is in fair condition. No further work is recommended at
terminus of the northern branch of the lava tube [Figure
Figure 39]. The
rock concentration is constructed of angular and subangular cobbles loosely piled
one to two layers on the tube floor [Figure ]. Two fragments of goat bone, modern
bottles, and a piece of burnt wood were identified on the rock concentration and on
the surrounding ground surface.
There is an alignment of small boulders stacked just northwest of the rock
concentration. The alignment is one to two courses wide and high, and appears to
limit access to the low tube continuing to the northwest. There are no additional
archaeological features or cultural material located in the low tube area to the
northwest.
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure 63
TMKs: multiple
Figure 33. Plan view map of SIHP # -
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Figure . -
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5 LR for the Closure 65 TMKs: multiple Figure 35. P-Cultural Surveys Hawai‘i Job Code: HIONAMOA 5 LR for the Closure 66 TMKs: multiple Figure 36. SIHP # -frame)
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Figure . -
refuse
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Figure . Plan view map of SIHP # -
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure 69
TMKs: multiple
Figure 39. Plan view map of SIHP # -
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Figure . -
-Contact era to modern.
might have been constructed during the pre-
Feature 3 is a low rock alignment located at the northeast terminus of the northern
branch of the lava tube [see Figure
Figure 39]. The rock alignment is
constructed of angular and subangular cobbles and small boulders loosely stacked
two to three courses high on top of a large, boulder-size piece of roof fall [Figure
–30]
-
information it yielded about historic and modern use.
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Figure . Plan view map of SIHP # -
Figure . -
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
SIHP # 50-10-69-29501 (–34)
Good
Personal items owned by the deceased.
None
School Campus [see Figure and Figure ]. The remains were placed on a lava
bench on which the remains were placed, and is roughly represented by the
dimensions documented above.
skeletal remains). The bodies appear to have been laid supine with their feet to the
southeast and their heads to the northwest … It is possible that the bodies were laid
in an east-west orientation, and the skeletal remains have shifted to the present
northwest-southeast orientation. While the long bones of the legs are still
articulated, the majority of skeletal elements are not, denoting some shifting
associated with natural taphonomic processes and animal disturbance
There are no nails apparent on the surface of the remain, nor on the lava bench
surface in the immediate area of the burials. The lack of nails suggests the bodies
likely were not placed in coffins at the time of burial. The presence of black and
white glass buttons suggests the bodies were laid to rest in clothing…
burials likely post-.
Though the burials are from a time period when many people were immigrating to
personal items found with the remains suggest the skeletal remains belonged to
Hawaiians that likely had land to ranch and cultivate sugarcane.
The ceiling of the lava tube that the burials are located in is between 9.5 and
feet in thickness [see Figure
solid lava rock between the top of the lava tube ceiling and the ground surface. The
burials within the tube are located directly below an intersection between the
schools main access drive and a secondary campus road [see Figure ]. Road
traffic is not audible from the burial location and the burial does not appear to have
–
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
-
significant under Criteria d and e, “as the burial site both contains important data and, more
importantly, is important to native Hawaiian people or other ethnicities in the state, due to
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
SIHP # 50-10-69-
Transportation
Late -
[3] 9-6-005:999 (county right-of-way)
None
SIHP # 50--69---mile) section of the historic
[see Figure ]. The section of this alignment within the project area follows the
present Maile Street and Pikake Street alignments located between the Lower
Town, respectively [see Figure ]. Construction of the modern Maile Street and
--33 ft) wide, has
impacted all the constructed elements of the corresponding portions of the former
ay [Figure through Figure ].
with the original [see
Figure , Figure , Figure , Figure , and Figure ]. With the construction
of the new Volcano Road (SIHP # -
after the development of SIHP # -
route is still called Wood Valley Road, but it is used by residents of Wood Valley
SIHP -
–
--6, SIHP # -
information it has yie
during the late nineteenth and early twentieth centuries. []
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Figure . Photo looking up Pikake toward the Kamani Street
view to north
Figure . Photo from
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Figure . ) of a portion of Maile Street within the project
Figure . ) of a portion of Maile Street in the project area,
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Figure . -minute
topographic quadrangles showing the location of the project area in relation to historic
roadways
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
Figure . -minute topographic quadrangles
showing the location of the project area in relation to historic roadways (map from
9)
Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
TMKs: multiple
SIHP # 50-10-69-31089
Road alignment (Volcano Road)
Transportation
-
[3] 9-6-005:999 (county right-of-way)
None
SIHP # 50--69---mile) section of the historic
Volcano Road alignment located with the current project area [see Figure ]. The
section of this alignment within the project area follows the present Maile Street
alignment located between the Lower Moaula Road fork and Pikake Street,
overlapping along Maile Street with the SIHP # -
portions of these t
[see Figure ]. Construction of the modern Maile Street roadway, which is
corresponding portions of the former Volcano Road roadway [see Figure
through Figure ].
mauka
[see Figure , Figure , Figure ,
and Figure ]--
-
[see Figure ] shows the portion of the Volcano Road
[see Figure ] does not label the
route at all.
SIHP --
--6, SIHP # -
Criterion d for the information it has yielded about primary transportation routes in
[
Appendix C
Early Consultation Comments and Responses
JOSH GREEN, M.D.
GOVERNOR |
SYLVIA LUKE
LIEUTENANT GOVERNOR |
DAWN N. S. CHANG
CHAIRPERSON
BOARD OF LAND AND NATURAL RESOURCES
COMMISSION ON WATER RESOURCE
MANAGEMENT
DEPARTMENT OF LAND AND NATURAL RESOURCES
LAND DIVISION
P.O. BOX 621
HONOLULU, HAWAII 96809
November 3, 2023
Wilson Okamoto Corporation
Attn: Mr. Keola Cheng via email: publiccomment@wilsonokamoto.com
Director of Planning
1907 South Beretania Street, Suite 400
Honolulu, Hawaii 96826
Dear Mr. Cheng:
SUBJECT: Environmental Information Document Consultation Package for Pahala
Large Capacity Cesspool Closure located at Pahala, Island of Hawaii;
Numerous TMKs and Multiple Roadways in Pahala on behalf of County of
Hawaii, Department of Environmental Management
Thank you for the opportunity to review and comment on the subject matter. The Land
Division of the Department of Land and Natural Resources (DLNR) distributed or made available
a copy of your request pertaining to the subject matter to DLNR's Divisions for their review and
comments.
At this time, enclosed are comments from the (a) Engineering Division and (b) Land
Division-Hawaii District on the subject matter. Should you have any questions, please feel free
to contact Darlene Nakamura at (808) 587-0417 or email: darlene.k.nakamura@hawaii.gov.
Thank you.
Sincerely,
Russell Y. Tsuji
Land Administrator
Enclosures
cc: Central Files
DEPARTMENT OF LAND AND NATURAL RESOURCES
ENGINEERING DIVISION
LD/Russell Y. Tsuji
Ref: Environmental Information Document Consultation Package for Pahala
Large Capacity Cesspool Closure
Location: Pahala, Island of Hawaii
TMK(s): Numerous TMKs and Multiple Roadways in Pahala
Applicant: Wilson Okamoto Corporation on behalf of County of Hawaii,
Department of Environmental Management
COMMENTS
The rules and regulations of the National Flood Insurance Program (NFIP), Title 44 of
the Code of Federal Regulations (44CFR), are in effect when development falls within a
Special Flood Hazard Area (high-risk areas). Be advised that 44CFR, Chapter 1,
Subchapter B, Part 60 reflects the minimum standards as set forth by the NFIP. Local
community flood ordinances may stipulate higher standards that can be more restrictive
and would take precedence over the minimum NFIP standards.
The owner of the project property and/or their representative is responsible to research
the Flood Hazard Zone designation for the project. Flood zones subject to NFIP
requirements are identified on FEMAs Flood Insurance Rate Maps (FIRM). The official
FIRMs can be accessed through FEMAs Map Service Center (msc.fema.gov). Our Flood
Hazard Assessment Tool (FHAT) (fhat.hawaii.gov) could also be used to research flood
hazard information.
If there are questions regarding the local flood ordinances, please contact the applicable
County NFIP coordinating agency below:
o Oahu: City and County of Honolulu, Department of Planning and Permitting
(808) 768-8098.
o Hawaii Island: County of Hawaii, Department of Public Works (808) 961-8327.
o Maui/Molokai/Lanai County of Maui, Department of Planning (808) 270-7139.
o Kauai: County of Kauai, Department of Public Works (808) 241-4849.
Signed: ________________________________
CARTY S. CHANG, CHIEF ENGINEER
Date: ________________________________
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
10349-08
March 14, 2024
Mr. Carty Chang
Department of Land and Natural Resources – Engineering Division
State of Hawaii
P.O. Box 621
Honolulu, Hawaii 96809
Subject: Environmental Information Document Early Consultation Package for the
Pāhala LCC Closure
Pāhala, Hawaiʽi Island, Hawai‘i
Dear Mr. Chang:
Thank you for your letter dated October 20, 2023 regarding the subject Early Consultation Package for the
Pāhala LCC Closure. We acknowledge your comments and they have been considered in the preparation
of the EID. A record of your comments, along with this response, have been produced and are appended to
the EID in Appendix C.
As discussed in Section 5.5.2 of the EID the project area includes lands within Flood Zone X which
designates areas determined to be outside the 0.2- percent annual chance (500-year) floodplain.
Please note that the EID has been published and made available for review and comment on the County of
Hawaiʻi Department of Environmental Management website.
We appreciate your participation in the EID review process.
Sincerely,
Keola Cheng
Director – Planning
cc: Mr. Mark Grant
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
10349-08
March 14, 2024
Mr. Gordon Heit
Department of Land and Natural Resources – Land Division
State of Hawaii
P.O. Box 621
Honolulu, Hawaii 96809
Subject: Environmental Information Document Early Consultation Package for the
Pāhala LCC Closure
Pāhala, Hawaiʽi Island, Hawai‘i
Dear Mr. Heit:
Thank you for your letter dated October 26, 2023 regarding the subject Early Consultation Package for the
Pāhala LCC Closure. We acknowledge that the Department of Land and Natural Resources Land Division
–Hawaiʻi District has no comments regarding the subject EID. A record of your comments, along with this
response, have been produced and are appended to the EID in Appendix C.
Please note that the EID has been published and made available for review and comment on the County of
Hawaiʻi Department of Environmental Management website.
We appreciate your participation in the EID review process.
Sincerely,
Keola Cheng
Director – Planning
cc: Mr. Mark Grant
JOSH GREEN, M.D.
GOVERNOR | KE
SYLVIA LUKE
LIEUTENANT GOVERNOR |
DAWN N. S. CHANG
CHAIRPERSON
BOARD OF LAND AND NATURAL RESOURCES
COMMISSION ON WATER RESOURCE
MANAGEMENT
DEPARTMENT OF LAND AND NATURAL RESOURCES
LAND DIVISION
P.O. BOX 621
HONOLULU, HAWAII 96809
November 9, 2023
Wilson Okamoto Corporation
Attn: Mr. Keola Cheng via email: publiccomment@wilsonokamoto.com
Director of Planning
1907 South Beretania Street, Suite 400
Honolulu, Hawaii 96826
Dear Mr. Cheng:
SUBJECT: Environmental Information Document Consultation Package for Pahala
Large Capacity Cesspool Closure located at Pahala, Island of Hawaii;
Numerous TMKs and Multiple Roadways in Pahala on behalf of County of
Hawaii, Department of Environmental Management
Thank you for the opportunity to review and comment on the subject matter. In addition
to our previous comments dated November 3, 2023, enclosed are comments from the Division of
Forestry & Wildlife on the subject matter. Should you have any questions, please feel free to
contact Darlene Nakamura at (808) 587-0417 or email: darlene.k.nakamura@hawaii.gov. Thank
you.
Sincerely,
Russell Y. Tsuji
Land Administrator
Enclosures
cc: Central Files
DIVISION OF FORESTRY AND WILDLIFE
1151 PUNCHBOWL STREET, ROOM 325
HONOLULU, HAWAII 96813
JOSH
GOVERNOR |
LIEUTENANT GOVERNOR |
CHAIRPERSON
BOARD OF LAND AND NATURAL RESOURCES
COMMISSION ON WATER RESOURCE
MANAGEMENT
FIRST DEPUTY
DEPUTY DIRECTOR - WATER
AQUATIC RESOURCES
BOATING AND OCEAN RECREATION
BUREAU OF CONVEYANCES
COMMISSION ON WATER RESOURCE
MANAGEMENT
CONSERVATION AND COASTAL LANDS
CONSERVATION AND RESOURCES
ENFORCEMENT
ENGINEERING
FORESTRY AND WILDLIFE
HISTORIC PRESERVATION
KAHOOLAWE ISLAND RESERVE COMMISSION
LAND
STATE PARKS
November 9, 2023
Log no. 4304
TO:RUSSELL Y. TSUJI, Administrator
Land Division
KATHRYN E. STANAWAY, Acting Wildlife Program Manager
Division of Forestry and Wildlife
The Department of Land and Natural Resources, Division of Forestry and Wildlife (DOFAW)
has received your request for comments on the Environmental Information Document (EID) for
the Proposed Pahala Large Capacity Cesspool (LCC) Closure located in the Ka’u district on
the island of Hawai’i. A portion of the Pahala community is serviced by a sewer system that
discharges sewage into two Large Capacity Cesspools (LCCs). The EPA and the County of
Hawai’i entered into an Administrative Order on Consent (AOC) to close the two existing
cesspools by 2026. The proposed action includes the construction of facilities that would allow
the county to close the two cesspools in Pahala and meet compliance requirements. The
alternatives for the proposed action include the following: a package plant and new collection
system (Alternative 1); a package plant connected to the existing collection system (Alternative
2); a maintenance contract model Individual Wastewater System (IWS) program (Alternative
3); and an operating permit model IWS (Alternative 4). Under Alternative 1 the County would
obtain a portion of TMK: 9-6-002:018 to construct a wastewater collection system, primarily
within the public right-of-way a to collect and convey sanitary waste from the currently
connected and accessible properties to the new treatment and disposal facility. Alternative 2
would include the measures in Alternative 1 with the addition of connecting the existing 80-
year-old collection system to the WWTP. Alternative 3 would involve the County issuing funds
as well as managing project construction of an Individual Wastewater System (IWS) which
would consist of a septic tank, disposal systems, and interconnecting piping between the IWS
and the existing dwelling. Alternative 4 would include the design under Alternative 3 with the
addition that homeowners would be responsible for maintenance and/or responding to trouble
calls, monitoring and record keeping of maintenance.
Thank you for allowing us to review the EID, DOFAW recommends the following measures be
included with the intent to avoid construction and operational impacts to State-listed species.
The State listed or Hawaiian Hoary Bat (Lasiurus cinereus semotus) could
potentially occur at or in the vicinity of the project and may roost in nearby trees. Any required
site clearing should be timed to avoid disturbance to bats during their birthing and pup rearing
season (June 1 through September 15). During this period woody plants greater than 15 feet
(4.6 meters) tall should not be disturbed, removed, or trimmed. Barbed wire should also be
avoided for any construction because bats can become ensnared and killed by such fencing
material during flight.
Artificial lighting can adversely impact seabirds that may pass through the area at night by
causing them to become disoriented. This disorientation can result in their collision with
manmade structures or the grounding of birds. For nighttime work that might be required,
DOFAW recommends that all lights used be fully shielded to minimize the attraction of
seabirds. Nighttime work that requires outdoor lighting should be avoided during the seabird
fledging season, from September 15 through December 15, when young seabirds make their
maiden voyage to sea.
If nighttime construction is required during the seabird fledgling season (September 15 to
December 15), we recommend that a qualified biologist be present at the project site to
monitor and assess the risk of seabirds being attracted or grounded due to the lighting. If
seabirds are seen circling around the area, lights should then be turned off. If a downed
seabird is detected, please follow DOFAW’s recommended response protocol by visiting
https://dlnr.hawaii.gov/wildlife/seabird-fallout-season/#response.Permanent lighting also poses
a risk of seabird attraction, and as such should be minimized or eliminated to protect seabird
flyways and preserve the night sky. For illustrations and guidance related to seabird-friendly
light styles that also protect seabirds and the dark starry skies of Hawai‘i please visit
https://dlnr.hawaii.gov/wildlife/files/2016/03/DOC439.pdf.
State-Himantopus mexicanus knudseni
waiian coot (Fulica alai), Branta sandvicensis)
could potentially occur at or in the vicinity of the proposed project site. It is against State law to
harm or harass these species. If any of these species are present during construction, all
activities within 100 feet (30 meters) should cease and the bird or birds should not be
approached. Work may continue after the bird or birds leave the area of their own accord. If a
nest is discovered at any point, please contact the Hawai’i Island Branch DOFAW Office at
(808) 974-4221 and establish a buffer zone around the nest.
DOFAW is concerned about the wastewater treatment facility attracting vulnerable birds to
areas that may host nonnative predators such as cats, rodents, and mongooses. We therefore
recommend taking action to minimize predator presence; i.e., remove cats, place bait stations
for rodents and mongoose, and provide covered trash receptacles. Implementing additional
mitigation measures is also recommended to avoid avian mortality during project design and
during operation for the long term.
The endemic pueo or Hawaiian Short-Eared Owl (Asio flammeus sandwichensis) could
potentially nest in the project area. Before any potential vegetative alteration, especially
ground-based disturbance, we recommend that line transect surveys are conducted during
crepuscular hours through the project area. If a pueo nest is discovered, a minimum buffer
distance of 100 meters from the nest should be established until chicks are capable of flight.
The State listed ‘io or Hawaiian Hawk (Buteo solitarius) may occur in the project vicinity. Prior
to undertaking vegetation clearing, DOFAW recommends that pre-construction surveys of the
area be conducted by a qualified biologist following appropriate survey methods (Gorressen et
al., 2008) to ensure no Hawaiian Hawk nests are present, which may occur during the
breeding season from March to September. The survey should be conducted at least 10 days
feet) should be established around it where no construction shall occur until the chick or chicks
have fledged, or the nest is abandoned and DOFAW staff should be immediately notified. If
adult individuals are detected in the area during construction, all activities within 30 meters
(100 feet) of the bird should cease. Work may continue when the bird has left the area on its
own.
The project area is within the range of the State listed Blackburn’s Sphinx Moth (Manduca
blackburni) or BSM. Larvae of BSM feed on many nonnative hostplants, which includes tree
tobacco (Nicotiana glauca), that grow in disturbed soil. We recommend contacting the
Island Branch DOFAW office at (808) 974-4221 for further information about where BSM may
be present and whether a vegetation survey should be conducted to determine the presence of
plants preferred by BSM. DOFAW recommends removing plants less than one meter in height
or during the dry season to avoid harm to BSM. If you intend to either remove tree tobacco
over one meter in height or to disturb the ground around or within several meters of these
plants, they must be thoroughly inspected by a qualified entomologist for the presence of BSM
eggs and larvae.
DOFAW recommends using native plant species for landscaping that are appropriate for the
area; i.e., plants for which climate conditions are suitable for them to thrive, plants that
historically occurred there, etc. Please do not plant invasive species. DOFAW also
recommends referring to www.plantpono.org for guidance on the selection and evaluation of
landscaping plants and to determine the potential invasiveness of plants proposed for use in
the project.
DOFAW recommends minimizing the movement of plant or soil material between
worksites. Soil and plant material may contain detrimental fungal pathogens (e.g., Rapid
Death), vertebrate and invertebrate pests (e.g., Little Fire Ants, Coqui Frogs, etc.), or
invasive plant parts (e.g., African Tulip, Octopus Tree, Trumpet Tree, etc.) that could harm our
native species and ecosystems. We recommend consulting the Big Island Invasive Species
Committee (BIISC) at (808) 933-3340 to help plan, design, and construct the project, learn of
any high-risk invasive species in the area, and ways to mitigate their spread. All equipment,
materials, and personnel should be cleaned of excess soil and debris to minimize the risk of
spreading invasive species.
a Death (ROD), DOFAW requests that the information and
project site that will be removed, trimmed, or potentially injured:
https://cms.ctahr.hawaii.edu/rod.
1 Gorresen, P. M., R. J. Camp, J. L. Klavitter, and T. K. Pratt. 2008. Abundance, distribution and population trend of the
Hawaiian Hawk: 1998-2007. Hawai`i Cooperative Studies Unit Technical Report HCSU-009. University of Hawai`i at Hilo. 53
pp., incl. 8 figures, 3 tables & 1 appendix.
Due to the arid climate and risks of wildfire to listed species, we recommend coordinating with
-0900 or
admin@hawaiiwildfire.org, on how wildfire prevention can be addressed in the project area.
When engaging in activities that have a high risk of starting a wildfire (i.e. welding in grass), it
is recommended that you:
area as needed,
We appreciate your efforts to work with our office for the conservation of our native species.
These comments are general guidelines and should not be considered comprehensive for this
site or project. It is the responsibility of the applicant to do their own due diligence to avoid any
negative environmental impacts. Should the scope of the project change significantly, or
should it become apparent that threatened or endangered species may be impacted, please
contact our staff as soon as possible. If you have any questions, please contact Myrna N.
Girald Pérez, Protected Species Habitat Conservation Planning Coordinator at (808) 265-3276
or myrna.girald-perez@hawaii.gov.
Sincerely,
KATHRYN E. STANAWAY
Acting Wildlife Program Manager
Avoidance, Minimization, and Conservation Measures for listed plants in the Pacific Islands
Project activities may affect listed plant species by causing physical damage to plant parts (roots, stems, flowers, fruits, seeds, etc.) as
well as impacts to other life requisite features of their habitat, which may result in reduction of germination, growth and/or
reproduction. Cutting and removal of vegetation surrounding listed plants has the potential to alter microsite conditions (e.g., light,
moisture, temperature), damaging or destroying the listed plants and also increasing the risk of invasion by nonnative plants, which
can result in higher incidence or intensity of fire. Activities such as grazing, use of construction equipment and vehicles, and increased
human traffic (i.e., trails, visitation, monitoring), can cause ground disturbance, erosion, and/or soil compaction, which decrease
absorption of water and nutrients and damage plant root systems and may result in reduced growth and/or mortality of listed plants.
Soil disturbance or removal has the potential to negatively impact the soil seed bank of listed plant species if such species are present
or historically occurred in the project area.
In order to avoid or minimize potential adverse effects to listed plants that may occur on the proposed project site, we recommend
minimizing disturbance outside of existing developed or otherwise modified areas. When disturbance outside existing developed or
modified sites is proposed, conduct a botanical survey for listed plant species within the project action area, defined as the area where
direct and indirect effects are likely to occur. Surveys should be conducted by a knowledgeable botanist with documented experience
in identifying native Hawaiian and Pacific Islands plants, including listed plant species. Botanical surveys should optimally be
conducted during the wettest part of the year (typically October to April) when plants and identifying features are more likely to be
visible, especially in drier areas. If surveys are conducted outside of the wet season, the Service may assume plant presence.
The boundary of the area occupied by listed plants should be marked with flagging by the surveyor. To avoid or minimize potential
adverse effects to listed plants, we recommend adherence to buffer distances for the activities in the Table below. Where disturbed
areas do not need to be maintained as an open area, restore disturbed areas using native plants as appropriate for the location.
Whenever possible we recommend using native plants for landscaping purposes. The following websites are good resources to use
when choosing landscaping plants: Landscape Industry Council of Hawai‘i Native Plant Poster
(https://hawaiiscape.com/Publications), Native Hawaiian Plants for Landscaping, Conservation, and Reforestation
(https://www.ctahr.hawaii.edu/oc/freepubs/pdf/of-30.pdf), and Best Native Plants for Landscapes
(https://www.ctahr.hawaii.edu/oc/freepubs/pdf/OF-40.pdf).
If listed plants occur in a project area, the avoidance buffers are recommended to reduce direct and indirect impacts to listed plants
from project activities. However, where project activities will occur within the recommended buffer distances, additional consultation
is required. The impacts to the plants of concern within the buffer area may be reduced by placing temporary fencing or other barriers
at the boundary of the disturbance, as far from the affected plants as practicable.
The above guidelines apply to areas outside of designated critical habitat. If project activities occur within designated critical habitat
unit boundaries, additional consultation is required.
All activities, including site surveys, risk introducing nonnative species into project areas. Specific attention needs to be made to
ensure that all equipment, personnel, and supplies are properly checked and are free of contamination (weed seeds, organic matter, or
other contaminants) before entering project areas. Quarantines and or management activities occurring on specific priority invasive
species proximal to project areas need to be considered or adequately addressed. This information can be acquired by contacting local
experts such as those on local invasive species committees (Kauaʻi: https://www.kauaiisc.org/; Oʻahu: https://www.oahuisc.org/; Maui
Nui: https://mauiinvasive.org/; and Hawaiʻi: https://www.biisc.org/
Table 1. Recommended buffer distances to minimize and avoid potential adverse impacts to listed plants from activities listed below.
Action
Buffer Distance (feet (meters)) – Keep Project Activity This
Far Away from Listed Plant
Grasses/Herbs/Shrubs and
Terrestrial Orchids Trees and Arboreal Orchids
Walking, hiking, surveys 3 ft (1 m) 3 ft (1 m)
Cutting and Removing Vegetation By Hand or Hand Tools
(e.g., weeding) 3 ft (1 m) 3 ft (1 m)
Mechanical Removal of Individual Plants or Woody
Vegetation (e.g., chainsaw, weed eater)
3 ft up to height of removed
vegetation (whichever greater)
3 ft up to height of removed
vegetation (whichever greater)
Removal of Vegetation with Heavy Equipment (e.g.,
bulldozer, tractor, “bush hog”)
2x width equipment +
height of vegetation 820 ft (250 m)
Action
Buffer Distance (feet (meters)) – Keep Project Activity This
Far Away from Listed Plant
Grasses/Herbs/Shrubs and
Terrestrial Orchids Trees and Arboreal Orchids
Use of Approved
Herbicides
(following label)
Ground-based Spray Application;
hand application (no wand applicator;
spot treatment)
10 ft (3 m) Crown diameter
Ground-based Spray Application;
manual pump with wand, backpack 50 ft (15 m) Crown diameter
Ground-based Spray Application;
vehicle-mounted tank sprayer 50 ft (15 m) Crown diameter
Aerial Spray (ball applicator) 250 ft (76 m) 250 ft (76 m)
Aerial Application – herbicide ballistic
technology (individual plant treatment) 100 ft (30 m) Crown diameter
Aerial Spray (boom) Further consultation required Further consultation required
Use of Insecticides (pollinators, seed dispersers) Further consultation required Further consultation required
Ground/Soil Disturbance/Outplanting/Fencing (Hand tools,
e.g., shovel, ʻōʻō; Small mechanized tools, e.g., auger) 20 ft (6 m) 2x crown diameter
Ground/Soil Disturbance (Heavy Equipment) 328 ft (100 m) 820 ft (250 m)
Surface Hardening/Soil
compaction
Trails (e.g., human, ungulates) 20 ft (6 m) 2x crown diameter
Roads/Utility Corridors,
Buildings/Structures 328 ft (100 m) 820 ft (250 m)
Action
Buffer Distance (feet (meters)) – Keep Project Activity This
Far Away from Listed Plant
Grasses/Herbs/Shrubs and
Terrestrial Orchids Trees and Arboreal Orchids
Prescribed Burns Further consultation required Further consultation required
Farming/Ranching/Silviculture 820 ft (250 m) 820 ft (250 m)
Definitions (Wagner et al. 1999)
Crown: The leafy top of a tree.
Herb: A plant, either annual, biennial, or perennial, with the non-woody stems dying back to the ground at the end of the growing
season.
Shrub: A perennial woody plant with usually several to numerous primary stems arising from or relatively near the ground.
Tree: A woody perennial that usually has a single trunk
References Cited
USFWS. 2010. Endangered and threatened wildlife and plants; determination of endangered
status for 48 species on Kauai and designation of critical habitat. Federal Register 75:
18960−19165.
. 2012. Endangered and threatened wildlife and plants; endangered status for 23 species
on Oahu and designation of critical habitat for 124 species; final rule. Federal Register
77: 57648−57862.
. 2013a Endangered and threatened wildlife and plants; determination of endangered
status for 38 species from Molokai, Lanai, and Maui. Federal Register 78: 32014−32065.
. 2013b. Endangered and threatened wildlife and plants; determination of endangered
species status for 15 species on Hawaii Island. Federal Register 78: 64638−64690.
. 2016. Endangered and threatened wildlife and plants; determination of endangered
status for 49 species from the Hawaiian Islands. Federal Register 81: 67786−67860.
. 2016. USFWS Rare plant database. Unpublished.
Wagner, W.L., Sohmer, S., and D.R. Herbst. 1999. Manual of the flowering plants of Hawaii,
revised edition. Honolulu, Hawaii. University of Hawaii and Bishop Museum Press.
1,919 pp.
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
10349-08
March 14, 2024
Ms. Kathryn Stanaway
Department of Land and Natural Resources
Division of Forestry and Wildlife
State of Hawaii
P.O. Box 621
Honolulu, Hawaii 96809
Subject: Environmental Information Document Early Consultation Package for the
Pāhala LCC Closure
Pāhala, Hawaiʽi Island, Hawai‘i
Dear Ms. Stanaway:
Thank you for your letter dated November 9, 2023 regarding the subject Early Consultation Package for
the Pāhala LCC Closure. We acknowledge your comments and they have been considered in the preparation
of the EID. A record of your comments, along with this response, have been produced and are appended to
the EID in Appendix C.
As discussed in Section 5.6 of the EID, multiple botanical and biological field surveys have been conducted
within the project area. Based on the findings of the field surveys, construction activities associated with
the project are not anticipated to result in adverse impacts to botanical and faunal resources in the
Pāhala area; however, the recommended mitigation measures shall be implemented in order to avoid any
potential impact to these resources.
Please note that the EID has been published and made available for review and comment on the County of
Hawaiʻi Department of Environmental Management website.
We appreciate your participation in the EID review process.
Sincerely,
Keola Cheng
Director – Planning
cc: Mr. Mark Grant
STATE OF HAWAI I
DEPARTMENT OF HEALTH
KA OIHANA OLAKINO
P. O. BOX 3378
HONOLULU, HI 96801-3378
6646 3 9 6 002 018 EID
P hala LCC Closure
November 22, 2023
Mr. Keola Cheng
Director of Planning
Wilson Okamoto Corporation
1907 South Beretania Street Suite 400
Honolulu, Hawaii 96826
Email: publiccomment@wilsonokamoto.com
Dear Mr. Cheng:
Subject: Environmental Information Document Consultation Package for
P hala LCC Closure
TMK (3) 9-6-002: 018
Thank you for allowing us the opportunity to provide comments for the subject document.
If the subject project is funded by the State of Hawaii Clean Water State Revolving Fund (CWSRF)
Program, the following would apply.
1. For Alternative #1, the project would need to comply with the Hawaii State
Environmental Review Process (SERP) and include all applicable federal
environmental cross-cutting authorities. The SERP may be found on the following
website: https://health.hawaii.gov/wastewater/files/2018/06/serp.pdf.
2. For Alternative #2, the project would need to comply with the SERP and include all
applicable federal environmental cross-cutting authorities.
3. For Alternative #3, no other information is needed. Environmental review and
addressing applicable federal environmental cross-cutting authorities not required.
4. For Alternative #4, no other information is needed. Environmental review and
addressing applicable federal environmental cross-cutting authorities not required.
Please be informed that the proposed wastewater systems for the subdivision/development may have
to include design considerations to address any effects associated with the construction of and/or
discharges from the wastewater systems to any public trust, Native Hawaiian resources, or the
exercise of traditional cultural practices. All wastewater plans must conform to applicable provisions
of the Hawaii Administrative Rules, Chapter 11-62, Wastewater Systems.
JOSH GREEN, M.D.
GOVERNOR OF HAWAI I
KE KIA INA O KA MOKU INA O HAWAI I
KENNETH S. FINK, MD, MGA, MPH
DIRECTOR OF HEALTH
KA LUNA HO OKELE
In reply, please refer to:
File:
Mr. Cheng
November 22, 2023
Page 2
Should you have any questions, please call Mr. Chane Hayashida of my staff at (808) 586-4294.
Sincerely,
SINA PRUDER, P.E., CHIEF
Wastewater Branch
LM/MST:ct
c: Ms. Kaylin Enos (via email)
Mr. Chane Hayashida (via email)
Ms. Ciely Oda (via email)
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
10349-08
March 14, 2024
Ms. Sina Pruder
Department of Health – Wastewater Branch
State of Hawaii
P.O. Box 3378
Honolulu, HI 96801
Subject: Environmental Information Document Early Consultation Package for the
Pāhala LCC Closure
Pāhala, Hawaiʽi Island, Hawai‘i
Dear Ms. Pruder:
Thank you for your letter dated November 22, 2023 regarding the subject Early Consultation Package for
the Pāhala LCC Closure. We acknowledge your comments and they have been considered in the preparation
of the EID. A record of your comments, along with this response, have been produced and are appended to
the EID in Appendix C.
As the subject project will be funded by the State of Hawaiʻi Clean Water State Revolving Fund (CWSRF)
Program, we acknowledge that Alternative #1 and Alternative #2 would be required to comply with the
Hawaiʻi State Environmental Review Process. The EID discusses previous environmental review efforts
for the subject project as well as compliance with various federal cross-cutting authorities.
Please note that the EID has been published and made available for review and comment on the County of
Hawaiʻi Department of Environmental Management website.
We appreciate your participation in the EID review process.
Sincerely,
Keola Cheng
Director – Planning
cc: Mr. Mark Grant
From:Cole, Colleen
To:Public Comment
Cc:Asman, Lindsy; PIFWO_Admin, FW1
Subject:Request for comments for proposed Pāhala Large Capacity Cesspool Closure project
Date:Monday, October 23, 2023 10:54:38 AM
Attachments:IPaC Info Letter_Species List Instructions_PIFWO_20Apr2022_Final.pdf
Hawaiianhoarybat-HawaiianHoaryBat.pdf
Hawaiianseabirds-HawaiianPetrelAnd2MoreSpecies.pdf
Hawaiianwaterbirds-HawaiianDuckAnd3MoreSpecies.pdf
Plant Avoidance and Minimization Measures_FINAL_May 2023.docx
Aloha Keola Cheng,
The Pacific Islands Fish and Wildlife Office received your request for comments on the
proposed Pāhala Large Capacity Cesspool Closure project located in the Kaʻū District on
Hawaiʻi Island. We reviewed the proposed project summarized in the Environmental
Information Document you provided. At this time, we recommend that the project planning
for any of the four alternative actions include avoidance and minimization measures (AMMs)
for endangered species that may be affected by project activities.
You can obtain an official species list in the Information for Planning and Consultation (IPaC)
online tool. Please see the attached pdf with detailed directions on how you obtain an official
species list in IPAC.
Once you have entered basic project information, including a map of the project, IPaC will
generate a species list comprised of all federally listed species that may occur in the project
area. Each species includes a link in which you will find avoidance and minimization measures
(AMMs) for that species.
Attached to this email are AMMs that you will likely encounter when you obtain an official
species list for the project.
Please feel free to contact me if you need additional assistance.
Mahalo,
Colleen Cole
Biologist - Maui Nui & Hawaiʻi Island Team
IPaC: Information for Planningand Consultation
IPaC is a project planning tool that streamlinesthe USFWS environmental review process.
ipac.ecosphere.fws.gov
Pacific Islands Fish and Wildlife OfficeU.S. Fish and Wildlife Service154 Waiānuenue Avenue Suite 103PO Box 10225Hilo, Hawaiʻi 96720-2452Cell Phone: 808-859-1002Email: colleen_cole@fws.gov
IPaC - Information for Planning and Consultation (https://ipac.ecosphere.fws.gov/): A project planning tool to help streamline the
U.S. Fish and Wildlife Service environmental review process.
U.S. Fish & Wildlife Service
Hawaiian hoary bat
Hawaiian Hoary Bat
Generated October 18, 2023 08:52 PM UTC, IPaC v6.99.0-rc3
Hawaiian hoary bat (Lasiurus cinereus semotus): The Hawaiian hoary bat roosts in both
exotic and native woody vegetation across all islands and will leave young unattended in trees
and shrubs when they forage. If trees or shrubs 15 feet or taller are cleared during the pupping
season, there is a risk that young bats could inadvertently be harmed or killed since they are too
young to fly or may not move away. Additionally, Hawaiian hoary bats forage for insects from
as low as 3 feet to higher than 500 feet above the ground and can become entangled in barbed
wire used for fencing.
To avoid and minimize impacts to the endangered Hawaiian hoary bat we recommend you
incorporate the following applicable measures into your project description:
• Do not disturb, remove, or trim woody plants greater than 15 feet tall during the bat
birthing and pup rearing season (June 1 through September 15).
• Do not use barbed wire for fencing.
Pacific Islands Fish And Wildlife Office - Publication Date: March 1, 2020
General Project Design Guidelines - Hawaiian Hoary Bat
10/18/2023 8:52 PM IPaC v6.99.0-rc3 Page 1
IPaC - Information for Planning and Consultation (https://ipac.ecosphere.fws.gov/): A project planning tool to help streamline the
U.S. Fish and Wildlife Service environmental review process.
U.S. Fish & Wildlife Service
Hawaiian seabirds
Hawaiian Petrel and 2 more species
Generated October 18, 2023 08:40 PM UTC, IPaC v6.99.0-rc3
General Project Design Guidelines - Hawaiian Petrel
and 2 more species
Published by Pacific Islands Fish And Wildlife Office - Publication Date: February 1, 2022 for the following species included in
your project
Hawaiian Petrel Pterodroma sandwichensis
Newell's Townsend's Shearwater Puffinus auricularis newelli
Band-rumped Storm-petrel Oceanodroma castro
Endangered Hawaiian petrel (Pterodroma sandwichensis), Threatened Newell’s shearwater
(Puffinus auricularis newelli), and Endangered Hawaii Distinct Population Segment of the
band-rumped storm-petrel (Oceanodroma castro):
Hawaiian seabirds may traverse the project area at night during the breeding, nesting and
fledging seasons (March 1 to December 15). Outdoor lighting could result in seabird
disorientation, fallout, and injury or mortality. Seabirds are attracted to lights and after circling
the lights they may become exhausted and collide with nearby wires, buildings, or other
structures or they may land on the ground. Downed seabirds are subject to increased mortality
due to collision with automobiles, starvation, and predation by dogs, cats, and other predators.
Young birds (fledglings) traversing the project area between September 15 and December 15, in
their first flights from their mountain nests to the sea, are particularly vulnerable to light
attraction.
To avoid and minimize potential project impacts to seabirds we recommend you incorporate the
following measures into your project description:
• Fully shield all outdoor lights so the bulb can only be seen from below.
• Install automatic motion sensor switches and controls on all outdoor lights or turn off
lights when human activity is not occurring in the lighted area.
• Avoid nighttime construction during the seabird fledging period, September 15 through
December 15.
Listed seabirds have been documented colliding with communication towers, particularly in
areas of high seabird passage rate. In general, self-supporting monopoles are the least likely to
result in collisions, whereas lattice towers, particularly those that rely on guy-wires, have a
greater risk.
To avoid and minimize the likelihood that towers will result in collisions by listed seabirds we
recommend you incorporate the following measures into your project description:
• The profile of the tower should be as small as possible, minimize the extent of the tower
that protrudes above the surrounding vegetation layer, and avoid the use of guywires.
• If the top of the tower must be lit to comply with Federal Aviation Administration
regulations, use a flashing red light verses a steady-beam red or white light.
• If possible, co-locate with existing towers or facilities.
Seabirds have been known to collide with fences, powerlines, and other structures near nesting
colonies. To avoid and minimize the likelihood of collision we recommend you incorporate the
following measures into your project description:
• Where fences extend above vegetation, integrate three strands of polytape into the fence
to increase visibility.
• For powerlines, guywires and other cables, minimize exposure above vegetation height
and vertical profile.
Pacific Islands Fish And Wildlife Office - Publication Date: February 1, 2022
General Project Design Guidelines - Hawaiian Petrel and 2 more species
10/18/2023 8:40 PM IPaC v6.99.0-rc3 Page 2
IPaC - Information for Planning and Consultation (https://ipac.ecosphere.fws.gov/): A project planning tool to help streamline the
U.S. Fish and Wildlife Service environmental review process.
U.S. Fish & Wildlife Service
Hawaiian waterbirds
Hawaiian Duck and 3 more species
Generated October 18, 2023 08:41 PM UTC, IPaC v6.99.0-rc3
General Project Design Guidelines - Hawaiian Duck
and 3 more species
Published by Pacific Islands Fish And Wildlife Office - Publication Date: February 1, 2022 for the following species included in
your project
Hawaiian Duck Anas wyvilliana
Hawaiian Common Gallinule Gallinula galeata sandvicensis
Hawaiian Stilt Himantopus mexicanus knudseni
Hawaiian Coot Fulica alai
Hawaiian waterbirds (Hawaiian stilt, Himantopus mexicanus knudseni; Hawaiian coot,
Fulica alai; Hawaiian common gallinule, Gallinula galeata sandvicensis; Hawaiian duck,
Anas wyvilliana):
Listed Hawaiian waterbirds are found in fresh and brackish-water marshes and natural or man-
made ponds. Hawaiian stilts may also be found wherever ephemeral or persistent standing water
may occur. Threats to these species include non-native predators, habitat loss, and habitat
degradation. Hawaiian ducks are also subject to threats from hybridization with introduced
mallards.
The creation of standing or open water may result in the attraction of Hawaiian waterbirds to a
site (creative nuisance or habitat sink). In particular, the Hawaiian stilt is known to nest in sub-
optimal locations (e.g. any ponding water), if water is present. Hawaiian waterbirds attracted to
sub-optimal habitat may suffer adverse impacts, such as predation and reduced reproductive
success, and thus the project may create an attractive nuisance. Therefore, we recommend you
work with our office during project planning so that we may assist you in developing measures
to avoid impacts to listed species (e.g., fencing, vegetation control, predator management).
To avoid and minimize potential project impacts to Hawaiian waterbirds we recommend you
incorporate the following applicable measures into your project description:
•In areas where waterbirds are known to be present, post and enforce reduced speed limits,
and inform project personnel and contractors about the presence of endangered species
on-site.
•Incorporate the Service’s Best Management Practices for Work in Aquatic Environments
into the project design.
•Have a biological monitor that is familiar with the species’ biology conduct Hawaiian
waterbird nest surveys, where appropriate habitat occurs within the vicinity of the
proposed project site, prior to project initiation. Repeat surveys again within 3 days of
project initiation and after any subsequent delay of work of 3 or more days (during which
the birds may attempt to nest). If a nest or active brood is found:
o Contact the Service within 48 hours for further guidance.
o Establish and maintain a 100-foot buffer around all active nests and/or broods
until the chicks/ducklings have fledged. Do not conduct potentially disruptive
activities or habitat alteration within this buffer.
o Have a biological monitor that is familiar with the species’ biology present on
the project site during all construction or earth moving activities until the
chicks/ducklings fledge to ensure that Hawaiian waterbirds and nests are not
adversely impacted.
Pacific Islands Fish And Wildlife Office - Publication Date: February 1, 2022
General Project Design Guidelines - Hawaiian Duck and 3 more species
10/18/2023 8:42 PM IPaC v6.99.0-rc3 Page 2
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
10349-08
March 14, 2024
Ms. Colleen Cole
Pacific Islands Fish and Wildlife Office
U.S. Fish and Wildlife Service
154 Waiānuenue Avenue, Suite 103
Hilo, Hawaiʻi 96720
Subject: Environmental Information Document Early Consultation Package for the
Pāhala LCC Closure
Pāhala, Hawaiʽi Island, Hawai‘i
Dear Ms. Cole:
Thank you for your letter dated October 23, 2023 regarding the subject Early Consultation Package for the
Pāhala LCC Closure. We acknowledge your comments and they have been considered in the preparation
of the EID. A record of your comments, along with this response, have been produced and are appended to
the EID in Appendix C.
As discussed in Section 5.6 of the EID, multiple botanical and biological field surveys have been conducted
within the project area. Based on the findings of the field surveys, construction activities associated with
the project are not anticipated to result in adverse impacts to botanical and faunal resources in the
Pāhala area; however, the recommended mitigation measures shall be implemented in order to avoid any
potential impact to these resources.
Please note that the EID has been published and made available for review and comment on the County of
Hawaiʻi Department of Environmental Management website.
We appreciate your participation in the EID review process.
Sincerely,
Keola Cheng
Director – Planning
cc: Mr. Mark Grant
Appendix D
Public Outreach Materials
PA-HALA WASTEWATER PUBLIC MEETING AND
PUBLIC COMMENT PERIOD
The County of Hawai‘i Department of
Environmental Management announces the
availability of the Amended Draft Environmental
Information Document (EID) and public
comment period until April 15, 2024,
regarding the closure of the large capacity
cesspools in Pa-hala.
The County is accepting comment on
its tentative identification of a package
wastewater treatment plant with new collection
system as the preferred option. The Draft EID
is available at the Pa-hala Public Library and at
the website address below. The community is
invited to participate at an upcoming meeting:
WHEN: 6 p.m. Wednesday, April 10
WHERE: Pa-hala Community Center,
96-1149 Kamani Street
ONLINE:
https://www.zoomgov.com/j/16031058165
For questions call (808) 961-8099 or email
cohdem@hawaiicounty.gov
https://www.dem.hawaiicounty.gov/
projects/pahala-na-alehu-large-capacity-
cesspool-closures
Wastewater Public Meeting
for Pāhala
The Department of Environmental Management of the County of
Hawai‘i will accept public input on the Revised Draft
Environmental Information Document for the Pāhala Large
Capacity Cesspool Closure Project and the County’s selection of a
new package plant and new collection system.
Pāhala Community Center
96-1149 Kamani Street
Wednesday, April 10, 2024
6 p.m. start
Online:
https://www.zoomgov.com/j/16031058165
• Public comment period March 15-April 15, 2024
• Revised Draft EID is available at the Pāhala Public and
School Library and at dem.hawaiicounty.gov/projects
Contact: (808) 961-8099
cohdem@hawaiicounty.gov
The regular meeting place is accessible to persons with disabilities.
(This page intentionally left blank)
Environmental Information Document
Pahala Large Capacity Cesspool Closure