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COUNTY OF HAWAI‘I PLANNING DEPARTMENT
BACKGROUND REPORT
COUNTY OF HAWAIʻI DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
SPECIAL PERMIT APPLICATION (PL-SPP-2025-000093)
COUNTY OF HAWAIʻI DEPARTMENT OF ENVIRONMENTAL MANAGEMENT is
requesting a Special Permit to construct and operate a new County-owned wastewater treatment
plant facility on an approximately 14.9-acre portion of a larger 42.5-acre parcel in the State Land
Use Agricultural District. The subject property is located at 96-3303 Maile Street, east of Maile
Street and mauka of Hawaiʻi Belt Road, Punaluʻu-Pāʻauʻau, Pāhala, Kaʻū, Hawaiʻi, TMK: (3) 9-
6-002:018 (por.).
APPLICANTS’ REQUEST
1. Request: The applicant is requesting a Special Permit to construct and operate a County-
owned wastewater treatment plant (WWTP) facility, designed as a package plant to treat
sewage currently being disposed of in 2 existing large capacity cesspools (LCCs), with
operations including preliminary treatment, odor control, secondary treatment and disposal
of the treated effluent. See pages 5-12 of the Application for a detailed description of the
treatment process and collection system. The proposed facility will include the following
(see Exhibit A of the Application for Project Figures and Site Plans):
• A security fence around the perimeter of the 14.9-acre permit area
• Package plant headworks
• Dewatering equipment
• Grit drying bed
• Potable water tank
• Utility operations building, including an emergency generator room and an
electrical room with a monitor control center
• Maintenance and storage room
• Restrooms
• Above ground fuel storage tank
• Irrigation control tank, designed with capacity for future expansion within the
permit area
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The 14.9-acre permit area does not include an existing 1,500-foot-long by 25-foot-wide
utility easement on the subject property and does not include work within the County Road
rights-of-way for the collection system given that public utilities are a permissible use
within the State Land Use Agricultural District per HRS 205-4.5(7).
2. Staffing/Employees: The applicant notes that staffing projections are not yet completed,
however it’s expected that the WWTP will be staffed by up to 2 supervisors with additional
staff present for repair and maintenance of equipment.
3. Hours of Operation: The WWTP will operate daily from 7:00 AM to 3:30 PM.
4. Reason for Request: 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 into two (2) large capacity cesspools (LCCs).
Around 2006, C. Brewer requested that the County of Hawaiʻi (County) Department of
Environmental Management (DEM) 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 construct and maintain a new and improved community
sewer system and to also 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 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 1999, the U.S. Environmental Protection Agency (EPA) issued
regulations under the Safe Drinking Water Act’s (SDWA) Underground Injection Control
(UIC) Program which prohibited the construction of new LCCs and required the closure of
all existing LCCs by April 5, 2005. In June 2017, EPA and the County entered into an
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Administrative Order of Consent (AOC) to close the LCCs serving the Pāhala community
by June 2021. Since then, the EPA and DEM have worked together to complete an
environmental document that identified and assessed a total of 4 feasible options for closing
the LCC’s and 9 alternative sites for location of the WWTP, with the subject 14.9-acre
permit area selected as the preferred alternative for construction of the new WWTP. The
EPA and DEM entered several amended AOC’s with the most recently amended AOC
requiring the LCCs to be closed no later than January 22, 2027.
5. Landowner: B. P. Bishop Estate Trustees, who has authorized the County to use the
subject property for the proposed use. According to the DEM, the County will complete a
process of condemnation and an order for possession of the 14.9-acre permit area, which
will be subdivided from the larger property.
6. Chapter 343, HRS: The proposed improvements are subject to the requirements of
Chapter 343, Hawaiʻi Revised Statutes, regarding Environmental Impact Statements,
because work is proposed using State and County funds. A Final Environmental
Assessment (FEA) (see page 45 of the Application) was prepared for the project and
published in the March 8, 2020 issue of the State Environmental Review Program’s The
Environmental Notice. On February 24, 2020, the DEM issued a Finding of No Significant
Impact (FONSI) Notice (Joint NEPA/HEPA) for the project. Subsequently, an amended
Administrative Order of Consent (AOC), dated August 22, 2022, between the
Environmental Protection Agency (EPA) and the County required submittal of an
Environmental Information Document (EID) (see page 982 of the Application) for EPA
approval, which was completed in May 2024. The EID is intended to address State and
Federal environmental review requirements of the revised AOC, consistent with
requirements of the National Environmental Policy Act (NEPA), Section 7 of the
Endangered Species Act and Section 106 of the National Historic Preservation Act.
7. Supportive Information: A Special Permit is required to construct and operate a
wastewater treatment plant facility in the State Land Use Agricultural District. The
applicant has submitted the attached in support of the request. (Planning Department
Exhibit 1 – Special Permit Application received on June 18, 2025)
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STATE & COUNTY PLANS
8. State Land Use District: Agricultural.
9. General Plan Land Use Pattern Allocation (LUPAG) Map: The General Plan LUPAG
map classifies the subject property as Low Density Urban (ldu), which allows for
residential, with ancillary community and public uses, and neighborhood and convenience-
type commercial uses; overall residential density may be up to 6 units per acre.
10. County Zoning: Agricultural-20 acres (A-20a).
11. Kaʽū Community Development Plan (CDP): The Kaʽū CDP was adopted by Ordinance
No. 17-66, which became effective on October 17, 2017. The subject property is designated
Important Agricultural Lands in the Land Use Policy Map for Pāhala.
12. Special Management Area (SMA): The property is not within the County’s Special
Management Area and is located approximately 3.8 miles from the nearest shoreline.
13. Coastal Zone Management: The entire State of Hawai‘i lies within the Coastal Zone
Management area.
DESCRIPTION OF SUBJECT PROPERTY AND SURROUNDING AREA
14. Subject Property: The subject, 42.5-acre property contains an existing macadamia nut
orchard and a 1,500-foot long by 25-foot wide utility easement. Approximately 4 acres of
the existing macadamia nut orchard will be removed to accommodate the proposed
WWTP. The 14.9-acre permit area, which excludes the easement, is located at the
southeastern side of the property, near the intersection of Maile Street and Hawai‘i Belt
Road.
15. Surrounding Zoning/Land Uses: Properties surrounding the subject property to the west
and south are zoned Agricultural (A-20a and A-1a), with most used for macadamia nut
orchards. Properties further to the north are zoned Single-Family Residential (RS-7.5, RS-
10 and RS-15), Industrial (MG-1a), Light Industrial (ML-20) and Open with uses
consisting of agriculture, residential, and vacant lands. A macadamia nut processing
facility is located approximately 200 feet northeast of the permit area, on the adjacent
parcel, while the nearest residences of Pāhala town are located approximately 0.5 miles
north of the permit area.
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16. U.S.D.A. Soil Type: Soils within the permit area are classified Nāʻālehu medial silty clay
loam, 3 to 10 percent slopes. The Nāʻālehu series consists of deep and very deep, well
drained soils that formed in basic volcanic ash.
17. Land Study Bureau’s Detailed Land Classification System: Soils within the permit
area are classified as mostly “D” or “Poor” for agricultural productivity with a small
portion classified as “B” or “Good.”
18. Agricultural Lands of Importance to the State of Hawai’i (ALISH): Approximately
50% of the permit area is unclassified, with the remainder of the permit area about evenly
divided between Other Agricultural Lands and Prime Agricultural Lands.
19. Flood Insurance Rate Map (FIRM): The property is classified as Flood Zone “X,” (Area
of Minimal Flood Hazard) according to the FEMA Flood Insurance Rate Mapping system.
20. Flora/Fauna Resources: Two botanical studies were conducted at the subject property,
the first in August 2018 and the second in October 2023. Both studies indicated the
presence of two native species on the subject property, Ipomoea indica and Waltheria
indica, but concluded that listed or endangered plant species are unlikely to be encountered
or disturbed by the proposed use. Ornamental plants, macadamia nut trees and cook pines
are also present on the subject property. Biological field studies conducted in conjunction
with the botanical studies indicated the presence of feral pigs, rats and domestic dogs in
the vicinity of the subject property. Additionally, avian studies indicated the presence of
common introduced species such as House Sparrow, Zebra Dove, Northern Cardinal, and
Japanese White-eye and noted an incidental observation of the Hawaiian Hawk. Finally,
by letter dated February 15, 2019, the Fish and Wildlife Service concluded that the
proposed use 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.
21. Archaeological/Cultural/Historical Resources: An archeological field inspection,
conducted in November 2016, involved pedestrian sweeps of the subject property to
determine the presence of historic properties or significant archeological features. The
inspection report indicated that past ground disturbances associated with plantation era
construction and creation of the macadamia nut tree orchard had destroyed most pre-
contact sites or historic features that may have existed on the subject property. However,
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the report recommended an Archeological Inventory Survey (AIS) to fully document
surface artifacts and to test for the presence of subsurface cultural deposits. The County
conducted an AIS of the 14.9-acre permit area in September of 2018. Although
geotechnical investigations indicated the presence of a lava tube on a portion of the subject
property, the AIS confirmed no significant artifacts or cultural deposits were observed on
the ground surface of the permit area and that no cultural deposits or lava tubes were
encountered during subsurface trenching. In compliance with Section 106 of the National
Historic Preservation Act (NHPA), the County sent letters requesting comments from
various Native Hawaiian Organizations in 2018. In 2023, an Archeological Literature
Review Report concluded that surface pre-contact sites are not expected within the permit
area given the known traditional land use in the area and impacts of continued agricultural
and residential development. By letter dated February 20, 2020, SHPD provided
concurrence that no historic properties shall be affected by the proposed use, and an
Archeological Monitoring Plan was accepted by SHPD on November 4, 2020.
22. Public Access: There is no public access to the mountains or the shoreline that runs
through the property.
PUBLIC UTILITIES AND SERVICES
23. Access/Parking/Traffic: Access to the subject property is from Maile Street, a County-
owned, paved roadway. Designated parking within the permit area will be accessed by a
new 24-foot wide asphalt concrete driveway. According to the applicants, only facility
operators will visit the property and traffic impacts are not anticipated to be significant,
with traffic remaining consistent with current levels.
24. Water: By letter dated April 5, 2018, the Department of Water Supply (DWS) notes that
the subject property is not serviced by county water and that the nearest point of connection
to the DWS system is from an existing 6-inch waterline at the intersection of Huapala Street
and Maile Street, approximately 2,000 feet northeast of the subject property. DWS requests
the submittal of estimated maximum daily water usage calculations, prepared by a
professional engineer. Upon review, if water is available, a water commitment deposit will
be due and DWS will determine facilities charges, water systems improvements and other
conditions for final approval. DWS requests that construction plans show, and proposed
sewer lines be installed with the proper horizontal and vertical clearances from existing
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water system facilities and concrete jacketing at waterline crossings, per DWS Water
System Standards. Further, DWS requires backflow prevention devices to be installed at
water system connections for the facility. The applicant states that water will be provided
to the permit area by installing a service line to connect the facility to an extended water
main, subject to approval by DWS.
25. Wastewater: The subject property is not currently served by the county sewer system.
26. Solid Waste: According to DOH, solid waste shall be properly recycled or disposed of at
DOH-permitted solid waste facilities.
27. Essential Utilities and Services: Telephone and electricity are available to the site. Fire
services are located approximately 31 miles away in Volcano and police services are
located approximately 15 miles away in Na‘alehu.
AGENCY COMMENTS
28. State Department of Health: (Planning Department Exhibit 2 – July 11, 2025 Memo).
29. State Office of Planning & Sustainable Development: (Planning Department Exhibit
3 – July 28, 2025 Letter).
30. Department of Water Supply: (Planning Department Exhibit 4 – April 5, 2018
Letter).
AGENCIES – NO COMMENTS/NO CONCERNS
31. Police Department, State Department of Land and Natural Resources- Land Division
AGENCIES – NO RESPONSE
32. State Land Use Commission, State Department of Land and Natural Resources-
Engineering Division, State Department of Agriculture, Fire Department, Department of
Environmental Management, Department of Public Works- Engineering.
PUBLIC COMMENTS
33. The Department has not received any comments or objections from the public or adjacent
landowners at the time of this writing.
SPECIAL PERMIT APPLICATION
COUNTY OF HAWAIʻI PLANNING COMMISSION (Type or legibly print the requested information)
APPLICANT(S):
APPLICANT’S SIGNATURE: DATE:
ADDRESS:
LIST APPLICANT’S INTEREST (if not owner):
PHONE: (Bus.) (Res.) (Email)
REQUEST:
TAX MAP KEY(S): ZONING:
SIZE OF PROPERTY / AREA OF REQUESTED USE:
LANDOWNER(S):
FEE SIMPLE LANDOWNER(S) WRITTEN AUTHORIZATION
(may be provided by letter with the below statement included):
DATE:
DATE:
AGENT:
AGENT ADDRESS:
PHONE: (Bus.) (Res.) N/A (Email)
Please indicate to whom original correspondence and copies should be sent.
ORIGINAL: APPLICANT COPIES: AGENT
County of Hawai'i Department of Environmental Management
345 Kekūanāo‘a St., Suite 41
Hilo, HI 96720
9-6-002:018
14.9 acres42.5 acres
B. P. Bishop Estate Trustees
A-20a (Agricultural)
Owner and Operator of WWTP Facility
808-961-8083 cohdem@hawaiicounty.gov
County owned wastewater treatment plant facility
4/28/25
Wilson Okamoto Corporation
1907 S Beretania Street Suite 400 Honolulu, HI 96826
(808) 946- 2277 hmeyers@wilsonokamoto.com
Pāhala Large Capacity Cesspool Closure Special Permit Application
Pāhala Large Capacity Cesspool Closure Special Permit Application Page 1 of 20
1. Project Background
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 into two
(2) large capacity cesspools (LCCs). Around 2006, C. Brewer requested that the County of Hawaiʻi
(County) Department of Environmental Management (DEM) 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
construct and maintain a new and improved community sewer system and to also 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 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. EPA promulgated regulations, 40 Code of Federal Regulations (CFR) 144.14, that require
the elimination of 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 nonresidential facilities has the
capacity to serve 20 or more persons per day.
In June 2017, EPA and the County entered into an Administrative Order of 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 WWTP to address the wastewater treatment and disposal needs of
the Pāhala community.
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 State
of Hawai‘i Environmental Review Program’s The Environmental Notice. The Final EA assessed 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 nine (9) alternative sites were identified
and assessed before selecting the 14.9-acre project site for the 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
Pāhala Large Capacity Cesspool Closure Special Permit Application Page 2 of 20
an industry standard wastewater collection system and a secondary 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 (FONSI)
Notice (Joint NEPA/HEPA) for the Pāhala Large Capacity Cesspool Replacement Project. The basis for
this determination is set forth in Section 8.1.1 of the February 2020, Final EA, which followed 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 associated engineering design work, additional
geophysical/geotechnical investigations identified and confirmed a large subsurface lava tube extended
under the proposed aerated open 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.
As of August 22, 2022, the County and the EPA voluntarily entered into a Revised AOC for the purpose of
bringing the County into compliance with the requirements of the SDWA, 42 U.S.C. § 300f, et seq. The
County later entered an Amended AOC (effective February 14, 2024) with the U.S. EPA. The Amended
AOC required submittal of an Environmental Information Document (EID) for EPA approval by July 30,
2024. The recently Amended AOC requires the LCCs to be closed no later than January 22, 2027.
The Amended AOC §31.a. requires that the EID evaluate four feasible options for the closure of the LCCs:
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, the EID also included:
5. A No Action alternative (Alternative 5).
A copy of the Final EID and Final EA/FONSI shall be attached as exhibits to support this Special Permit
Application.
2. Purpose and Need
The U.S. EPA has determined that the County, as the current owner and/or operator of two (2) LCCs that
serve approximately 109 private residences in the community of Pāhala violated and continues to violate
the SDWA and its UIC program requirements for existing LCCs.
Based on the above, the County has outlined that the purpose and need for the Proposed Use 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 the EID served to evaluate, gather community input, and make an informed
decision on selecting one of the four alternatives that would 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.
Pāhala Large Capacity Cesspool Closure Special Permit Application Page 3 of 20
Unlike the original AOC, the Amended AOC no longer requires that the wastewater treatment plant
(WWTP) provide secondary treatment of the sewage. As such, the IWS alternatives were explored to
provide a method to close the two Large Capacity Cesspools (LCCs) without providing a secondary
treatment process. In the process of identifying a preferred alternative, extensive community engagement
was conducted, encompassing a series of meetings and discussions with the EPA. Preliminary Engineering
Reports (PER) have also been completed to assess the identified alternatives as discussed in the 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, DEM – WWD has tentatively
selected to construct a package plant and new collection system (Alternative 1) as the preferred alternative.
For more information, please refer to Appendix A of the Final EID.
3. Proposed Use
Under the selected 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.
3.1 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.
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 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.
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.
Pāhala Large Capacity Cesspool Closure Special Permit Application Page 4 of 20
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 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.
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-footwide 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 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
outlines the following conditions:
Pāhala Large Capacity Cesspool Closure Special Permit Application Page 5 of 20
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 that is recommended to be implemented
at Pāhala. Notably, 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+ acres 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, dewatering equipment, potable water tank, utility or
operations building which includes a , 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 narrative description of the proposed
improvements contained herein mirrors the recommendations set forth in the subject PER, however, the
CoH-DEM reserves the right / flexibility to utilize its discretion to utilize and implement alternative
methods / technologies / processes that it deems superior / equivalent in regards to meeting the purpose and
need of the Proposed Action.
3.1.1 Preliminary Treatment
The preliminary treatment system will generally include, but is not limited to the following elements /
components:
1) Influent Flow Measurement
Influent flow measurement equipment will be provided upstream of the screening system to allow the
assessment of flows and loads to the biological treatment process, and to assess the biological treatment
process performance.
2) Influent Sampling
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.
Pāhala Large Capacity Cesspool Closure Special Permit Application Page 6 of 20
3) Screening
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.
An in-channel cylindrical screen which combines screening, screenings washing, dewatering, compacting,
and bagging/disposal within a single unit was recommended for the WWTP. For this installation, the
headworks is anticipated to include one in-channel cylindrical screen, plus a bypass channel with manually
cleaned bar rack.
4) Grit Removal.
The 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.
Use of aerated grit chambers are recommended at the WWTP. Aerated grit chambers are tanks that function
specifically to remove inorganic solids from the wastewater stream. These 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. 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.
3.1.2 Odor Control
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.
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Initial iterative project design and planning efforts identified that a granular activated carbon (GAC)
scrubber would be recommended to 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.
Through this process, the 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.
Additional, and or other Odor Control measures may be potentially employed, contingent upon available
hardware / technologies at the time of project implementation.
3.1.3 Secondary Treatment
Secondary treatment process provides 5-day biochemical oxygen demand (BOD5), total suspended solids
(TSS) and nutrient removal via biological treatment. Based on an analysis of various secondary treatment
options including advantages, disadvantages and applicability to the Pahala WWTP, a membrane bioreactor
(MBR), activated sludge with anoxic selector, and recirculating gravel filter was recommended for use at
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.
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.
While the MBR has been recommended, it should be noted that the package unit that will be chosen to
provide secondary treatment at the Pāhala WWTP will be determined on the vendor’s ability to
accommodate performance specifics.
The proposed effluent management system (subsurface drip irrigation disposal) shall be treated for R-2
suitable uses. R-2 is considered to be the mid-tier of recycled water in which the wastewater has undergone
oxidation and disinfection. Suitable uses for R-2 subsurface drip irrigation includes:
1) Golf course landscaping;
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2) Parks, athletic fields, schoolyards, cemeteries;
3) Above-ground food crops (such as fruit trees) where the edible portion of the crop has minimal
contact with the recycled water;
4) Impoundments without fountains or any other water features that generate spray or mist;
5) Landscapes around certain residential property such as condominiums that have a recycled water
manager responsible for the landscape irrigation; and
6) Freeway, roadside, and medial strip landscaping.
Calcium hypochlorite is a solid form of hypochlorite that commonly used for disinfection of smaller WWTP
such as Pāhala. The County utilizes solid calcium hypochlorite as a disinfectant at other existing treatment
plants, so existing supply chain logistics may be leveraged should this be utilized at the Pāhala WWTP.
The above processes will require dewatering of the wastewater solids which will be coordinated by the
County.
The dewatered solids 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.
3.1.4 Disposal
Disposal of the treated effluent is an important consideration at any WWTP. Methods such as ocean
discharge, use of injection wells, water recycling and slow rate land treatment 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 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 the Pāhala WWTP.
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 are 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). .
The effluent disposal system will be sized to handle the peak day wet weather flow. 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.
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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 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.
3.2 Collection System
As a part of the project, 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
Pāhala Large Capacity Cesspool Closure Special Permit Application Page 10 of 20
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.
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.
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.
Phase 2 includes the completion of the new collection system through the following actions:
3. Construction of segments totaling approximately 9,400 LF of 8-inch line throughout Pāhala,
ensuring gravity flow connection from 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
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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.
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.
It should be noted that the construction of the WWTP is anticipated to occur after the completion of the
collection system. As such, a temporary connection will direct wastewater flows from all currently
connected lots back to the LCC. No increases in wastewater flows are anticipated to occur. Upon completion
of the WWTP, the crossover connection will be activated and the temporary connection to the LCC shall
be disassembled.
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.”
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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.
3.3 Operational Hours and Staffing Requirement
The wastewater treatment plant shall operate during regular hours Monday through Sunday from 7:00 AM
to 3:30 PM. Hours may be adjusted for public holidays. Staffing projections for the WWTP are not yet
completed but is anticipated to include 1-2 supervisors and additional staff present for repair and
maintenance of the equipment.
4. Land Use and Land Use Plans
The existing land use in the project area and surrounding region includes residential, agricultural, and
undeveloped land. Agricultural activities, such as macadamia nut farming, are important for the local
economy and a portion of the WWTP site includes previous macadamia farms. The Project Area is located
within the Urban and Agricultural State Land Use Districts. As such, the Proposed Use would be required
to comply with the regulations set forth in the State Land Use Law (HRS, Chapter 205).
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
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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.
Hawai‘i County Code (HCC) Chapter 25 regulates land use in accordance with adopted land use policies.
The code presents permitted uses and structures, development standards, and height controls for each
zoning district. The wastewater treatment and disposal facility will be owned by the County and managed
and operated by the DEM. The facility will be a “public use” as defined by HCC § 25-1-5, as a use
conducted by or a structure or building owned or managed by the federal government, the State of Hawai‘i
or the County to fulfill a governmental function, activity or service for public benefit and in accordance
with public policy.
HCC § 25-2-71 (c)(1) states: Plan approval shall be required in all applicable districts prior to the
construction or establishment of public uses, structures and buildings and community buildings, as
permitted under section 25-4-11.
HCC § 25-4-11(c) states: Public uses, structures and buildings and community buildings are permitted uses
in any district, provided that the director has issued plan approval for such use.
The Project Area is located approximately 3.8 miles from the nearest shoreline and is not situated within
the State Special Management Area (SMA) as defined by Chapter 205A, HRS.
5. Flood Insurance Rate Map
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.
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.
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6. Archaeological Resources and Historic Resources
A 2016 survey of available information identified the presence of one historic site is in the vicinity of the
proposed wastewater collection system. In 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. This 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 Use. 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. An
Archeological Monitoring Plan was prepared (Wilkinson and Hammatt 2020) and accepted by SHPD in a
letter dated November 4, 2020.
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
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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. For more information, please refer to Appendix B of the Final EID.
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.
7. Valued Cultural Resources
As stated above, 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.
8. Floral and Faunal Resources:
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
Pāhala Large Capacity Cesspool Closure Special Permit Application Page 16 of 20
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 Use..
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 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
Pāhala Large Capacity Cesspool Closure Special Permit Application Page 17 of 20
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.
9. Existing Access
10.1 Public Access to Shoreline and Mountain Areas
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). As such, there is no existing public access to or along the
shoreline which will be impacted as a result of the Proposed Access. Topography in the Pāhala area is
characterized by gently sloping to moderately steep terrains; there is no knowledge of existing access to
and along mountain areas in the vicinity of the Project Area.
10.2 Access to the Project Area
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. The Project Site is accessible via the existing road network. Further, the proposed collection system shall be located almost entirely within the Public Right-of-Way
(ROW) in Pāhala. 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 collection system is also anticipated to utilize three easements
in the Pāhala community to collect and convey waste to the WWTP. 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. Additionally, a 24-foot wide asphalt concrete (AC) access driveway will be constructed from Maile Street to the facility as shown in the attached site plans. 10. Traffic
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. 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. The proposed project sites, including the preferred location for
the wastewater treatment and disposal facility, are accessible via the existing road network.
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.
Pāhala Large Capacity Cesspool Closure Special Permit Application Page 18 of 20
11. Availability of Utilities
The County of Hawai‘i Department of Water Supply (DWS) provides water service to the Pāhala
community from groundwater sources. The water lines are primarily located along or under the roadways
in the area. The nearest point of connection to the DWS system is at an existing 6-inch waterline at the
intersection of Huapala Street and Maile Street, approximately 2,000 feet northeast of the WWTP Site.
Electrical services to the Pāhala area are provided by Hawaiian Electric Light Company (HELCO) via pole-
mounted overhead lines located along the roadways within the community. The HELCO lines are located
along Māmalahoa Highway, leading to a substation west of the intersection of Kamani Street and the
highway. Hawaiian Telcom is the primary telecommunications provider within the County of Hawai‘i and
has overhead lines for telephone service in the Pāhala community.
Solid waste in the Pāhala area is managed by the County Solid Waste Division. The public facilities are
comprised of West Hawai‘i Sanitary Landfill, the East Hawai‘i Reload Facility and twenty-one (21)
Recycling & Transfer Stations. The Pāhala Transfer Station currently accepts household generated self-
haul waste, scrap metal and white goods / appliances, as well as clean corrugated cardboard, brown paper
bags, and non-HI-5 glass containers.
12. Justification for Special Permit Request
This Special Permit is submitted in accordance with Rule 6.7 of the County of Hawai‘i Planning
Commission Rules of Practice and Procedure (2017) to allow the County of Hawai‘i Department of
Environmental Management (DEM) to construct and operate a 14.9-acre wastewater treatment and disposal
facility in the Pāhala community. The project site is located on land designated as “Agricultural” by the
State Land Use Commission and classified by the Land Study Bureau (LSB) with an overall productivity
rating of B (good) for approximately 50 percent of the site and D (poor) for the remaining 50 percent.
The proposed use promotes the effectiveness and objectives of Chapter 205, Hawai‘i Revised Statutes
(HRS), by supporting the public health and welfare of the community without displacing or diminishing
the agricultural potential of surrounding lands. Chapter 205 seeks to preserve lands of high agricultural
value for farming and related uses. However, the Special Permit mechanism allows for unusual and
reasonable uses of Agricultural District lands in cases where non-agricultural public uses are necessary and
appropriate. This project is considered such a use based on the following criteria:
1. The proposed use shall not adversely affect surrounding properties.
The facility is sited to avoid impacts on neighboring uses. The selected location is proximate to the existing
substandard collection system and cesspools and was chosen after a multi-criteria site selection process
documented in the Final EA (published March 8, 2020). Surrounding properties are largely undeveloped or
in agricultural use, and the treatment plant will be buffered and screened to minimize noise, odor, and visual
impacts. As a utility infrastructure project designed to replace failing cesspools, the facility will improve
environmental and public health conditions in the area and will not generate nuisance conditions for
adjacent parcels.
2. The proposed use shall not unreasonably burden public agencies to provide services.
This project represents a County-initiated utility infrastructure improvement. The proposed wastewater
treatment facility and disposal system will replace existing substandard facilities and will be maintained by
the County. The project will not require new school facilities, police or fire stations, or other off-site
Pāhala Large Capacity Cesspool Closure Special Permit Application Page 19 of 20
infrastructure. Roads, drainage, and water access are already available to support the project, and no
substantial upgrades are required to serve the proposed facility.
3. Unusual conditions, trends, and needs have arisen since the district boundaries were established.
Since the Agricultural District boundaries were adopted, federal regulations under the Clean Water Act
have been implemented that prohibit the use of Large Capacity Cesspools (LCCs). The U.S. Environmental
Protection Agency (EPA) issued an Administrative Order on Consent (AOC) to the County in June 2017,
mandating the closure of LCCs in Pāhala and construction of a compliant wastewater system. These federal
requirements represent a significant and unanticipated shift in public health policy and wastewater
regulation, creating an unusual condition that necessitates a County response. The proposed facility is
needed to comply with this federal order and to protect local groundwater and drinking water resources.
4. The land is unsuited for the permitted uses within the district.
While the LSB rates a portion of the parcel as Class B, the site is not actively used for agricultural production
and lacks existing agricultural improvements. The property was selected for its proximity to existing
wastewater infrastructure, suitable soils for disposal, and ease of access. Alternative sites with higher
agricultural utility were considered and rejected during the EA process. The limited agricultural use and
existing constraints make this parcel better suited for the proposed public utility function than for intensive
agricultural development.
5. The proposed use will not substantially alter the character of the land.
The project will result in a low-profile, public utility facility that is designed to integrate into the existing
landscape with minimal disturbance. Landscaping, fencing, and design features will be used to minimize
visual and environmental impacts. The proposed use does not involve commercial development, residential
expansion, or incompatible land uses. It will remain a limited, essential service facility on a portion of a
larger agricultural parcel, and the surrounding land character will be maintained.
6. The proposed use aligns with the General Plan and applicable community plans.
The project supports the goals of the Hawai‘i County General Plan, including the protection of public health
and natural resources, provision of essential infrastructure, and long-term community sustainability. It also
aligns with State and County policies to eliminate LCCs and protect groundwater. While the Kaʻū
Community Development Plan (CDP) emphasizes agricultural preservation and rural character, the project
supports these goals by preventing contamination, providing necessary infrastructure, and avoiding urban
development. The selection of this site over other locations reflects sensitivity to land use values and long-
term planning goals.
Summary
This Special Permit application seeks approval for an unusual and reasonable use of land within the
Agricultural District to fulfill a federally mandated public health obligation. The proposed wastewater
treatment and disposal facility will not interfere with ongoing agricultural activity in the region, will serve
the existing community without burdening public services, and aligns with both legal mandates and County
planning objectives.
Pāhala Large Capacity Cesspool Closure Special Permit Application Page 20 of 20
EXHIBIT A:
Project Figures and Site Plans
Existing Large Capacity Cesspool
(LCC 1)
Proposed Pahala
WWTP Site
Existing Large Capacity Cesspool (LCC 2)
ME
Y
E
R
R
D
ME
Y
E
R
R
D
HAU
S
T
HAU
S
T
HA
U
P
A
L
A
S
T
HA
U
P
A
L
A
S
T
HINANO
S
T
HINANO
S
T
PAKAL
A
N
A
S
T
PAKAL
A
N
A
S
T
PUMELI STPUMELI ST
HOLEI STHOLEI ST
KOKI
O
S
T
KOKI
O
S
T
KEAH
I
S
T
KEAH
I
S
T
OHIA
S
T
OHIA
S
T
ILIA
U
S
T
ILIA
U
S
T
KAUM
A
H
A
N
A
S
T
KAUM
A
H
A
N
A
S
T
KAMA
N
I
S
T
KAMA
N
I
S
T
KO
A
L
I
S
T
KO
A
L
I
S
T
PU
A
H
A
L
A
S
T
PU
A
H
A
L
A
S
T
PIK
A
K
E
S
T
PIK
A
K
E
S
T
LE
H
U
A
S
T
LE
H
U
A
S
T
MAI
L
E
S
T
MAI
L
E
S
T
HA
W
A
I
I
B
E
L
T
R
D
HA
W
A
I
I
B
E
L
T
R
D
HA
L
A
S
T
HA
L
A
S
T
PAA
U
A
S
T
PAA
U
A
S
T
PA
A
U
A
P
L
PA
A
U
A
P
L
ILI
M
A
S
T
ILI
M
A
S
T
FIGURE 2
PAHALA LARGE CAPACITY CESSPOOL CLOSURE PROJECTPAHALA LARGE CAPACITY CESSPOOL CLOSURE PROJECT
ALTERNATIVE 1 SITE PLANALTERNATIVE 1 SITE PLAN
Ka’u High &Pahala ElementarySchool
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)
ARCHITECTURAL OVERALL SITE PLAN
SCALE: 1" = 100'A 0 100'200'50'N
SEWER PUMP STATION,SEE CIVIL DWGS
FIRE PROTECTION TANK,SEE CIVIL DWGS
CONTROL BUILDING,SEE DWGS NO A02.1
CANOPY BUILDING(UNDER SEPARATEPERMIT)
1839.50'
25'-0" EASEMENT A-1
'27.833
4
3
.
8
4
'
8
6
2
.
4
4
'
10.00'
2
0
0
.
0
0
'
27.70
'
1618.69'
582.
5
5
'
5
1
3
.
8
0
'
33.96'
M A I L E S T R E E T
H
A
W
A
I
I
B
E
L
T
R
O
A
D
90
6
.
4
9
'
191.41'
652.
2
4
'
6'-0" HIGH CHAIN LINKFENCE, SEE CIVIL DWGS
(E)
A
C
R
O
A
D
FUTURE EXPANSION BCRREACTORS - TYP
(E) AC ROAD
6'-0" HIGH x 22'-0" WIDECHAIN LINK GATE
SEE PARTIAL SITE PLAN,DWG NO G01.2
81
9
'
-
0
"
48'
-
1
0
"
9
3
'
-
0
"
1491'-0
"
TMK: (3) 9 - 6 - 002: 024ZONING: MG-1a, A-20a
TMK: (3) 9 - 6 - 002: 016ZONING: A-1a
20'-0" SIDE YARD SETBACK
30'-0" FRONT YARDSETBACK
30'-0" REAR YARDSETBACK
492'-10"
TMK: (3) 9 - 6 - 002: 018ZONING: A-20a
OFSHEET
APPR'DBYREVISIONBRIEFDATE
APPROVED BY:
DESIGNED BY
164
COUNTY OF HAWAI'I, WASTEWATER DIVISION, CHIEF DATE
KA'U, ISLAND OF HAWAIʻI, HAWAIʻI
PAHALA WASTEWATER TREATMENT PLANT
DRAWN BY CHECKED BY
COUNTY OF HAWAI'IDEPARTMENT OF ENVIRONMENTAL MANAGEMENT
455 E. Lanikaula St. Hilo, Hawai`i 96720
Main (808) 933-7900 www.epinc.proENGINEERINGPA R T N E R S Hawai`i Las Vegas
BR I A N .F FU
N
A
...SI,I U AW
HA A
SIGNATURE
WILL BE UNDER MY OBSERVATION.CONSTRUCTION OF THIS PROJECTME OR UNDER MY SUPERVISION,THIS WORK WAS PREPARED BY
Exp. 04/30/26
No. AR-7698
LICENSEDPROFESSIONAL
ARCHITECT
I
K2, BFK2
3
G01.1
ARCHITECTURAL OVERALL SITE PLAN
EPI
I
ʻ
PERMIT AREA
NAFLOOR PLAN
54'-0"
36
'
-
0
"
5'
-
0
"
105
MAINTENANCE
101
ROOM
GENERATOR
103
RESTROOM
16'-0"14'-0"22'-8"
5'-4"7'-4"
DESK
(NIC)
CHAIR
(NIC)
SL
O
P
E
4'-0"13'-4"4'-0"6'-8"
ADA
LAV ADA
WC
ADA
SHOWER
8'
-
0
"
2'
-
0
"
3'-4"4'-0"
4"4"
3'-4"1'-4"
SLOPE
106
LABORATORY 14
'
-
0
"
22
'
-
0
"
4'-0"3'-4"
5'-4"3'-4"5'-4"
104
ROOM
ELECTRICAL
ADA
SINK
WH
5'-4"5'-4"
5'
-
4
"
4'
-
0
"
4'
-
8
"
4'
-
0
"
5'
-
4
"
2'
-
8
"
5'
-
4
"
4'
-
8
"
8"
8'
-
0
"
5'
-
0
"
DS W/ SPLASH
BLOCK - TYP
5'-4"
ADA
EYEWASH
WITH COVER
FD
5'-0"
9'
-
4
"
3'-4"
6" HIGH
CONC
PAD, SEE
STRL
DWGS
8"
5'
-
4
"
30
'
-
8
"
4'-8"12'-0"14'-8"
102
ROOM
HEATER
WATER
PLUMBING
CHASE
CL OF CMU WALL
AIR
CONDITIONING
AIR
CONDITIONING
PLUMBING CHASE
8" CMU - TYPICAL
SMOOTH FLUSH
CONNECTION - TYP
WALLS
8" CMU WALL
W/ GROUT
FILLED: STC 55
DASHED LINE
OF ROOF LINES
MOTOR
CONTROL
CTR, SEE
ELEC
DWGS
ANTI-
STATIC
MAT BY
OWNER
3'-4"
CONC WALKWAY,
SEE CIVIL DWGS
TRUE
NORTH N PLAN
NORTH
OFSHEET
APPR'DBYREVISIONBRIEFDATE
APPROVED BY:
DESIGNED BY
XX
COUNTY OF HAWAI'I, DEPARTMENT OF ENVIRONMENTAL MANAGEMENT DATE
KA'U, ISLAND OF HAWAIʻI, HAWAIʻI
PAHALA WASTEWATER TREATMENT PLANT
DRAWN BY CHECKED BY
COUNTY OF HAWAI'I
DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
455 E. Lanikaula St. Hilo, Hawai`i 96720
Main (808) 933-7900 www.epinc.proENGINEERINGP A R T N E R S Hawai`i Las Vegas
30% DESIGN
SUBMITTAL
K2, BFXX
X
A02.1
FLOOR PLAN
A ROOF PLAN
4:
1
2
RO
O
F
PI
T
C
H
4:
1
2
RO
O
F
PI
T
C
H
4:12
ROOF
PITCH
4:12
ROOF
PITCH
321 RIDGE FLASHING DETAIL / PLANHIP FLASHING DETAILRIDGE/HIP VENT FLASHING DETAIL
ATTIC VENTILATION
GUTTER &
DOWNSPOUT
CALCULATION
1,944 SQ FT DIV BY 300 SQ FT = 6.48 = 6 SQ FT OF NFVA
6 SQ FT OF NFVA X 144 (INCH PER SQ FT) = 264 SQ IN OF NFVA
SOFFIT VENT, SEE DETAIL #
60% OF 264 SQ IN = 158.4 = 158 SQ IN (SOFFIT VENTS)
158 SQ IN DIV BY 9 (NFVA-PERPFT RATING OF VENT) = 17.5 =
18 LIN FT OF INTAKE
RIDGE VENT, SEE DETAIL 1 ON THIS SHEET
40% OF 264 SQ IN = 105.6 = 106 SQ IN (RIDGE VENTS)
106 SQ IN DIV BY 9 (NFVA-PER-FT RATING OF VENT) = 11.7 =
12 LIN FT OF EXHAUST
Hawaii -- Pahala
Rainfall Intensity (10yr) = 8.7 in./hr.
Rainfall Intensity (100yr) = 12 in./hr.
Drainable Area (10yr) = 140 sq. ft.
Drainable Area (100yr) = 100 sq. ft.
Year Setting = 10 yr.
Plan Area = 1364 sq. ft.
Gutter length = 62 ft.
Max Gutter Served by Each DS = 62 ft.
Design Area = 1432.2 sq. ft.
Minimum Number of DS = 1
Max Roof Area Served by Each DS = 1432.2 sq. ft.
Min. Gutter Width = 6 in.
Min. Gutter Depth = 6 in.
Min. Ds Size = 5 in. dia
4
TYPICAL CORRUGATED METAL
ROOFING DETAIL
OFSHEET
APPR'DBYREVISIONBRIEFDATE
APPROVED BY:
DESIGNED BY
XX
COUNTY OF HAWAI'I, DEPARTMENT OF ENVIRONMENTAL MANAGEMENT DATE
KA'U, ISLAND OF HAWAIʻI, HAWAIʻI
PAHALA WASTEWATER TREATMENT PLANT
DRAWN BY CHECKED BY
COUNTY OF HAWAI'I
DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
455 E. Lanikaula St. Hilo, Hawai`i 96720
Main (808) 933-7900 www.epinc.proENGINEERINGPARTNERSHawai`i Las Vegas
30% DESIGN
SUBMITTAL
K2, BFEPIXX
X
A03.1
ROOF PLAN
A EXTERIOR ELEVATIONS
TOP OF PLATE
OFSHEET
APPR'DBYREVISIONBRIEFDATE
APPROVED BY:
DESIGNED BY
XX
COUNTY OF HAWAI'I, DEPARTMENT OF ENVIRONMENTAL MANAGEMENT DATE
KA'U, ISLAND OF HAWAIʻI, HAWAIʻI
PAHALA WASTEWATER TREATMENT PLANT
DRAWN BY CHECKED BY
COUNTY OF HAWAI'I
DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
455 E. Lanikaula St. Hilo, Hawai`i 96720
Main (808) 933-7900 www.epinc.proENGINEERINGPARTNERSHawai`i Las Vegas
30% DESIGN
SUBMITTAL
K2, BFEPIXX
X
A05.1
EXTERIOR ELEVATIONS
3
A
B
C
D
21
97'-6"
26'-6"71'-0"
25
'
-
0
"
25
'
-
0
"
85
'
-
0
"
DS
DS
101
CANOPY
SCREW
PRESS
DEWATERED
SOLIDS
RECEPTACLE
BCR 1
EQUALIZATION
DASHED LINE OF
ROOF OVERHANG
E
15
'
-
0
"
20
'
-
0
"
35
'
-
0
"
50
'
-
0
"
20
'
-
0
"
15
'
-
0
"
25
'
-
0
"
25
'
-
0
"
DS
DS
DS
DS
DS
DS
DS
DS
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OFSHEET
APPR'DBYREVISIONBRIEFDATE
APPROVED BY:
DESIGNED BY
XX
COUNTY OF HAWAI'I, DEPARTMENT OF ENVIRONMENTAL MANAGEMENT DATE
KA'U, ISLAND OF HAWAIʻI, HAWAIʻI
PAHALA WASTEWATER TREATMENT PLANT
DRAWN BY CHECKED BY
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DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
455 E. Lanikaula St. Hilo, Hawai`i 96720
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APPROVED BY:
DESIGNED BY
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COUNTY OF HAWAI'I, DEPARTMENT OF ENVIRONMENTAL MANAGEMENT DATE
KA'U, ISLAND OF HAWAIʻI, HAWAIʻI
PAHALA WASTEWATER TREATMENT PLANT
DRAWN BY CHECKED BY
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DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
455 E. Lanikaula St. Hilo, Hawai`i 96720
Main (808) 933-7900 www.epinc.proENGINEERINGPARTNERSHawai`i Las Vegas
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APPR'DBYREVISIONBRIEFDATE
APPROVED BY:
DESIGNED BY
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COUNTY OF HAWAI'I, DEPARTMENT OF ENVIRONMENTAL MANAGEMENT DATE
KA'U, ISLAND OF HAWAIʻI, HAWAIʻI
PAHALA WASTEWATER TREATMENT PLANT
DRAWN BY CHECKED BY
COUNTY OF HAWAI'I
DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
455 E. Lanikaula St. Hilo, Hawai`i 96720
Main (808) 933-7900 www.epinc.proENGINEERINGPARTNERSHawai`i Las Vegas
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Harry Kim
Mayor
f ILE COPY 1
1
William A. Kucharski
-----Director
Roy Takemoto
Managing Director
MAR .. 8 2020 Diane A. Noda
Deputy Director
County of Hawai'i
DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
February 24, 2020
345 Kekuanao'a Street, Suite 41 · Hilo, Hawai'i 96720
Ph: (808} 961-8083 • Fax: (808) 961-8086
Email: cohdem@hawaiicounty.gov
Dr. Keith Kawaoka, Acting Director
Office of Environmental Quality Control
State of Hawai'i
235 South Beretania Street, Room 702
Honolulu, Hawai'i 96813
Subject: Final Environmental Assessment/Finding of No Significant Impact Notice
(Joint NEPA/HEPA)
Piihala Large Capacity Cesspool Replacement Project
Pii'au'au, Ka'u, Hawai'i Island, Hawai'i
WWTP Tax Map Key (TMK): (3) 9-6-002:018
Dear Dr. Kawaoka:
The U.S. Environmental Protection Agency (EPA) and the Hawai'i County Department of
Environmental Management (DEM) are issuing a joint Final Environmental Assessment (FEA) of
the Proposed Pahala Large Capacity Cesspool Replacement Project. With this letter DEM
hereby transmits the subject FEA notice.
This FEA was prepared in accordance with the National Environmental Policy Act (NEPA), EPA
and Council on Environmental Quality NEPA regulations as well as the Hawai'i Environmental
Policy Act (HEPA-Hawai'i Revised Statutes, Chapter 343) and implementing rules Hawai'i
Administrative Rules (HAR), Title 11, State of Hawai'i Department of Health Chapter 200,
Environmental Impact Statement Rules. •.
A Finding of No Significant Impact is determined for this project. The basis for this
determination is set forth in the FEA Section 8.1.1, which follows the significance criteria set
forth in HAR, Title 11, Chapter 200, Section 12.
Pursuant to the requirements of Sections 11-200-9.1 and 11-200-11.1 Hawai'i Administrative
Rules, we request that you publish notice of the FEA in the March 8, 2020, periodic bulletin The
Environmental Notice.
County of Hawai'i Is an Equal Opportunity Provider and Employer 20-214
Dr. Keith Kawaoka, Acting Director
Office of Environmental Quality Control
February 24, 2020
Page 2
Please contact Dora Beck, County of Hawai'i Wastewater Division Chief, at (808) 961-8513 if
you have any questions.
Sincerely,
/lia--u-c-c.h_a,,,...rs"--k-i _,____ __
Director
cc: Dora Beck, DEM-WWD
WK:mef
. I \ (I
Sandra Mendonca, DEM-WWD
Kate Rao, Environmental Protection Agency
Craig Lekven, Brown and Caldwell
Earl Matsukawa, Wilson Okamoto Corporation
Patrick Goodwin, ERG
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco, CA 94105-3901
FINDING OF NO SIGNIFICANT IMPACT
Pahala Large Capacity Cesspool Replacement Project, Hawai'i, United States
Proposed Action
In accordance with the National Environmental Policy Act (NEPA), 42 U.S.C. §§ 4321-4370h, and its implementing regulations, 40 C.F.R. §§ 1500.1-1508.28, as well as the U.S. Environmental
Protection Agency (EPA) procedures for implementing NEPA, 40 C.F.R. Part 6, EPA has prepared
a Final Environmental Assessment (EA) describing the potential environmental impacts associated
with, and the alternatives to, the proposed Pahala Large Capacity Cesspool (LCC) Replacement Project (Proposed Action).
Project Background
In 2006, EPA awarded a Special Appropriations Act Project (SAAP) grant to the County of Hawai'i (County) for the Ka'0 LCC Replacement Project (Grant No. XP-96942401) in the amount of $1.842
million. The initial SAAP grant work plan included wastewater upgrade projects for LCCs serving both the Na'alehu and Pahala communities in the Ka'O District. It was later determined that federal
grant funds would only cover a portion of one of the projects. The grant work plan was revised to
address the LCCs serving the Pahala community since the timeline appeared to be on a faster path than Na'alehu and there was a concern about spending grant funding within the project period.
EPA's award of the SAAP grant for the Proposed Action is considered a major federal action
requiring compliance with NEPA in accordance with 40 C.F.R. § 1508.18. In addition, NEPA
regulation 40 C.F.R. § 1506.2, calls for federal agencies to cooperate with State and local agencies
to the fullest extent possible to reduce duplication between NEPA and State and local requirements. The Final EA has been prepared by both the EPA and the County of Hawai'i to meet
the content and procedural requirements of both NEPA and Hawai'i State and local requirements.
Purpose and Need for Action
In 1999, EPA promulgated regulations under the Safe Drinking Water Act's (SOWA) 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 Pahala community by June 2021. The compliance date was revised in September 2019 to April 2023.
The purpose of the Proposed Action is to enable the County to comply with the SOWA and to fulfill
the compliance provisions of the June 2017 AOC between EPA and the County with respect to closure of the Pahala LCCs by April 2023.
The need for action is driven by the public health and environmental concerns associated with
LCCs. Cesspools can release disease-causing pathogens and other pollutants (e.g., nitrates) into
groundwater aquifers, streams, and eventually the ocean, thus leading to public health and environmental concerns.
Printed 011 J 00% Pas/consumer Recycled Pape,: Process Chlorine Free.
Alternatives Analysis and Selection of the Preferred Alternative
Pahala LCC Replacement Project Pahala, Ka'O District, Hawai'i
The proposed location for the Proposed Action is both within and immediately south of the community of Pahala, which is about 52 miles southwest of Hilo, in the Ka'O District, Island of
Hawai'i. Pahala is located west (mauka) of Mamalahoa Highway (State Route 11) 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.
Candidate sites were identified based on three primary criteria. First, the site would have to be appropriate for the preliminary design of the treatment and disposal facility. Second, access to the site would allow the County to meet the various requirements of the AOC that stipulated closure of the LCCs by June 2021. Third, the environmental impacts of construction of the treatment and disposal facility were considered. Based on these three primary criteria, and considering additional suggestions from the Pahala community obtained during Community Outreach meetings in December 2017, nine candidate sites for the proposed wastewater treatment and disposal facility were identified.
As detailed in the Final EA, the suitability of each candidate site was evaluated using a weighted scoring system that considered twenty-one criteria within four general categories (environmental, social, and cultural; location and site; land use and availability; and collection system and service area). The three highest-scoring candidate sites (Sites 7, 8, and 9) were carried forward as alternatives for evaluation, and the highest-scoring site (Site 7) was ultimately selected as the Preferred Alternative.
Site 7 Alternative (Preferred Alternative)
Under the Preferred Alternative for the Proposed Action, the County will perform the following actions:
1)Acquire, or otherwise obtain the right to develop and use, a 14.9-acre portion of a 42.5-parcel (Tax Map Key (TMK): 9-6-002:018), identified as "Site 7", that is currently ownedby B. P. Bishop Estate Trustees (commonly known as Kamehameha Schools), thenconstruct a new secondary wastewater treatment and disposal facility within that portionof the parcel;
2)Construct a new wastewater collection system, primarily within the public right-of-way(ROW) and three segments within easements in the Pahala community, to collect andconvey sanitary waste from the currently connected and accessible (in accordance withHawai'i County Code) properties to the new wastewater treatment and disposal facility;
3)Close and abandon two LCCs, according to State of Hawai'i Department of Healthclosure procedures; and
4)Abandon the existing wastewater collection system in place.
Unde.r the Preferred Alternative, the proposed wastewater treatment and disposal facility will
occupy about 14.9 acres and will consist of a headworks and an odor control unit, an operations building, four lined aerated lagoons, a subsurface flow constructed wetland to remove nitrogen, an adjacent disinfection system to remove pathogens, and four slow-rate land treatment basins that
occupy a total area of approximately 8.0 acres for disposal of the treated effluent. The proposed wastewater collection system will be located within 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).
Site 8 Alternative
Under the Site 8 Alternative for the Proposed Action, the County would perform the same actions as described above for the Preferred Alternative, with the exception that the new wastewater
treatment and disposal facility would be constructed at Site 8, a 45.2-acre parcel (TMK: 9-6-002:021) located southwest of and adjacent to Site 7, across Maile Street and above Mamalahoa
2
Pahala LCC Replacement Project Pahala, Ka'O District, Hawai'i
Highway. The Site 8 Alternative would require approximately 1,600 feet of additional pipe within the ROW of Lower Maoula Road for the new wastewater collection system and, because of the steeper slopes, would require larger slow-rate land application groves totaling approximately 12 acres. Site 8 was not selected as the Preferred Alternative because it scored lower in the weighted scoring system due to the presence of a stream bisecting the parcel lengthwise that would complicate siting of the treatment and disposal facility.
Site 9 Alternative
Under the Site 9 Alternative for the Proposed Action, the County would perform the same actions as described above for the Preferred Alternative, with the exception that the new wastewater treatment and disposal facility would be constructed at Site 9, a 157-acre parcel (TMK: 9-6-002:049) located southeast of Sites 7 and 8 across Mamalahoa Highway. The Site 9 Alternative would require approximately 3,200 feet of additional pipe within the ROW of Maile Street and across Mamalahoa Highway for the new wastewater Collection system. Site 9 was not selected as the Preferred Alternative because it scored lower in the weighted scoring system due to the presence of surface water within the parcel and the added difficulty of access given its location
relative to existing roads.
No-Action Alternative
In addition to the Site 7, 8, and 9 Alternatives, EPA considered a No-Action Alternative, under
which the County would continue to use the two existing LCCs in Pahala, existing substandard gravity sewer lines, and individual septic systems. No additional properties would be added to the community sewer system under this alternative. Under the No-Action Alternative, the action would not be implemented and the Pahala community would not be provided with an acceptable wastewater collection, treatment, and disposal system. This alternative would not fulfill the purpose and need for the action and would result in non-compliance with the AOC between EPA and the
County. Because this alternative would not achieve the objectives of the SAAP grant, protect human health and the environment,. or enhance State and local agency efforts to achieve compliance with the Safe Drinking Water Act, it was not considered to be the Preferred Alternative.
Environmental Impacts
In compliance with NEPA, EPA has prepared a Final EA that analyzes the environmental impacts of the Pahala LCC Replacement Project. After considering a wide range of regulatory, environmental (both natural and human), and socioeconomic factors, the Final EA did not identify any significant impacts to the environment that will result from the implementation of the Preferred Alternative for the Proposed Action. The following is a summary of environmental impacts as
described in the Final EA associated with the Preferred Alternative.
Summary of Endangered Species Act. Section 7 Consultation
The collection system will be constructed primarily within areas that were disturbed during construction of County streets, plus two short segments within easements in the Pahala community. The treatment and disposal facility site has previously been cleared, graded, and planted with a macadamia nut orchard. The affected sites do not provide habitat for federal or State
of Hawai'i listed or candidate threatened or endangered species of flora or fauna. A biological field survey in August 2018 did not identify any native mammalian or avian species within Site 7, though the ·endangered Hawaiian Petrel (Pterodroma sandwichensis) and the threatened Newell's
Shearwater (Puffinus newe/11) have been recorded flying over the general area between April and the end of November each year. Construction and design of the wastewater treatment and disposal facility will incorporate impact avoidance measures as summarized below to avoid or minimize adverse effects to protected avian species. 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 Hawai'i, requested concurrence from the U.S. Fish and Wildlife Service (FWS)
3
·Pahala LCC Replacement ProjectPahala, Ka'O District, Hawai'i
that the Pahala LCC Replacement Project is not likely to adversely affect federally listed threatened and endangered species or critical habitat. The FWS concurred on February 15, 2019 that the Preferred Alternative may affect, but is not likely to adversely affect, listed species.
Summary of National Historic Preservation Act, Section 106 Consultation
An Archaeological Inventory Survey (AIS), which included subsurface testing within Site 7, was conducted to test for the presence of archaeological resources on the project site. The AIS confirmed no significant artifacts or cultural deposits were observed on the ground surface within the proposed treatment and disposal facility 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 Site 7. On September 26, 2019, EPA sent a letter to Hawai'i State Historic Preservation Division (SHPD) to document its determination that no historic properties will be affected by the undertaking and to request concurrence from SHPD in accordance with 36 C.F.R. § 800.4(d)(1 ), Pursuant to 36 C.F.R. §800.5(c)(1 ), EPA may proceed after the close of a 30-day review period if SHPD does not provide a response within such time. No response was received within this timeframe, therefore, EPA fulfilled its responsibilities under Section 106. The Preferred Alternative will incorporate appropriate mitigation measures as summarized below to avoid impacts should unanticipated archeological resources be discovered during construction.
Consultation letters were delivered to invite comments from organizations that may attach religious or cultural significance to properties affected by the Preferred Alternative. A total of 14 letters were
mailed to various Native Hawaiian Organizations requesting comments. No responses were received from these organizations.
Summary of Other Resource Area Impacts
The Preferred Alternative will result in minor, short-term impacts to noise, air quality, and traffic in the immediate vicinity of the project site during the period of construction. Short-term constructionrelated impacts include intermittent and unavoidable noise from construction vehicles and
equipment within the Pahala community, including a possible short-term increased noise impact associated with the removal of bedrock depending on conditions encountered in the collection system area. Construction of the wastewater treatment and disposal facility will also require removal of macadamia nuttrees, removal of several of the Cook pines (Araucaria co/umnaris) that line Maile Street, and clearing and excavating for construction of various improvements. Wastewater treatment plants can be a source of nuisance odors to the surrounding community if not properly designed or operated. However, the facility will include an odor control system to limit odors typically associated with a wastewater treatment facility. The minor short-term increase in traffic during construction of the proposed wastewater treatment and disposal facility will be due to the transport of construction equipment and supplies to the construction site. Deliveries to the
construction site could require temporary stoppage of traffic on Maile Street to safely unload equipment and supplies. Operation of the wastewater treatment and disposal facility will contribute almost no additional light pollution, noise, or air emissions to the local area or detrimentally affect air or water quality.
Construction of the treatment and disposal facility will result in an increase in impervious surfaces. However, the treatment and disposal facility would be designed with an on-site drainage system and will ensure there is no adverse impact on adjacent or downstream properties due to postdevelopment flows. In addition, the wastewater treatment and disposal facility would be designed and sized so the exposed (not enclosed) treatment processes have sufficient free-board depth to accommodate a 24-hour, 100-year storm event at the site. The wastewater treatment processes would be designed to accommodate the peak flows caused by the design storm event, including precipitation that falls on the aerated and covered lagoon treatment system.
Other resource areas besides those described above were evaluated in the Final EA but will not be impacted by the Proposed Action. These include, but are not limited to, floodplains, wetlands,
4
Pahala LCC Replacement Project Pahala, Ka'u District, Hawai'i
coastal zones, and Sole Source Aquifers. The Preferred Alternative does not establish a drinking water system, and since no Sole Source Aquifers are present on the Island of Hawai'i, will not impact such aquifers based on the location. The collection system and wastewater treatment and disposal facility will not affect coastal resources and is not located within a floodplain area and therefore will not have an adverse impact on floodplains and will minimize the risk of flood-related
impacts on surrounding properties. The site of the Preferred Alternative contains no wetland features and no streams and therefore is not expected to impact surface water or wetland resources.
The Pahala LCC Replacement Project will allow the County to provide wastewater collection, treatment, and disposal. facilities meeting the needs of the Pahala community and will have a beneficial impact on the economic and social welfare of the community. The Preferred Alternative
will not result in population changes in the Pahala area. The Preferred Alternative will not result in disproportionately high and adverse human health or environmental effects on sensitive
populations.
Mitigation Measures
The Preferred Alternativewill include the incorporation of certain mitigation measures as discussed in the Final EA, ineluding, but not limited to, measures relatedlo·archeological resources and those that were specified in the FWS Section 7 Consultation process. The Preferred Alternative will
incorporate appropriate mitigation measures to avoid impacts should unanticipated archeological resources be discovered during construction. The contract documentation 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 Preferred Alternative will incorporate the avoidance and minimization measures cited in the
FWS Section 7 Consultation 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.
Public Review and Comments
A Draft EA was circulated for public comment from September 23, 2018 through December 1 0, 2018. In accordance with 40 C.F.R. § 6.203(b)(1), a preliminary FONSI was made available for public review and comment as part of the Draft EA. A public information meeting was conducted by the County on October 10, 2018 in Pahala at the Ka'0 Gym Multi-Purpose Conference Room
to discuss the availability of the Draft EA and process for submitting comments. In addition, the County conducted two additional workshops for property owners that would be affected by the Proposed Action prior to the October 1 0 public information meeting. Lastly, the County voluntarily convened an additional public meeting in Pahala on March 21, 2019 to gain further input from property owners and provide financing options available to owners of certain parcels that would be affected by the Proposed Action.
EPA received detailed, technical, and other public comments from individuals, various agencies, and interested parties. In total, 77 comment letters were received, some of which included multiple individual comments. Responses to comments were developed and are attached to the Final EA as an appendix. No substantial changes to the Proposed Action were necessary as a result of
comments on the Draft EA.
5
Finding
After carefully considering the regulatory, environmental, and socioeconomic factors as described in the Final EA, EPA has determined that the Preferred Alternative of the Proposed Action will not
significantly affect the quality of the human environment within the meaning of Section 102(2)(C)
of NEPA. Accordingly, preparation of an environmental impact statement on the Proposed Action is not required and this FONSI formally documents EPA's finding of no significant impact in
accordance with 40 C.F.R. § 1508.13, 40 C.F.R. § 6.206, and 40 C.F.R. § 6.203(b).
APPROVAL
Tomas Torres
Director, Water Division
Pahala LCC Replacement Project
Pahala, Ka'O District, Hawai'i
Date
6
Office of Environmental Quality Control February 2016 Revision
Page 1 of 2
AGENCY
PUBLICATION FORM
Project Name: Pāhala Large Capacity Cesspool Replacement Project
Project Short Name: Pāhala Large Capacity Cesspool Replacement
HRS §343-5 Trigger(s): Use of State and County lands and funds
NEPA Trigger Use of congressional earmark funds
Island(s): Hawaiʻi
Judicial District(s): Kaʻu
TMK(s): 9-6-002:018
Permit(s)/Approval(s): State of Hawaiʻi Department of Health - Approval to Construct, Approval to Use, National Pollutant
Discharge Elimination System (NPDES) Permit, Underground Injection Well Abandonment, Noise
Noise Permit, Noise Variance (if required)
County of Hawaiʻi - Special Permit, Plan Approval, Grading Permit, Building Permit, Fence Permit,
Street Usage Permit
Proposing/Determining
Agencies:
County of Hawaiʻi Department of Environmental Management / U.S. Environmental Protection
Agency, Region 9
Contact Name, Email,
Telephone, Address
Dora Beck, 345 Kekūanāo‘a St., Suite 41, Hilo, HI 96720
Dora.Beck@hawaiicounty.gov (808) 961-8083
Accepting Authority: (for EIS submittals only)
Contact Name, Email,
Telephone, Address
Consultant: Wilson Okamoto Corporation (COH) / Eastern Research Group, Inc (EPA)
Contact Name, Email,
Telephone, Address
Keola Cheng, Project Manager
1907 S. Beretania Street, Suite 400
Honolulu, HI 96826
PahalaEA@wilsonokamoto.com tel: (808) 946-2277 / fax: (808) 946-2253
Status (select one) Submittal Requirements
___ DEA-AFNSI Submit 1) the proposing agency notice of determination/transmittal letter on agency letterhead, 2)
this completed OEQC publication form as a Word file, 3) a hard copy of the DEA, and 4) a searchable
PDF of the DEA; a 30-day comment period follows from the date of publication in the Notice.
__X_ FEA-FONSI Submit 1) the proposing agency notice of determination/transmittal letter on agency letterhead, 2)
this completed OEQC publication form as a Word file, 3) a hard copy of the FEA, and 4) a searchable
PDF of the FEA; no comment period follows from publication in the Notice.
____ FEA-EISPN Submit 1) the proposing agency notice of determination/transmittal letter on agency letterhead, 2) this completed OEQC publication form as a Word file, 3) a hard copy of the FEA, and 4) a searchable
PDF of the FEA; a 30-day comment period follows from the date of publication in the Notice.
____ Act 172-12 EISPN
(“Direct to EIS”)
Submit 1) the proposing agency notice of determination letter on agency letterhead and 2) this
completed OEQC publication form as a Word file; no EA is required and a 30-day comment period
follows from the date of publication in the Notice.
____ DEIS Submit 1) a transmittal letter to the OEQC and to the accepting authority, 2) this completed OEQC
publication form as a Word file, 3) a hard copy of the DEIS, 4) a searchable PDF of the DEIS, and 5) a
searchable PDF of the distribution list; a 45-day comment period follows from the date of publication
in the Notice.
____ FEIS Submit 1) a transmittal letter to the OEQC and to the accepting authority, 2) this completed OEQC
publication form as a Word file, 3) a hard copy of the FEIS, 4) a searchable PDF of the FEIS, and 5) a
searchable PDF of the distribution list; no comment period follows from publication in the Notice.
____ FEIS Acceptance
Determination
The accepting authority simultaneously transmits to both the OEQC and the proposing agency a letter
of its determination of acceptance or nonacceptance (pursuant to Section 11-200-23, HAR) of the
FEIS; no comment period ensues upon publication in the Notice.
Office of Environmental Quality Control Agency Publication Form
February 2016 Revision
Page 2 of 2
FEIS Statutory
Acceptance
Timely statutory acceptance of the FEIS under Section 343-5(c), HRS, is not applicable to agency
actions.
____ Supplemental EIS
Determination
The accepting authority simultaneously transmits its notice to both the proposing agency and the
OEQC that it has reviewed (pursuant to Section 11-200-27, HAR) the previously accepted FEIS and
determines that a supplemental EIS is or is not required; no EA is required and no comment period
ensues upon publication in the Notice.
____ Withdrawal Identify the specific document(s) to withdraw and explain in the project summary section.
____ Other Contact the OEQC if your action is not one of the above items.
Project Summary
Provide a description of the proposed action and purpose and need in 200 words or less.
The County of Hawaiʻi Department of Environmental Management proposes to construct wastewater system improvements to replace the existing large capacity cesspools (LCCs) currently serving Pāhala, in order to comply with U.S. Environmental Protection
Agency (EPA) regulations. The project improvements would include a new wastewater collection system located primarily within
public streets in the Pāhala community, and a treatment and disposal system on land to be acquired by the County (TMK: 9-6-002:
018). The project would be partially funded by an EPA grant and by the State of Hawaiʻi Department of Health Clean Water State
Revolving Fund loan program.
The collection system would consist of approximately 12,150 linear feet of 8 to 12-inch diameter underground gravity flow piping in
Maile, ʻIlima, Huapala, Hīnano, Hala Streets, Puahala, Pīkake, and Kamani Streets. The treatment and disposal facility would occupy
about 14.9 acres and consist of a headworks and an odor control unit, an operations building, four lined aerated lagoons, a
subsurface flow constructed wetland to remove nitrogen with an adjacent disinfection system to remove pathogens, and four
slowrate land treatment basins for further treatment and disposal of the treated effluent. A perimeter security fence would enclose
the entire facility. The existing LCCs and associated wastewater collection system would be abandoned.
ENVIRONMENTAL ASSESSMENT
for the
Pāhala Large Capacity Cesspool (LCC)
Replacement Project
EPA Grant XP-96942401
VOLUME 1
Pāhala, District of Ka‘u, County of Hawai‘i, Hawai‘i
TMK: 9-6-002:018
U.S. Environmental Protection Agency
Region 9
75 Hawthorne Street
San Francisco, California 94105
County of Hawai‘i
25 Aupuni Street
Hilo, HI 96720
FINAL
February 2020
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka’ū District, Hawai‘i
February 2020
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Final EA, Pāhala LCC Replacement Project
Pāhala, Ka’ū District, Hawai‘i
February 2020
TITLE PAGE
Prepared for:
U.S. Environmental Protection Agency and the County of Hawai‘i Prepared By:
Brown & Caldwell – contractor to the County of Hawai‘i Wilson Okamoto Corporation – subcontractor to Brown & Caldwell Eastern Research Group, Inc. – contractor to the U.S. Environmental Protection Agency
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka’ū District, Hawai‘i
February 2020
LIST OF PREPARERS
Eastern Research Group, Inc.:
Braden Rosenberg Patrick Goodwin Blake Fox J.J. Johnson April Eilers Kettie Rupnik Wilson Okamoto Corporation:
Earl Matsukawa John Sakaguchi Brown & Caldwell:
Craig Lekven Michelle Sorensen
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka’ū District, Hawai‘i
February 2020
PREFACE
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). The
Pāhala Large Capacity Cesspool (LCC) Replacement Project will be constructed with funds provided by EPA. EPA Region 9 has determined that NEPA requirements for the proposed project can be fulfilled by preparing an Environmental Assessment (EA) with a Finding of No Significant
Impact (FONSI).
Comparably, Hawai‘i Revised Statues (HRS) 343, as amended, and implementing rules under Hawai‘i Administrative Rules (HAR) 11-200 (Environmental Impact Statement Rules) require state
and local governmental agencies undertaking projects utilizing state or county lands or funds to consider the potential environmental impacts of a proposed project by preparing environmental review documentation. The Pāhala LCC Replacement Project will be constructed by the County
of Hawai‘i Department of Environmental Management (DEM) using County funds. Based on HAR § 11-200-9(a)(4), construction and use of the proposed project does not warrant the preparation of an environmental impact statement. Further, based on the findings and the assessment of potential impacts of the proposed project as set forth in HAR § 11-200-12 and documented in Section 8.1.1 of this Final EA, a FONSI is determined by DEM (see Section 8.1.2).
Federal NEPA regulations at 40 CFR § 1506.2 direct federal agencies to cooperate with state and local agencies to the fullest extent possible to reduce duplication between NEPA and state and local requirements. See also 40 CFR §§ 6.200 and 6.201. Hawai‘i law and regulations similarly direct agencies subject to HRS 343 to cooperate with federal agencies to the fullest extent possible (HRS § 343-5(h), HAR § 11-200-25(2)). This EA has been prepared to jointly meet the content and procedural requirements of both NEPA and federal cross-cutting authorities, and
HRS 343, as amended.
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TABLE OF CONTENTS
ACRONYMS ............................................................................................................................. vii
1 SUMMARY ......................................................................................................................1-1
2 PROPOSED PROJECT DESCRIPTION .........................................................................2-1
2.1 Background .........................................................................................................2-1
2.1.1 Pāhala Community ................................................................................2-1
2.1.2 Project Funding .....................................................................................2-1
2.1.3 Large Capacity Cesspools .....................................................................2-3
2.1.4 History of Wastewater Management in Pāhala ......................................2-4
2.2 Purpose and Need for Action ...............................................................................2-4
2.3 Proposed Action – Site 7 Alternative (Preferred Alternative) ................................2-5
2.3.1 Acquire Site 7 and Construct New Secondary Wastewater Treatment and Disposal Facility .............................................................................2-5
2.3.2 Construct New Wastewater Collection System .................................... 2-15
2.3.3 Close and Abandon Two Existing Large Capacity Cesspools .............. 2-18
2.3.4 Close and Abandon Existing Wastewater Collection System ............... 2-19
2.4 Proposed Action – Site 8 Alternative .................................................................. 2-19
2.5 Proposed Action – Site 9 Alternative .................................................................. 2-21
2.6 No-Action Alternative ......................................................................................... 2-23
2.7 Development of Site Alternatives and Selection of Preferred Alternative............ 2-23
2.8 Alternatives Considered but Not Carried Forward .............................................. 2-25
2.8.1 Other Site Alternatives ......................................................................... 2-25
2.8.2 Other Wastewater Treatment Alternatives ........................................... 2-26
2.8.3 Other Effluent Management Options ................................................... 2-29
2.9 Relationship to 2007 Final Environmental Assessment ...................................... 2-29
2.10 Other Considerations ......................................................................................... 2-30
2.10.1 Zoning Considerations ......................................................................... 2-30
2.10.2 Land Transfer ...................................................................................... 2-31
2.10.3 Hawaiʻi Revised Statutes (HRS) Chapter 205 Considerations ............. 2-31
2.11 Project Schedule and Implementation ................................................................ 2-32
3 DESCRIPTION OF EXISTING CONDITIONS, IMPACTS AND MITIGATION MEASURES ....................................................................................................................3-1
3.1 Climate ................................................................................................................3-1
3.1.1 Existing Conditions ................................................................................3-1
3.1.2 Impacts and Mitigation Measures ..........................................................3-1
3.2 Topography .........................................................................................................3-2
3.2.1 Existing Conditions ................................................................................3-2
3.2.2 Impacts and Mitigation Measures ..........................................................3-3
3.3 Geology ...............................................................................................................3-4
3.3.1 Existing Conditions ................................................................................3-4
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3.3.2 Impacts and Mitigation Measures ..........................................................3-4
3.4 Seismic Hazard ....................................................................................................3-5
3.4.1 Existing Conditions ................................................................................3-5
3.4.2 Impacts and Mitigation Measures ..........................................................3-5
3.5 Volcanic Hazard ...................................................................................................3-6
3.5.1 Existing Conditions ................................................................................3-6
3.5.2 Impacts and Mitigation Measures ..........................................................3-6
3.6 Soils .....................................................................................................................3-6
3.6.1 Existing Conditions ................................................................................3-6
3.6.2 Impacts and Mitigation Measures ..........................................................3-7
3.7 Surface Water ......................................................................................................3-9
3.7.1 Existing Conditions ................................................................................3-9
3.7.2 Impacts and Mitigation Measures – Construction Activities ...................3-9
3.7.3 Impacts and Mitigation Measures – Operation of Wastewater System 3-11
3.8 Groundwater ...................................................................................................... 3-12
3.8.1 Existing Conditions .............................................................................. 3-12
3.8.2 Impacts and Mitigation Measures ........................................................ 3-12
3.9 Flood Risk .......................................................................................................... 3-13
3.9.1 Existing Conditions .............................................................................. 3-13
3.9.2 Impacts and Mitigation Measures ........................................................ 3-14
3.10 Agricultural Lands .............................................................................................. 3-14
3.10.1 Existing Conditions .............................................................................. 3-14
3.10.2 Impacts and Mitigation Measures ........................................................ 3-18
3.11 Solid and Hazardous Waste ............................................................................... 3-18
3.11.1 Existing Conditions .............................................................................. 3-18
3.11.2 Impacts and Mitigation Measures ........................................................ 3-19
3.12 Flora .................................................................................................................. 3-20
3.12.1 Existing Conditions .............................................................................. 3-20
3.12.2 Impacts and Mitigation Measures ........................................................ 3-20
3.13 Fauna ................................................................................................................ 3-21
3.13.1 Existing Conditions .............................................................................. 3-21
3.13.2 Impacts and Mitigation Measures ........................................................ 3-22
3.14 Air Quality .......................................................................................................... 3-23
3.14.1 Existing Conditions .............................................................................. 3-23
3.14.2 Impacts and Mitigation Measures ........................................................ 3-24
3.15 Archaeological and Cultural Resources ............................................................. 3-25
3.15.1 Existing Conditions .............................................................................. 3-25
3.15.2 Impacts and Mitigation Measures ........................................................ 3-28
3.16 Socioeconomic Characteristics .......................................................................... 3-29
3.16.1 Existing Conditions .............................................................................. 3-29
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3.16.2 Impacts and Mitigation Measures ........................................................ 3-30
3.17 Traffic ................................................................................................................ 3-33
3.17.1 Existing Conditions .............................................................................. 3-33
3.17.2 Impacts and Mitigation Measures ........................................................ 3-33
3.18 Noise ................................................................................................................. 3-34
3.18.1 Existing Conditions .............................................................................. 3-34
3.18.2 Impacts and Mitigation Measures ........................................................ 3-35
3.19 Visual Considerations and Light Pollution .......................................................... 3-36
3.19.1 Existing Conditions .............................................................................. 3-36
3.19.2 Impacts and Mitigation Measures ........................................................ 3-37
3.20 Public Services – Police Protection .................................................................... 3-38
3.20.1 Existing Conditions .............................................................................. 3-38
3.20.2 Impacts and Mitigation Measures ........................................................ 3-38
3.21 Public Services – Fire Protection ....................................................................... 3-38
3.21.1 Existing Conditions .............................................................................. 3-38
3.21.2 Impacts and Mitigation Measures ........................................................ 3-38
3.22 Infrastructure – Water System ........................................................................... 3-39
3.22.1 Existing Conditions .............................................................................. 3-39
3.22.2 Impacts and Mitigation Measures ........................................................ 3-39
3.23 Infrastructure – Drainage System....................................................................... 3-40
3.23.1 Existing Conditions .............................................................................. 3-40
3.23.2 Impacts and Mitigation Measures ........................................................ 3-41
3.24 Infrastructure – Electrical and Communications Systems ................................... 3-43
3.24.1 Existing Conditions .............................................................................. 3-43
3.24.2 Impacts and Mitigation Measures ........................................................ 3-43
4 CUMULATIVE EFFECTS ................................................................................................4-1
4.1 Scope of Analysis ................................................................................................4-1
4.1.1 Geographic Scope of Analysis ...............................................................4-1
4.1.2 Past, Present, and Reasonably Foreseeable Actions within Geographic Scope of Analysis ...............................................................4-2
4.2 Cumulative Improvements and Impacts Analysis .................................................4-2
5 FEDERAL CROSS CUTTER REQUIREMENTS .............................................................5-1
5.1 Archaeological and Historic Preservation Act (54 U.S.C. § 312502) ....................5-1
5.2 Bald and Golden Eagle Protection Act (16 U.S.C. § 668-668c) ............................5-2
5.3 Clean Air Act (42 U.S.C. § 7401 et seq.) ..............................................................5-2
5.4 Coastal Barrier Resources Act (16 U.S.C. § 3501) ..............................................5-3
5.5 Coastal Zone Management Act (16 U.S.C. § 1451) .............................................5-3
5.6 Endangered Species Act (16 U.S.C. § 1531) .....................................................5-7
5.7 Environmental Justice Executive Order 12898 .....................................................5-9
5.8 Farmland Protection Policy Act (7 U.S.C. § 4201) ................................................5-9
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5.9 Fish and Wildlife Coordination Act (16 U.S.C § 661) ........................................ 5-10
5.10 Floodplain Management (Executive Order 11988, as amended by
Executive Orders 12148 and 13690) ................................................................. 5-11
5.11 Magnuson-Stevens Fishery Conservation and Management Act (16 U.S.C.
§ 1801) .............................................................................................................. 5-11
5.12 Marine Mammal Protection Act (16 U.S.C. §§ 1361 et seq.) .............................. 5-11
5.13 Migratory Bird Treaty Act (16 U.S.C. §§ 703 et seq.) ......................................... 5-12
5.14 National Historic Preservation Act (54 U.S.C. § 300101) ................................... 5-12
5.15 Protection of Wetlands (Executive Order 11990 (1977), as amended by
Executive Order 12608 (1997)) .......................................................................... 5-13
5.16 Rivers and Harbors Act (33 U.S.C. § 403) ......................................................... 5-14
5.17 Safe Drinking Water Act (42 U.S.C. § 300f) ....................................................... 5-14
5.18 Wild and Scenic Rivers Act (16 U.S.C. §§ 1271-1287) ....................................... 5-14
5.19 Clean Water Act (33 U.S.C. § 1251 et seq.) ....................................................... 5-15
6 PLANS, POLICIES AND CONTROLS .............................................................................6-1
6.1 State Land Use Plans and Policies ......................................................................6-1
6.1.1 Hawai‘i State Plan .................................................................................6-1
6.1.2 State Functional Plans ...........................................................................6-5
6.1.3 State Land Use District ..........................................................................6-6
6.1.4 Chapter 344, State Environmental Policy ..............................................6-7
6.1.5 Hawai‘i Coastal Zone Management Program ........................................6-7
6.2 Hawai‘i County Land Use Plans and Policies ..................................................... 6-12
6.2.1 Hawai‘i County General Plan ............................................................... 6-12
6.2.2 Ka‘ū Community Development Plan .................................................... 6-16
6.2.3 County of Hawai‘i Zoning ..................................................................... 6-21
6.2.4 County of Hawai‘i Special Management Area ...................................... 6-21
7 PUBLIC PARTICIPATION ...............................................................................................7-1
7.1 Community Outreach Program ............................................................................7-1
7.2 Outreach Since the Publication of the Draft EA ....................................................7-4
7.3 Response to Comments and Revisions to the Draft EA .......................................7-6
8 FINDINGS AND DETERMINATION ................................................................................8-1
8.1 Chapter 343, Hawaiʻi Revised Statutes (HRS) – Department of
Environmental Management (DEM) Finding of No Significant Impact
(FONSI) ...............................................................................................................8-1
8.1.1 Significance Criteria ..............................................................................8-1
8.1.2 Determination ........................................................................................8-4
8.2 National Environmental Policy Act – EPA Finding of No Significant Impact
(FONSI) ...............................................................................................................8-4
9 LIST OF PERMITS AND APPROVALS ...........................................................................9-1
10 CONSULTED PARTIES ................................................................................................ 10-1
10.1 Pre-Assessment Consultation ............................................................................ 10-1
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Pāhala, Ka’ū District, Hawai‘i
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10.2 Agencies and Organizations Consulted on the Draft EA .................................... 10-3
11 REFERENCES .............................................................................................................. 11-1
APPENDIX A. Responses to Pre-Assessment Consultation Letters
APPENDIX B. November 2019 Preliminary Engineering Report (PER)
APPENDIX C. August 2018 Biological Survey Report
APPENDIX C-1. Endangered Species Act Section 7 Consultation
APPENDIX D. Draft Archeological Inventory Survey (AIS) Report
APPENDIX D-1. National Historic Preservation Act Section 106 Consultation
APPENDIX E. EPA and County of Hawai‘i Responses to Comments on the Draft EA
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LIST OF FIGURES
Figure 2.1. Location of Pāhala Community on the Island of Hawaiʻi ........................................ 2-2
Figure 2.2. Elements of the Proposed Action .......................................................................... 2-6
Figure 2.3. Preliminary Site Plan for New Wastewater Treatment and Disposal Facility at
Site 7 (Preferred Alternative) ................................................................................................... 2-7
Figure 2.4. Preliminary Process Schematic for New Wastewater Treatment and Disposal Facility at Site 7 (Preferred Alternative) ................................................................................... 2-9
Figure 2.5. Example of Shade Ball Floating Cover in a Lagoon ............................................. 2-10
Figure 2.6. Preliminary Collection System Plan with New Wastewater Treatment and
Disposal Facility at Site 7 (Preferred Alternative) .................................................................. 2-16
Figure 2.7. Site 8 Alternative – Preliminary Site Plan for New Wastewater Treatment and
Disposal Facility .................................................................................................................... 2-20
Figure 2.8. Site 9 Alternative – Preliminary Site Plan for New Wastewater Treatment and Disposal Facility .................................................................................................................... 2-22
Figure 2.9. Locations of Nine Candidate Sites Considered for New Wastewater
Treatment and Disposal Facility ............................................................................................ 2-24
Figure 3.1. Pāhala Area Soils Map .......................................................................................... 3-8
Figure 3.2. Pāhala Area Land Study Bureau (LSB) Ratings Map .......................................... 3-16
Figure 3.3. Pāhala Area Agricultural Lands of Importance to the State of Hawai‘i (ALISH)
Classification Map ................................................................................................................. 3-17
Figure 3.4. Stormwater Culverts Near Site 7 ......................................................................... 3-41
Figure 6.1. Community Development Plan Land Use Policy Map .......................................... 6-17
LIST OF TABLES
Table 3.1 Demographic, Economic, and Social Characteristics of Pāhala and Hawai‘i County .................................................................................................................................. 3-31
Table 3.2 Permissible Sound Levels by Zoning District ......................................................... 3-35
Table 6.1 Hawai‘i State Plan Objectives and Policies .............................................................. 6-1
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ACRONYMS
AAQS Ambient air quality standards
AC Asphaltic concrete
ACS American Community Survey
AHPA Archaeological and Historic Preservation Act
AIS Archaeological Inventory Survey
ALISH Agricultural Lands of Importance to the State of Hawai‘i
AOC Administrative Order on Consent
ASTM American Society for Testing and Materials
BMP Best management practice
BOD5 Five-day biochemical oxygen demand
CAA Clean Air Act
CBRA Coastal Barrier Resources Act
CBRS Coastal Barrier Resources System
CDP Community Development Plan
CEQ Council on Environmental Quality
CFR Code of Federal Regulations
CREAT Climate Resilience Evaluation and Awareness Tool
CWRM Commission on Water Resource Management
CWSRF Clean Water State Revolving Fund
CZM Coastal Zone Management
CZMA Coastal Zone Management Act
dBA A-weighted decibel scale
DBEDT (State of Hawaiʻi) Department of Business, Economic Development and Tourism
DEM (County of Hawai‘i) Department of Environmental Management
DLNR (State of Hawaiʻi) Department of Land and Natural Resources
DOE (State of Hawaiʻi) Department of Education
DOH (State of Hawaiʻi) Department of Health
DOT (State of Hawaiʻi) Department of Transportation
DWS (County of Hawai‘i) Department of Water Supply
EA Environmental Assessment
EFH Essential Fish Habitat
EMS Emergency medical services
EO Executive Order
EPA (United States) Environmental Protection Agency
ESA Environmental Site Assessment
FEMA Federal Emergency Management Agency
FIRM Flood Insurance Rate Map
FONSI Finding of No Significant Impact
FPPA Farmland Protection Policy Act
FWS (United States) Fish and Wildlife Service
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GAC Granular activated carbon
HAR Hawai‘i Administrative Rules
HCC Hawai‘i County Code
HDPE High-density polyethylene
HELCO Hawaiʻi Electric and Light Company
HRS Hawai‘i Revised Statues
HUD (United States) Department of Housing and Urban Development
IBC International Building Code
LCC Large capacity cesspool
LF Linear feet
LSB (University of Hawai‘i) Land Study Bureau
LUC (State of Hawaiʻi) Land Use Commission
MBTA Migratory Bird Treaty Act
MMPA Marine Mammal Protection Act
msl Mean sea level
NAAQS National ambient air quality standards
NEPA National Environmental Policy Act
NFPA National Fire Prevention Association
NHO Native Hawaiian Organization
NHPA National Historic Preservation Act
NMFS National Marine Fisheries Service
NOAA National Oceanic and Atmospheric Administration
NPDES National Pollutant Discharge Elimination System
NRCS Natural Resources Conservation Service
NWI National Wetland Inventory
OEQC (State of Hawaiʻi) Office of Environmental Quality Control
OSHA Occupational Safety and Health Administration
PER Preliminary Engineering Report
PM2.5 Particulate matter with a diameter of 2.5 micrometers or less
PM10 Particulate matter with a diameter of 10 micrometers or less
PVC Polyvinyl chloride
REC Recognized environmental concern
ROW Right-of-way
SAAP Special Appropriations Act Project
SDWA Safe Drinking Water Act
SF Square feet
SHPD (Hawai‘i) State Historic Preservation Division
SIHP (Hawai‘i) State Inventory of Historic Places
SIP State Implementation Plan
SMA Special Management Area
SO2 Sulfur dioxide
SWPPP Stormwater Pollution Prevention Plan
TMK Tax Map Key
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February 2020 Page ix
TSS Total suspended solids
TTEE Trustees
UIC Underground Injection Control
U.S.C. United States Code
USDA United States Department of Agriculture
USDA-RD United States Department of Agriculture – Rural Development Program
USGS United States Geological Survey
UV Ultraviolet light
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1 SUMMARY
Proposing County
Agency: County of Hawai‘i Department of Environmental Management
345 Kekūanāo‘a Street, Suite 41 Hilo, HI 96720
Proposing Federal
Agency: U.S. Environmental Protection Agency, Region 9 75 Hawthorne Street
San Francisco, CA 94105
EA Preparers: Wilson Okamoto Corporation
1907 South Beretania Street, Suite 400 Honolulu, HI 96826 Contact: Earl Matsukawa, AICP, Project Manager
Tel: 808.946.2277; Fax: 808.946.2253 Eastern Research Group, Inc. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 Contact: Patrick Goodwin, Project Manager Tel: 703.615.4371
Project Location: Pāhala, Hawai‘i
Recorded Fee Owner: B. P. Bishop Estate, TTEES (Kamehameha Schools) (wastewater treatment and disposal facility site)
Tax Map Key: 9-6-002:018 (wastewater treatment and disposal facility)
9-6-005:036 and 9-6-005:044 (easements for wastewater collection system) 9-6-002:016 (LCC 1)
9-6-016:041 (LCC 2 and associated temporary easement) Various (laterals to wastewater collection system)
Area: 14.9 acres (wastewater treatment and disposal facility) 42.5 acres (parcel for wastewater treatment and disposal facility)
State Land Use
Classification: Urban Agricultural
County Zoning: Single and Multi-Family Residential; Village Commercial; Industrial; and A-20a
Proposed Action: The proposed wastewater collection system would be located within five streets in the western portion of the community (Maile,
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ʻIlima, Huapala, Hīnano, and Hala Streets) and three streets in the eastern portion of the community (Puahala, Pīkake, and Kamani
Streets).
The proposed wastewater treatment and disposal facility would occupy 14.9 acres and would consist of a headworks and an odor
control unit, an operations building, four lined aerated 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.
Impacts: No significant impacts are anticipated from construction and use of the collection system and the wastewater treatment and disposal facility.
Agencies Consulted in
Pre-Draft Assessment: Federal
U.S. Army Corps of Engineers
U.S. Fish and Wildlife Service
U.S. Department of Agriculture Natural Resources Conservation Service
National Oceanic and Atmospheric Administration
National Park Service Hawaiʻi Volcanoes National Park
State of Hawaiʻi
Department of Agriculture
Department of Accounting and General Services
Department of Business, Economic Development and Tourism (DBEDT)
DBEDT, Hawaiʻi State Energy Office
DBEDT, Land Use Commission
DBEDT, Office of Planning
Hawaiʻi Emergency Management Agency
Department of Health (DOH)
DOH, Office of Environmental Quality Control
DOH, Office of Director
DOH, Environmental Management Division
DOH, Environmental Planning Office
DOH, Clean Water Branch
DOH, Safe Drinking Water Branch
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DOH, Wastewater Branch
Department of Land and Natural Resources (DLNR)
DLNR, Engineering Division
DLNR, Division of Forestry and Wildlife
DLNR, State Historic Preservation Division
DLNR, Commission on Water Resources Management
Department of Transportation
Department of Hawaiian Home Lands
Office of Hawaiian Affairs
University of Hawaiʻi, Environmental Center
Hawaiʻi State Library
Hilo Regional Library
County of Hawaiʻi
Hawaiʻi Fire Department
Department of Parks and Recreation
Planning Department
Police Department
Department of Public Works
Department of Water Supply
Elected Officials
Congresswoman Tulsi Gabbard
State Senator Russell Ruderman
State Representative Richard H.K. Onishi
Councilmember Maile David
Native Hawaiian Organizations
Hawaiʻi Island Burial Council
Association of Hawaiian Civic Clubs
Charles Pelenui Mahi ʻOhana
Friends of ʻIolani Palace
Hawaiian Civic Club of Hilo
Kamehameha Schools
Kanu o kaʻĀina Learning ʻOhana
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Koʻolau Foundation
Makuʻu Farmers Association
Na Koa Ikaika Ka Lāhui Hawaiʻi
Office of Hawaiian Affairs
Pacific Agricultural Land Management Systems
Partners in Development Foundation
Piʻihonua Hawaiian Homestead Community Association
Other
Hawaiʻi Gas
Hawaiian Electric Light Company
Hawaiian Telcom
Spectrum Hawaiʻi
Mr. Stason Nishimura
Mr. Lance Uno
Ms. Julia Neal
The comments and responses are shown in Appendix A.
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2 PROPOSED PROJECT DESCRIPTION
2.1 Background
2.1.1 Pāhala Community
The community of Pāhala is located about 52 miles southwest of Hilo, in the Ka‘ū District, Island of Hawaiʻi. Pāhala is located west (mauka) of Māmalahoa Highway (State Route 11) 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 2.1
shows the location of Pāhala.
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 is undeveloped. The District of Ka‘ū is situated at the southern tip of the island and extends across the southern and southeastern flanks of Mauna Loa. 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 has a population of approximately 1,341 persons. 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 these communities, including wastewater treatment and disposal facilities.
Founded in 1826, C. Brewer and Company, Ltd. (C. Brewer) was both the oldest company in
Hawaiʻi and a major developer of the sugar industry in Pāhala. The Ka‘ū Sugar Company operations were closed in 1996, meaning that the sugar industry was no longer the major
agricultural activity of the Ka‘ū region. However, agriculture is still the major source of economic activity in the region. Today, macadamia nuts and coffee are the major crops grown within the
Ka‘ū District; however, growing competition from foreign producers is beginning to affect the
macadamia nut industry.
2.1.2 Project Funding
Planning level cost comparisons for the Pāhala Large Capacity Cesspool (LCC) Replacement Project are summarized in the November 2019 Pahala Wastewater Treatment Plant Preliminary
Engineering Report (PER), which is included as Appendix B. The capital cost of an aerated lagoon/constructed wetland/land application treatment and disposal facility is estimated at $16 million (plus $2 million for concrete lagoon lining if required) and has an estimated annual operations and maintenance cost of $227,000. The capital cost of closure of two community LCCs and a new collection system is estimated at $14 million. These numbers represent conceptual planning level cost estimates and do not include administrative, planning, design, land acquisition, or past project costs. Of the treatment alternatives that were deemed feasible and compared in the PER, the proposed wastewater treatment and disposal facility design has the lowest estimated capital cost and estimated annual operations and maintenance cost.
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
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Figure 2.1. Location of Pāhala Community on the Island of Hawaiʻi
Final EA, Pāhala LCC Replacement Project
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February 2020 Page 2-3
(a) EPA Special Appropriations Act Project Grant
In 2006, a U.S. Environmental Protection Agency (EPA) Special Appropriations Act Project
(SAAP) grant was awarded to the County of Hawaiʻi for the Ka‘ū LCC Replacement Project (XP-
96942401). The grant’s federal funding amount is $1.842 million which currently expires in October 2020. The purpose of the award is for the design and construction of wastewater system
improvements to replace LCCs in the Ka‘ū District. The initial SAAP grant was awarded for the design and construction of wastewater system improvements to replace other LCCs in the Ka‘ū
District in addition to those located in Pāhala. As stated in Section 2.1.4 (History of Wastewater
Management in Pāhala), LCCs in the community of Nāʻālehu were originally included in earlier funding considerations.
However, since the projects were separated as described in Section 2.9 (Relationship to 2007 Final Environmental Assessment), the grant workplan for the EPA SAAP grant has been revised to only include funding for the Pāhala LCC Replacement Project. This decision was made based on two points: 1) the federal grant funds would only cover a portion of one of the projects and 2)
it was expected that the Pāhala LCC Replacement Project could be completed faster than the
Nāʻālehu Project, and there was therefore a lesser likelihood that funds associated with the grant would be de-obligated before they could be spent. Consequently, the grant award and current work plan provide funding to replace only the two LCCs serving the Pāhala community.
(b) State Revolving Fund
This project may also be funded by the State of Hawaiʻi Department of Health (DOH) Clean Water State Revolving Fund (CWSRF) Program. 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 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.
2.1.3 Large Capacity Cesspools
In 1999, EPA promulgated 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 CFR § 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. Cesspools can release disease-causing pathogens and other pollutants (e.g., nitrates) into groundwater aquifers, streams, and eventually the ocean, thus leading to public health and environmental concerns.
In 2017, a state law, Act 125, was enacted requiring all cesspools not exempted by the DOH to be upgraded or converted to septic systems, or aerobic treatment unit systems, or connected to
sewage systems by January 1, 2050. This legislation will affect all parcels in Pāhala currently using cesspools. Unlike LCCs, which serve multiple dwellings and/or have the capacity to serve 20 persons or more per day, small capacity cesspools typically serve individual homes and are
not regulated under federal law.
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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. In September 2019, EPA accepted
the County’s request to extend the Pahala LCC closure date from June 2021 to April 2023.
2.1.4 History of Wastewater Management in Pāhala
Part of the Pāhala community is currently served by a sewer system comprised of substandard
gravity lines that convey sewage from approximately 109 parcels to two LCCs, which were previously owned and operated by C. Brewer. The existing sewer system was constructed in the backyards of the residential parcels and some within the streets. In 1996, C. Brewer shut down
its sugar growing and processing facility in Pāhala. In 2003, C. Brewer requested assistance from the County to close their LCCs as required by EPA.
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.1 It was 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 County Council.
On April 25, 2010, a community meeting sponsored by Councilman Guy Enriques was held at the
Pāhala Community Center to discuss the Nā‘ālehu and Pāhala LCC Replacement project. As part
of the meeting, an informational handout prepared by the County’s Wastewater Division provided
a brief history of the project documenting that, in 2004, Mayor Kim’s office used a ballot system distributed via mail to get input from property owners regarding different wastewater treatment/disposal alternatives for those residents who would no longer be served by the C.
Brewer system after LCC closure. 87 percent of the returned ballots were in favor of a new sewer collection system and a treatment and disposal system to be owned and maintained by the County. The handout indicated Mayor Kim’s office advised the property owners the County would move forward with new sewer systems for Nā‘ālehu and Pāhala on November 5, 2004. Additionally, the handout stated public meetings were held in both Nā‘ālehu and Pāhala in November 2006, to discuss the wastewater system alternatives. The handout included that
adequate land for the treatment and disposal system had not been identified in Pāhala.
2.2 Purpose and Need for Action
EPA’s purpose for the Proposed Action considered in this Environmental Assessment (EA) is to
provide the infrastructure necessary to enable the County to comply with the SDWA and fulfill the compliance provisions of the AOC between EPA and the County with respect to closure of the
Pāhala LCCs by April 2023.
1 C. Brewer did not commit to construct laterals on then-connected private properties whose owners did
not consent or on approximately 30 house lots and commercial businesses subsequently sold or having Deed restrictions making them liable for all costs associated with a new sewer system for those lots.
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Pāhala, Ka‘ū District, Hawai‘i
February 2020 Page 2-5
The County’s purpose for the Proposed Action considered in this EA, as stated in the June 22, 2017 EPA Region 9 AOC, is to provide an industry-standard wastewater collection system and a
secondary treatment and disposal facility, a basic service to the Pāhala community, to eliminate underground injection from LCCs it operates to help protect underground drinking water sources. Though closure of individual wastewater systems by the County is not part of the Proposed Action,
legislation described in Section 2.1.3 affects the future of all parcels in Pāhala utilizing cesspools for sewage disposal.
The need for action is driven by the public health and environmental concerns associated with
LCCs, as described in Section 2.1.3.
2.3 Proposed Action – Site 7 Alternative (Preferred Alternative)
This section describes the Preferred Alternative under the Proposed Action.
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 42.5-acre Site 7 that is 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 portion of the parcel (see Figure 2.3);
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 are described in further detail below and are depicted in Figure 2.2.
2.3.1 Acquire Site 7 and Construct New Secondary Wastewater Treatment and Disposal
Facility
Under the Preferred Alternative, the County would acquire, or obtain the right to develop and use, a 14.9-acre portion of Tax Map Key (TMK) 9-6-002:018 located about 0.5 miles (2,600 feet) south of the developed area of the community and identified as Site 7 for construction of a new secondary wastewater treatment and disposal facility. This 42.5-acre parcel is owned by Kamehameha Schools and used as a macadamia nut orchard. It is located adjacent to LCC #1. An at-grade irrigation system runs in a north-south direction which allows vehicle access between the rows. Slopes throughout Site 7 are between approximately 3 and 10 percent.
The County would work with the current landowner to subdivide the 42.5-acre parcel into two parcels: 1) a 14.9-acre parcel that would be owned by the County; and 2) a 27.6-acre parcel that
would include a 25-foot-wide by 1,500-foot-long utility easement and would continue to be owned by the current owner. See Figure 2.3 for a preliminary site plan showing the proposed location of the treatment and disposal facility within Site 7. This location is in the northeast corner of the Maile
Street and Māmalahoa Highway intersection outside of the State of Hawaiʻi Department of Transportation (DOT) right-of-way, east (makai) of an existing access road from Maile Street. Access to both parcels would be provided from driveways on Maile Street sited mauka of the
Maile Street and Māmalahoa Highway intersection.
Final EA, Pāhala LCC Replacement Project
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February 2020 Page 2-6
Figure 2.2. Elements of the Proposed Action
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
February 2020 Page 2-7
Figure 2.3. Preliminary Site Plan for New Wastewater Treatment and Disposal Facility at Site 7 (Preferred Alternative)
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
February 2020 Page 2-8
The County developed wastewater flow projections for the treatment and disposal facility using the City and County of Honolulu current wastewater standards, most recently updated during
2017. Based on these standards, the treatment and disposal facility would be designed to provide an average dry weather flow capacity of 190,000 gallons per day, which would be sufficient capacity to allow closure of the two LCCs.
The wastewater treatment and disposal facility would consist of the following primary components:
• Headworks preliminary treatment system. The headworks would protect the downstream
system operations from large objects, debris, and rags that may be present in the incoming
flows. It would include a below-grade concrete tank with channels to control flows; a
fiberglass or aluminum cover plate to facilitate foul air collection; an above-grade
screening system; a granular activated carbon (GAC) scrubber for odor control; and
influent flow measurement and sampling equipment. A free-standing roof structure over
the headworks would protect operators and equipment from rain and sun conditions.
• Aerated lagoon treatment system. A series of three 0.4-acre partial-mix aerated lagoons
would provide biological wastewater treatment. Partial-mix aerated lagoons allow the
solids to settle while providing enough aeration and mixing to meet the oxygen demands
of the naturally occurring micro-organisms in the system. The lagoons would be equipped
with high-speed floating aerators and lined with either high-density polyethylene (HDPE)
or concrete to prevent wastewater seepage into the subsurface.
• Subsurface flow constructed wetland. The approximately 0.6-acre wetland would provide
additional treatment of the effluent from the aerated lagoons via a process called
denitrification, which would decrease the land area required for the slow-rate land
application (see below). The subsurface flow wetland would consist of a shallow HDPE-
lined basin filled with gravel media and planted with emergent wetland vegetation. Effluent
from the lagoons would flow through the gravel media layer, with the effluent level being
maintained below the gravel surface at all times. Treatment would occur through physical, chemical, and biological mechanisms.
• Covered lagoon and disinfection. The 0.8-acre lined and covered lagoon (Lagoon 4) would
allow for effluent storage and algae removal, followed by disinfection to kill pathogens or
render them incapable of reproduction or harm to humans. The lagoon would feature a
floating cover of HDPE shade balls to prevent algae growth while allowing rainwater to
pass through. Disinfection would occur through the use of an ultra-violet system.
• Slow-rate land application system. Disposal of the treated and disinfected effluent would
be accomplished through land treatment in four groves of native, water-tolerant native
trees occupying a total area of approximately 8.0 acres. Application of the effluent would
be rotated to a different grove each day, resulting in a wet/dry cycle of 1-day wetting and
3-days drying. A lined irrigation equalization basin would be provided to facilitate grove
dosing.
Figure 2.4 shows a preliminary process schematic for the proposed facility. Figure 2.5 illustrates an example of a lagoon using a floating cover of shade balls.
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February 2020 Page 2-9
Figure 2.4. Preliminary Process Schematic for New Wastewater Treatment and Disposal Facility at Site 7 (Preferred
Alternative)
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
February 2020 Page 2-10
Figure 2.5. Example of Shade Ball Floating Cover in a Lagoon
EPA defines land treatment as “the application of appropriately pre-treated municipal and industrial wastewater to the land at a controlled rate in a designed and engineered setting. The purpose of the activity is to obtain beneficial use of these materials, to improve environmental quality, and to achieve treatment goals in a cost-effective and environmentally sound manner.” Land treatment systems rely on soil and vegetation to achieve treatment objectives, rather than energy-intensive mechanical equipment. As such, they are considered to be a form of “natural” treatment. The slow-rate land application concept is to intermittently apply wastewater to vegetation growing in permeable soils. As the applied effluent percolates through the soil matrix or is taken up by the crop, it is treated by physical filtration and biological mechanisms. After an application period or wetting period, the surface is allowed to dry, and oxygen can enter the soil
matrix, which aids aerobic biological treatment. The frequent wetting and drying of the soils also maintains the infiltration rate through the soil surface and minimizes clogging. This treatment process is effective for five-day biochemical oxygen demand (BOD5), total suspended solids
(TSS), trace organics, phosphorus, metals and pathogen removal. Furthermore, nitrogen removal can be significant if it is necessary to manage the system for that objective.
The facility would be appropriately designed to have capacity to accommodate upset conditions,
including pump and other equipment failures. In addition, the wastewater treatment and disposal facility would be designed not to preclude expansion to treat future average dry weather flows up to 360,000 gpd to meet the future needs of the community. As a matter of good engineering
practice, and to the extent practical, the wastewater treatment and disposal facility and collection system would be designed to be expandable should the County or community decide in the future
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February 2020 Page 2-11
that expansion is necessary in accordance with the requirements established in the Ka‘ū Community Development Plan Policy 120. See Appendix B.
It should be noted that wastewater flows from a community are highly variable, and peak flow rates from small community wastewater collection systems are typically three to five times higher than the average flow rates. The City and County of Honolulu standards take this variability into
account, and application of the standards results in conservatively designed facilities that are protective of human health and the environment in anticipated operational conditions.
The wastewater treatment and disposal facility would be designed and sized so the exposed (not
enclosed) treatment processes have sufficient free-board depth to accommodate the 24-hour, 100-year storm event at the site. The wastewater treatment processes would be designed to accommodate the peak flows caused by the design storm event, including precipitation that falls on the aerated and covered lagoon treatment system. The aerated lagoons would be lined with HDPE liners or concrete to prevent water seepage through the bottom and sides of the lagoons. The aerated lagoons would be designed with operational freeboard that would be available to
contain and to equalize lagoon flows during wet weather events. In addition, the slow-rate land application groves would be designed to completely contain both peak effluent flows and precipitation from a 100-year, 24-hour storm event.
The groves would be designed in accordance with EPA’s “Process Design Manual, Land
Treatment of Municipal Wastewater Effluents.” Effluent would be applied at a hydraulic loading rate that is a small percentage of the percolation rate of the soil, ensuring sufficient capacity for assimilation of peak effluent flow rates and precipitation from the design storm event.
Stormwater runoff generated mauka of the treatment and disposal facility project site would be directed around the perimeter of the site via diversion swales that would convey flow back to the existing drainage pattern that flows to the existing culvert at Maile Street. During heavy rain events, stormwater may temporarily back up behind the culvert. There would be no changes to
this culvert and the proposed treatment and disposal facility would not be located within the area of the culvert.
The treatment and disposal facility would be designed with an on-site drainage system to collect
runoff caused by impervious portions of the site. The system would collect the runoff via grated inlets or swales and the flows conveyed to on-site drainage detention systems, such as subsurface linear infiltration or depressed detention basins, to detain flows and volumes to their
pre-development condition. In addition, landscape buffers with soil berms would be constructed around most of the perimeter of the site to function as a secondary containment in the event of a large storm event. The design is to ensure there is no adverse impact on adjacent or downstream properties due to post-development flows.
A geotechnical engineering assessment of berm stability would be conducted during the design process for any berms constructed to act as containment in the event of a large storm event.
The wastewater treatment and disposal facility design would meet the requirements of Hawai‘i County Code (HCC) § 27-20(e) (Standards for subdivisions and other developments), which
mandates a site drainage plan to “comply with sections 27-20(a) and (b) and section 27-24, and shall include a storm water disposal system to contain runoff caused by the proposed development, within the site boundaries, up to the expected one-hour, ten year storm event as shown in the department of public works ‘Storm Drainage Standards’ unless those standards specify a greater interval.” Also, to meet the requirements of HCC § 27-20(f), the project site “shall not alter the general drainage pattern above or below the development.” Thus, no increase in flow
amount would be directed to either of the culverts at the highway as a result of the site development.
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Any “type” of wastewater treatment process (such as aerated lagoons, activated sludge
“mechanical” treatment plants, etc.) must incorporate both peak flows from the collection system
and precipitation that falls on the exposed process components into the design. The proposed
aerated lagoon system is a “flow through” process, not a storage reservoir. Wastewater from the community (including peak wet weather flows) would move through the lagoon system to the
disposal system and would not be stored in the lagoons. The proposed aerated lagoon system would be lined and designed to have adequate freeboard to contain the required storm event and not overflow offsite. Further:
• Stormwater flows generated outside of the treatment and disposal facility would be
directed around the site;
• An onsite stormwater collection and management system would contain runoff generated
at the facility; and
• The proposed land application groves would be designed to completely contain both peak
effluent flows and precipitation from a design storm event.
Because the above measures would be incorporated no matter what “type” of treatment process is chosen, flooding was not a criterion specifically evaluated as part of the treatment process selection.
The facility would also include an operations building (approximately 1,620 square feet (SF)), which would include an electrical room, restroom, and maintenance/storage room. The Draft EA described a chlorination system for this disinfection process. The Proposed Action has since been
revised to instead include an ultraviolet light (UV) disinfection system to reduce the use of chemicals at the facility. Disinfection would occur through a UV system which destroys microorganisms by affecting their deoxyribonucleic acid and ribonucleic acid and impeding their
ability to reproduce. A UV disinfection system is comprised of lamps, a reactor, and control panel. Wastewater flows parallel to the lamps in the reactor, while the control box provides a starting voltage and maintains the continuous electrical current needed. The UV reactor would be covered to contain the UV light within the facility, which would also prevent spill-over of the light to the surrounding area. Currently, most such systems are equipped with an automated lamp cleaning system to maintain lamp efficiency levels.
The Draft EA stated a pad-mounted diesel generator would be used as the emergency power supply in the event of power loss from the commercial system. The Proposed Action has since been revised to instead place the emergency generator within the operations building, which is now feasible due to the descoping of the chlorine disinfection system from the operations building in favor of ultra-violet disinfection. This would better protect the generator from corrosion and also provide a more secure location. The generator would be connected to an exterior, aboveground double-walled, concrete-encased fuel tank with capacity to support three consecutive days of operation. The tank would have a capacity of about 250 gallons. An electrical service panel would
be equipped with a manual transfer switch and generator receptacle mounted to the exterior wall of the building. This would provide a connection for a portable, trailer-mounted generator, in the event of emergency generator maintenance or failure during an extended power outage.
Emergency backup power would be required whether commercial power or alternative energy systems are utilized. It is feasible to partially augment commercial power utilizing photovoltaic solar panel arrays on the headworks and operations building rooftops. Potential use of alternative
energy systems would be further analyzed during the detailed design phase after loads and demand patterns have been determined. Also, the proposed electrical systems would be
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designed to accept or be adaptable to additional alternative energy input in the future if prioritized and funded by County Council.
The design of the treatment and disposal facility would not include utilizing alternative energy systems such as photovoltaic solar or wind as a total replacement for connecting to the HELCO grid due to:
• The need for consistent power supply;
• Up-front capital cost;
• The need for additional land to accommodate alternative energy systems;
• The objective to minimize the amount of land area removed from agricultural production;
and
• EPA-enforced project deadlines.
Methane gas is generated at wastewater treatment plants that use a treatment process called anaerobic digestion. The proposed wastewater treatment facility would be too small for anaerobic
digestion to be economical. As stated previously, the dry weather design flow to the Pāhala LCC Replacement Project for the Proposed Action is 190,000 gallons per day. Anaerobic digestion is only economically attractive for wastewater treatment and disposal facilities that treat at least 5 to
10 million gallons per day. In addition, the anaerobic digestion process requires primary clarifiers as part of the liquid treatment process, but primary clarifiers tend to be odorous in tropical climates, due to the relatively high wastewater temperatures. The proposed wastewater treatment and disposal facility would instead rely on natural treatment systems that require relatively low energy input. Additional detail regarding the preliminary analysis of alternative energy options can be found in the PER (Appendix B).
The entire wastewater treatment and disposal facility would be enclosed with a 6-foot-high chain-link fence, which would not be topped with barbed wire stringers, and posted to prevent public access. Gate(s) to the facility would be locked, except when County or other County-authorized personnel are present. The site fencing would not extend into the Maile Street or Māmalahoa Highway rights-of-way.
A 25-foot-wide by approximately 1,500-foot-long easement located along the eastern edge of the Kamehameha Schools parcel would be used to provide access to utilities from Maile Street to the treatment and disposal facility site. The easement would contain the incoming sewer line from the
collection system, potable water line, and above-ground electric service from the Hawaiʻi Electric and Light Company (HELCO) system. The easement would not be improved as an access road to the treatment and disposal facility. Potable water would be provided by extending the existing
water main in Maile Street operated by the County of Hawaiʻi Department of Water Supply (DWS), located approximately 2,000 feet northeast of the parcel, and by installing a service line in the easement to connect the new facility to that extended water main. The above-ground electric
service would likely consist of 480-volt, three-phase electrical power via a pole-mounted transformer to a service panel with a meter. Provided utilities would also include a land-line and/or cellular telephone telemetry system would be used to connect the wastewater treatment and disposal facility to Department of Environmental Management (DEM) operations staff based in Hilo or Kona and would facilitate automatic control of equipment and communication of operational data, malfunctions or intrusion. This system would have an auto-dialer to inform operators of alarm conditions. Operational procedures would be in place to address mechanical and electrical outages and other issues. Permanent, exterior site lighting would be limited to one shielded light mounted under the roof overhang of the operations building, and one shielded light
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near the headworks, and one shielded light at the UV disinfection system. The exterior lighting would be manually switched and used only for emergency purposes; the facility would normally
be unlit at night.
The treatment and disposal facility would be designed according to National Fire Prevention
Association (NFPA) 820 “Standard for Fire Protection in Wastewater Treatment and Collection
Facilities.” In accordance with Hawai‘i Fire Department requirements, Fire Department access and water supply to the site would be designed to comply with Chapter 18 of NFPA 2006 Uniform
Fire Code as amended by Hawai‘i County.
It is anticipated that the wastewater treatment and disposal facility would require only weekly visits by an operator based in Hilo or Kona to check and occasionally maintain it.
A geophysical survey of the treatment and disposal facility site would be performed during detailed design with the specific intent to locate potential subsurface voids (such as lava tubes) present beneath the site that may impact design and construction of the new facility. The presence of potential subsurface voids identified by the geophysical survey would be confirmed by
geotechnical borings. The intent of the subsurface investigations is to minimize the impacts of lava tubes on the project, including avoiding excessive damage to lava tubes and burials from construction of the treatment and disposal facility at Site 7.
Hazards related to hurricanes, such as wind, rain, and flood loads, would be taken into account during detailed design. Applicable regulations and standards, including IBC 2006, would be adhered to. The County would develop a facility management plan in accordance with applicable rules and regulations.
The aerated lagoon plant design would not result in the migration of aerosols outside of the site boundaries. In addition, disinfection processes selectively kill pathogens or render them incapable of reproduction or harm to humans. As outlined in Appendix B Section 3.2, continuous disinfection of the treated effluent would be provided to protect human health and the environment. The land
application groves would incorporate a distribution system at the ground surface which would not produce aerosols (Appendix B, Section 4.5.1).
To mitigate potential nuisance odors, the headworks would be equipped with an odor control
system with a GAC scrubber to remove odor. A package GAC scrubber passes the odorous air through a bed of activated carbon, which adsorbs the odorous constituents within the pore spaces of the carbon. The County currently operates GAC scrubbers at other facilities, and it has been
proven to be an effective means of odor control both locally and nationwide. The treatment lagoons would be equipped with mechanical aerators capable of maintaining sufficiently aerobic (with oxygen) conditions within the water column, which would prevent nuisance odor conditions from occurring under normal operating conditions. The disposal groves would be irrigated with fully treated and aerobic secondary effluent from the treatment process; irrigation with secondary effluent is not associated with development of nuisance odor conditions.
Construction of the wastewater treatment and disposal facility would require extensive site modifications, including the following:
• Clearing and grubbing of approximately 14.9 acres of macadamia nut trees within Site 7
to accommodate the new facility, and clearing of up to approximately 0.9 acres of trees
from within the utility easement – these trees would be disposed of at an approved site or
re-used for some other purpose;
• Removal of Cook pines (Araucaria columnaris) along Maile Street, limited to those
necessary to accommodate the main access to Site 7 via Maile Street and an existing
private road to be relocated northwest (mauka) of its current location in order to provide
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continued access between Maile Street and the macadamia nut processing plant
immediately northeast of Site 7.
• Excavation to a depth of approximately 10 feet to provide the necessary capacity for the
lagoons;
• Excavation to a depth of approximately 4 feet to provide the necessary depth for the media
in the subsurface constructed wetland;
• Excavation to a depth of approximately 6 feet to provide sufficient depth for the planted
groves and disposal of the effluent;
• Construction of a berm (with approximate 4-foot height) on all four sides of the groves to
contain rainfall from a 100-year, 24-hour storm event, with perimeter roads on the top of
the berms to provide operator access;
• Construction of internal service roads to provide access to the new facilities; and
• Relocation of the existing access road from Maile Street to the macadamia nut processing
facility (see above).
Prior to construction of the treatment and disposal facility, the County would need to obtain the
necessary discretionary and ministerial approvals from various federal, state, and county agencies.
2.3.2 Construct New Wastewater Collection System
Under the Preferred Alternative, 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 on Site 7. The new collection system would consist of a total of approximately 12,150 linear feet (LF) (2.3 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 between 176-177 lots (111 existing or previously connected lots, plus 65-66 newly accessible lots as described later in this subsection), with the specific number being dependent on the results of the topographic survey and the design of the collection system, conveying sewage to the new wastewater treatment and disposal facility at Site 7. Figure 2.6 shows the collection system plan.
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.
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
February 2020 Page 2-16
Figure 2.6. Preliminary Collection System Plan with New Wastewater Treatment and
Disposal Facility at Site 7 (Preferred Alternative)
The County would construct the collection system in two phases to ensure that residential units can maintain sewer system access all times. Phase 1 would construct segments totaling approximately 2,510 LF 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:
• A new 1,730-LF, 16-inch diameter line within the Maile Street ROW to intercept flows from
the existing system serving ʻIlima, Huapala, Hīnano, and Hala Streets and convey this
sewage to the new wastewater treatment and disposal facility at Site 7. This new line
would be sized to accommodate the flows from the entire community.
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
February 2020 Page 2-17
• A new 780-LF, 14-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.
Phase 2 would complete the new collection system by constructing segments totaling approximately 9,630 LF 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 an 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; most shoulder areas are somewhat improved or consist of grassy swales. Most of the streets have two travel lanes, are approximately 22 to 24 feet wide (plus shoulders), and do not have curbs or gutters. Residential lots along the streets have driveways with direct access to the travel lanes. Overhead utility poles are located outside the travel lanes. 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), sewer pipe installed, and then the trench would be backfilled and compacted. The cut portion of the AC pavement would then be patched with new AC material. Additional resurfacing may be required where trenches parallel 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.
As discussed in Section 3.3, geophysical and geotechnical surveys of the proposed collection system sites would be performed during detailed design with the specific intent to locate potential subsurface voids (such as lava tubes) which, if present beneath the sites, could require minor
adjustments to the preliminary collection system plan where practicable.
All accessible properties would be required to connect to the new wastewater collection system in accordance with HCC § 21-5. However, 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 systems. Once the actual costs are determined, County Council action is still required to approve the expenditure of funds on private property for existing connections.
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.
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
February 2020 Page 2-18
(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. Under the Preferred Alternative, 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.
Additionally, as discussed in Section 4, 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 following completion of the Proposed Action. 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.”
2.3.3 Close and Abandon Two Existing Large Capacity Cesspools
Under the Preferred Alternative, following DOH approval to operate the new wastewater treatment
and disposal facility and completion of Phase 1 of the new collection system, the County would close and abandon LCC 1 (located within TMK 9-6-002:016) and LCC 2 (located within TMK 9-6-016:041) as instructed by DOH Safe Drinking Water Branch UIC requirements. HAR § 11-23-19 sets forth the plugging and abandonment requirements, which state the following:
“(a) any owner who wishes to abandon an injection well shall submit an application, in
accordance with Section 11-23-12, containing the details of the proposed
abandonment. The DOH may require an abandoned well to be plugged in a manner
which will not allow detrimental movement of fluids between formations. If required,
plugging shall be completed by grouting with the tremie method in accordance with
the Honolulu Board of Water Supply's "Water System Standards", dated March, 1977;
or by some other method found appropriate and acceptable to the DOH; (b) The DOH
may order an injection well to be plugged and abandoned when it no longer performs
its intended purpose, or when it is determined to be a threat to the ground water
resource. The owner shall schedule the plugging so that DOH staff may be present to
monitor the abandonment operation.”
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
February 2020 Page 2-19
The specific methods to be used for closure of the LCCs have not yet been determined but would be consistent with the requirements described above.
The two LCCs in Pāhala are readily accessible for closure activities. LCC 1 is located in a parcel that has been previously cleared. However, it is currently overgrown with tall grasses and it may be necessary to clear a path for construction vehicles and equipment to access. Clearing an
access road (or other similar work) would not be necessary at LCC 2, which is located in the backyard of a residential lot with access via the house driveway. After the new treatment and disposal facility is operational, temporary easement(s) and a pipeline may be needed to bypass
LCC 2, connect the existing collection system to the new collection system in Pikake Street, and close the LCC.
2.3.4 Close and Abandon Existing Wastewater Collection System
Under the Preferred Alternative, following completion of Phase 2 of the new collection system, the County would close and abandon the existing C. Brewer wastewater collection system. This system includes some lines located in the back yards of residential lots and some within public
streets; therefore, abandoning the lines in place would minimize impacts related to their excavation and removal. The cut ends of the abandoned laterals to the collection system would be plugged with concrete to prevent unauthorized use of the old system and to prevent maintaining an unused underground hydraulic conduit.
2.4 Proposed Action – Site 8 Alternative
Under the Site 8 Alternative, the County would perform the same actions as described in Section
2.4 for the Preferred Alternative, with the following exceptions:
• The new secondary wastewater treatment and disposal facility would be constructed at
Site 8 instead of Site 7; and
• The new wastewater collection system would require approximately 1,600 feet of additional pipe within the ROW of Lower Maoula Road to reach Site 8.
The County would acquire, or obtain the right to develop and use, the area identified as Site 8 for construction of the new secondary wastewater treatment and disposal facility (see Figure 2.7).
The 45.2-acre parcel (TMK 9-6-002:021) containing Site 8 is southwest of and adjacent to the parcel containing Site 7, across Maile Street and above Māmalahoa Highway. As with Site 7, it is owned by Kamehameha Schools and used as a macadamia nut orchard. Site 8 is more steeply sloped than Site 7, with slopes between approximately 10 and 20 percent. An unnamed branch of Hi‘onamoa Gulch crosses from northwest to southeast near the center of the parcel.
The secondary wastewater treatment and disposal facility at Site 8 would consist of the same treatment components, and would require the same support facilities and infrastructure, as the facility described in Section 2.3.1 for the Preferred Alternative. However, because of the steeper slopes in Site 8, use of this site would require larger slow-rate land application groves totaling approximately 12 acres. Also, depending on the selected configuration of the wastewater treatment facility and the land application groves, this alternative could require trenching and construction of piping across an unnamed branch of Hi‘onamoa Gulch within the parcel.
As with the Preferred Alternative, the Site 8 Alternative would close and abandon LCC 1 and LCC 2 following completion of the wastewater treatment and disposal facility and Phase 1 of the new
collection system and would close and abandon the existing C. Brewer wastewater collection system following completion of Phase 2 of the new collection system.
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
February 2020 Page 2-20
Figure 2.7. Site 8 Alternative – Preliminary Site Plan for New Wastewater Treatment and
Disposal Facility
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
February 2020 Page 2-21
2.5 Proposed Action – Site 9 Alternative
Under the Site 9 Alternative, the County would perform the same actions as described in Section 2.3 for the Preferred Alternative, with the following exceptions:
• The new secondary wastewater treatment and disposal facility would be constructed at Site 9 instead of Site 7; and
• The new wastewater collection system would require approximately 3,200 feet of
additional pipe within the ROW of Maile Street and across Māmalahoa Highway to reach
Site 9.
The County would acquire, or obtain the right to develop and use, the area identified as Site 9 for construction of the new secondary wastewater treatment and disposal facility (see Figure 2.8). The 157-acre parcel (TMK 9-6-002:049) containing Site 9 is south of Sites 7 and 8, across
Māmalahoa Highway. As with Sites 7 and 8, it is owned by Kamehameha Schools and used as a macadamia nut orchard. Slopes throughout Site 9 are between approximately 3 and 10 percent. An unnamed branch of Hi‘onamoa Gulch crosses the parcel from north to south near the northwest corner of the site (through the upper westerly portion of the parcel).
The secondary wastewater treatment and disposal facility at Site 9 would consist of the same treatment components, and would require the same support facilities and infrastructure, as the facility described in Section 2.3.1 for the Preferred Alternative, and the slow-rate land application groves would total approximately 8 acres. However, an unnamed branch of Hi‘onamoa Gulch or the outfall from the concrete box culvert crossing the highway at the intersection of Maile Street
and Māmalahoa Highway near the upper portion of the parcel could affect the selected
configuration of the wastewater treatment facility and the land application groves. Potentially, to maximize energy efficiency by taking advantage of gravity flow, the headworks, lagoons and the subsurface constructed wetlands could be sited in the upper portion of the site, or the area closest
to the highway. In addition, because the site is located across Māmalahoa Highway from the
Pāhala community, it would require construction of piping and other utilities within the highway ROW, which would require approval by the State DOT. Also, depending on the selected
configuration of the wastewater treatment facility and the land application groves, this alternative could require trenching and construction of piping across an unnamed branch of Hi‘onamoa Gulch within the site. Finally, this alternative would require additional access roads to facilitate both construction and operation of the treatment and disposal facility and a slightly longer transmission line given its increased distance from the existing LCCs.
As outlined in the PER Section 8 (Appendix B), Site 9 earned a lower ranking than Site 7 for the following criteria: presence of and/or proximity to archaeological/cultural sites, existing vehicle access, power and potable water availability, and distance from the area of the wastewater collection system. Site 7 had a lower ranking than Site 9 in one category: topography. With the distance between the two sites less than 300 feet, they were ranked equally for the criteria of proximity of treatment units to existing occupied buildings.
As with the Preferred Alternative, the Site 9 Alternative would close and abandon LCC 1 and LCC 2 following completion of the wastewater treatment and disposal facility and Phase 1 of the new collection system and would close and abandon the existing C. Brewer wastewater collection
system following completion of Phase 2 of the new collection system.
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
February 2020 Page 2-22
Figure 2.8. Site 9 Alternative – Preliminary Site Plan for New Wastewater Treatment and
Disposal Facility
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
February 2020 Page 2-23
2.6 No-Action Alternative
Under the No-Action Alternative, the County would continue to use the two existing LCCs in
Pāhala and existing substandard gravity sewer lines. No additional properties would be added to the community sewer system under this alternative.
This alternative would not provide the Pāhala community with an acceptable wastewater collection, treatment, and disposal system; would not fulfill the purpose and need for action described in Section 2.2; and would result in non-compliance with the AOC between EPA and the County.
2.7 Development of Site Alternatives and Selection of Preferred Alternative
For several years, the County has considered various alternative sites in the Pāhala area for construction of a new wastewater treatment and disposal facility. The County has primarily considered sites that could be obtained at “minimal or no” cost and currently vacant sites to avoid displacement and relocation.
The County identified candidate sites based on three primary criteria. First, the site would have to be appropriate for the preliminary design of the treatment and disposal facility. For example, the site would need to have sufficient area to accommodate the facility and have soil conditions that are suitable for effluent management purposes. Second, access to the site would allow the County to meet the various requirements of the AOC that stipulated closure of the LCCs by June 2021.2 Third, the environmental impacts of construction of the treatment and disposal facility should be considered. For example, the site would need to be located where a treatment and disposal facility would not create nuisance impacts (e.g., odor or visual impacts) to the community.
Based on these three primary criteria, and considering additional suggestions from the Pāhala community obtained during Community Outreach meetings in December 2017, the County
identified nine candidate sites for the proposed wastewater treatment and disposal facility. Figure 2.9 shows the locations of these nine sites, identifies the landowners for each, and depicts their proximity to the existing LCCs. The County evaluated the suitability of each candidate site
according to the following process:
1. Twenty-one criteria within four general categories (environmental, social and cultural; location and site; land use and availability; and collection system and service area) were
established and defined for the analysis.
2. Six “fatal flaw” conditions were identified. Sites with a fatal flaw were eliminated from further consideration.
3. Relative weighting factors were established for each category and criteria. Environmental, social and cultural considerations, and location and site characteristics were weighted highest (35 percent each), the collection system and service area category was weighted at 20 percent, and the land use and availability category was weighted at 10 percent.
4. Sites were mapped using Geographic Information System. Data such as size, soil type, location of subsurface and surface water, topography, zoning and prevailing wind direction were determined.
5. Each site was evaluated and scored for the twenty-one criteria.
2 In September 2019, EPA accepted the County’s request to extend the Pahala LCC closure date from June 2021 to April 2023.
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
February 2020 Page 2-24
Figure 2.9. Locations of Nine Candidate Sites Considered for New Wastewater Treatment and Disposal Facility
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
February 2020 Page 2-25
6. A weighted ranking was determined for each site based on the weighting factors established in Step 3.
7. A preferred site was identified, based on the weighted high scores.
As a result of this process, the County identified three sites (Sites 7, 8, and 9) as reasonable alternatives for construction of the wastewater treatment and disposal facility under the Proposed
Action. The final scores for Sites 7, 8, and 9 were 4.33, 4.06, and 4.10 respectively, out of a total possible score of 5. Based on this analysis, Site 7 was selected as the Preferred Alternative. The site is easily accessible, has good soils for a land application system, and is close to the existing
LCCs. Site 8 has a stream bisecting the parcel lengthwise that complicates siting of the treatment and disposal facility. Site 9 also has some surface water within the parcel but is also more difficult to access given its location relative to existing roads. Site 9 would require construction of additional access roads to facilitate construction and operation of the treatment and disposal facility and would also require a longer transmission line given its distance from the existing LCCs.
Additional information on the specific scoring criteria and the results of the weighted analysis can
be found in the PER (Appendix B).
Section 2.3 describes the Preferred Alternative under the Proposed Action, including the preferred site (Site 7) for construction of the treatment and disposal facility. Sections 2.4 and 2.5 describe the other two sites (Sites 8 and 9, respectively) identified as reasonable alternatives for construction of the treatment and disposal facility under the Proposed Action. Section 2.8.1 describes the six sites (Sites 1-6) that were eliminated from consideration as reasonable alternatives.
2.8 Alternatives Considered but Not Carried Forward
2.8.1 Other Site Alternatives
During evaluation of site alternatives, six “fatal flaw” conditions were identified, and sites with a
“fatal flaw” were eliminated from further consideration. For more information on fatal flaw conditions, refer to the PER (Appendix B).
(a) Alternative Site 1: LCC Parcel
Site 1 (TMK 9-6-002:024) is owned by the County of Hawaiʻi. This parcel is only 0.41 acres, precluding it from being suitable for a wastewater treatment facility due to parcel size. As a result
of this “fatal flaw,” Site 1 was removed from further consideration.
(b) Alternative Site 2: Macadamia Nut Plant Site
Site 2 (TMK 9-6-002:016) is located adjacent to the 0.41-acre County LCC parcel. This parcel occupies about 64.8 acres, is privately owned and contains an active macadamia nut processing facility that occupies only a portion of the entire parcel. The site is located near the Pāhala
community meaning it would be close the collection system, limiting the environmental impacts related to construction of the influent and fire protection lines.
However, due to the soil type, Site 2 would require an area of approximately 200 acres to
accommodate the slow-rate land application basins. The unoccupied area of Site 1 is located on the northern portion of the parcel. As a result, the proposed treatment and disposal site would be nearly adjacent to a residential area and the Pāhala Hongwanji Mission. Use of this site would
potentially have adverse impacts to residents and the Pāhala Hongwanji Mission. For these reasons, use of Site 2 for the treatment and disposal facility is not considered a reasonable and feasible alternative.
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
February 2020 Page 2-26
(c) Alternative Site 3: HELCO Substation
Site 3 (TMK 9-6-002:043) is owned by HELCO and occupies 4.46 acres. It is currently used as a
substation to supply electrical power to the Pāhala community. The size of the parcel and the
requirement for approval from the State of Hawaiʻi Public Utilities Commission made use of Site 3 for the treatment and disposal facility not a reasonable and feasible alternative.
(d) Alternative Site 4: Mauna Loa Macadamia Nut Parcel
Site 4 (TMK 9-6-002:048) is located east of Māmalahoa Highway and occupies about 339 acres. The parcel is privately owned and contains an active macadamia orchard. An unnamed gulch
runs east-west between the highway and orchard area that would need to be crossed by influent and fire protection lines. The state may require a Stream Channel Alteration Permit should the two lines alter the stream banks. Placing the lines below the stream might require separate pump stations for the lines to access the treatment and disposal facility. The only access to Site 4 is
from Māmalahoa Highway. Approval would be needed to construct within the right-of-way. Due to the soil type, Site 4 would require an area of approximately 200 acres to accommodate the
slow-rate land application basins. For these reasons, use of Site 4 for the treatment and disposal facility is not considered a reasonable and feasible alternative.
(e) Alternative Site 5: State of Hawaiʻi
Site 5 (TMK 9-6-002:005), a vacant parcel owned by the State of Hawaiʻi, is located about 3,300
feet south of Maile Street below Māmalahoa Highway and occupies about 2,160 acres. Hi‘onamoa and Moa‘ula gulches lie between Maile Street and Site 3 and influent and fire protection lines would need to cross the gulches to reach the site. A Stream Channel Alteration Permit would be required should the two lines alter the stream banks. Approval would also be required to construct within the state right-of-way. Due to the soil type at Site 5, approximately 200 acres would be required to accommodate the slow-rate land application basins. For these reasons, use of Site 5 for the treatment and disposal facility is not considered a reasonable and feasible alternative.
(f) Alternative Site 6: State of Hawaiʻi
Site 6 (TMK 9-6-002:013), a vacant parcel owned by the State of Hawaiʻi, is located about 1.25
miles feet south of Maile Street above Māmalahoa Highway and occupies about 75.8 acres.
Influent and fire protection lines would need to cross two, and possibly three, gulches to reach the site. A Stream Channel Alteration Permit would be required if the lines alter the stream banks. Approval would also be required to construct utilities within the highway ROW. Because Site 6
lies above the highway, one or two pump stations might be required for the influent line. Due to the soil type at the site, approximately 200 acres of this soil type would be required to accommodate the slow-rate land application basins. For these reasons, use of Site 6 for the treatment and disposal facility is not considered a reasonable and feasible alternative.
2.8.2 Other Wastewater Treatment Alternatives
As previously discussed, wastewater flows from a community are highly variable, and peak flow rates from small community wastewater collection systems are typically three to five times higher than the average flow rates. The City and County of Honolulu standards take this variability into account, and application of the standards results in conservatively designed facilities that are protective of human health and the environment in anticipated operational conditions. The selected wastewater treatment alternative must be capable of achieving these standards and receiving discretionary and ministerial approvals. The following other wastewater treatment alternatives were evaluated.
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
February 2020 Page 2-27
(a) Septic Tank Alternatives
Several septic tank alternatives were identified and considered. Additional details on each
alternative can be found in the PER (Appendix B).
• Community Septic Tank. Based on current design criteria and current flow projections, an
approximately 800,000-gallon community septic tank would be necessary to provide the
extended detention times needed to optimize treatment performance, to avoid the need
for frequent septage pumping, and to account for peak flow rates. A community septic tank
of this size would require pumping on a 3-year interval. Septic tanks produce hydrogen
sulfide, reduced sulfur compounds, and other odorous gases; a community septic tank
would concentrate these emissions to a single point source, requiring treatment with a
dual-stage scrubber to avoid nuisance odor conditions. More significantly, a community
septic tank would not be capable of achieving the effluent quality standards (less than 30
mg/L of both BOD5 and TSS) specified in HAR 11-62. Therefore, use of a community
septic tank is not considered to be feasible.
• Converting LCC to Seepage Pit. Converting LCC 1 to a seepage pit regulated as an
injection well (LCC 2 could not be converted as it is on private land) would lead to
numerous potential compliance issues with HAR 11-23-07, which regulates injection wells.
The condition and structure of LCC 1 is unknown, and HAR 11-62-25 requires all new and
proposed effluent disposal systems to have a backup system. No such system could be
feasibly constructed as new injection wells are not allowed. A DOH variance necessitating
renewal applications every 5 years (which are not certain to be approved) would also be
required. No additional flow or connections would be allowed, meaning the proposed new
collection system could not conform to the project purpose, meet currently applicable
Hawai’i County Code requirements, or be expandable to serve the rest of the community.
• Leachfield Disposal. To meet DOH’s leachfield design criteria, a minimum of 30 acres of
land would be required to meet loading rate and redundancy requirements. Achieving
even distribution of effluent over a leachfield of this size would be challenging. Therefore,
leachfield disposal is not considered to be feasible.
• Conversion to Individual Wastewater Systems. Many of the lots in Pāhala are 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. Conversion to individual wastewater systems is therefore not considered
feasible.
• Package Plants. Package plants are pre-manufactured treatment facilities that may be
used to treat wastewater in small communities or on individual properties. Typical flows
for this technology range between 10,000 and 250,000 gallons per day. Although they
have the advantage of a small footprint and associated capital cost, these plants have
limited storage and equalization capacity, require the addition of chemicals, and are
operationally complex. In addition, they are energy intensive, and the solids produced
must be properly handled and disposed. Package plants do not commonly achieve
denitrification or phosphorus removal without additional unit processes. Often, package
plants utilize proprietary equipment, adding to operational costs and equipment availability
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
February 2020 Page 2-28
issues when replacements are unavailable or the equipment becomes obsolete. Because
of the need for daily operations and maintenance, on-site chemical storage and chemical
addition, mechanical complexity, lack of operational flexibility under changing conditions,
energy consumption and sludge handling concerns, package plants were removed from
consideration for the Proposed Action. Additional issues include access for construction
equipment, ownership of the units, and operation and maintenance of the units either by
the County of Hawaiʻi on private property or by individual property owners in this remote
location.
(b) Other Treatment Alternatives
Several other treatment alternatives were considered for the project. Additional details can be found in the PER (Appendix B).
• Option 1: Aerated Lagoons/Constructed Wetland/Land Application (Proposed Treatment
Method). Option 1 consists of an aerated lagoon treatment system with a constructed
wetland and disinfection, followed by land application for effluent management. This is the
proposed treatment method for the Pāhala wastewater treatment and disposal facility.
• Option 2: R-1 Treatment/Land Application. Option 2 consists of a treatment system
designed to produce recycled water that meets DOH R-1 recycled water criteria. The R-1
treatment system would be followed by land application.
• Option 3: R-1 Treatment/Seasonal Water Recycling. Option 3 consists of a treatment
system similar to Option 2 to produce R-1 recycled water. The recycled water would then
be used to irrigate nearby macadamia nut orchards. A water recycling analysis no
irrigation is typically needed between October and March because precipitation exceeds
evaporation during those months. During months when irrigation is unnecessary, recycled
water could be land applied.
• Option 4: R-1 Treatment and Storage for 100 Percent Recycling. Option 4 adds a seasonal
storage reservoir for recycled water. HAR 11-62 requires a disposal system for all recycled
water systems to provide a means for disposal of water that does not meet R-1 standards
or disposal of excess water should the seasonal storage reservoir capacity be exceeded
during an exceptionally wet year. Storage in open reservoirs can also lead to algae growth
and odor issues, requiring additional treatment to meet R-1 criteria before irrigation.
• Option 5: Maximum Practical Treatment. Option 5 consists of implementing advanced
wastewater treatment processes that represent maximum practical treatment, eventually
producing R-1 water. The same issues associated with utilizing or storing R-1 water
described for Options 3 and 4 would apply to Option 5.
The treatment alternatives described above were removed from consideration due for several reasons, as described below. Additional details can be found in the PER (Appendix B).
• Labor Requirements. Options 2 through 5 require daily site visits from operators based in
Hilo or Kona to conduct sampling required for R-1 compliance. These options also consist
of mechanical treatment technology that requires more operator attention. Option 1
(preferred alternative) requires weekly visits by treatment plant operators based in Hilo or
Kona, with periodic maintenance visits as needed.
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
February 2020 Page 2-29
• Operational Complexity. Options 2 through 5 require Grade IV certification through HAR
11-61 due to the complexity of treatment processes. Generally, the County has difficulty
attracting and retaining Grade IV operators. Option 1 requires an operator certification
level of Grade 1, the lowest level established by HAR 11-61.
• Energy Consumption. Options 2 through 5 require a substantial amount of electrical
energy due to the use of mechanical processes. Option 1 requires significantly less energy
due to the use of natural treatment systems.
• Sludge Management. Options 2 through 5 would require an anaerobic digester for sludge
management, with solids trucked to a landfill on a weekly basis. Option 1 would require
sludge removal from lagoons approximately once every 15 to 20 years. The resulting
solids are well-digested and inoffensive.
Additionally, Living Machine® technology was suggested during community outreach meetings. The technology has been implemented in buildings but there is no evidence of the technology being used at a municipal scale. The proposed non-proprietary treatment system (aerated lagoons and subsurface flow wetland) uses essentially the same natural treatment processes as the Living Machine®, but on a municipal scale.
2.8.3 Other Effluent Management Options
Several effluent management options were evaluated for feasibility as an alternative to land application. The options described below were removed from consideration due to their lack of feasibility and other concerns as outlined herein.
• Ocean Discharge. Ocean discharge of treated effluent is not considered a viable option
for Pāhala due to the long distance from the site to the shoreline, the high cost to construct
an outfall, stringent receiving water quality standards, high ocean water monitoring costs,
and the difficulty and length of time required to secure permits.
• Subsurface Disposal via Injection Wells. Per HAR 11-23, disposal to groundwater via an
injection well is not allowed west (mauka) of the DOH UIC line. Because the town of
Pāhala is located mauka of the UIC line, an injection well is not a viable option.
• Water Recycling. Water recycling was considered as an alternative effluent management
option but removed from consideration due to the low irrigation demand in the Pāhala area
and DOH requirements for all water recycling programs to have a 100-percent backup
system. Storage systems could be constructed but could lead to issues as described in
Section 2.8.2.
• Drain Field. A drain field (i.e., a leachfield) is an alternative effluent management option,
but was removed from consideration due to the reasons outlined in Section 2.8.2, most
notably the large amount of land required for a drain field and difficulties with distributing
effluent across such a large area.
2.9 Relationship to 2007 Final Environmental Assessment
In August 2007, the County of Hawaiʻi DEM issued a Final EA for the Nā‘ālehu-Pāhala LCC Conversion project. The County then made a Negative Declaration, also referred to as a FONSI, regarding the project on August 10, 2007, and published a notice of the determination in the August 23, 2007 issue of the Office of Environmental Quality Control (OEQC) publication The
Environmental Notice.
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As described in that Final EA, the County DEM initiated the project to address the closure of the
LCCs within the Nā‘ālehu and Pāhala communities. Although that Final EA addressed both
communities, the proposed improvements were essentially similar for both communities. For
Pāhala, the proposed project was to construct new sewer collection systems located primarily within the public ROWs and to replace the existing LCCs with six DOH-approved septic tanks for
wastewater treatment and reuse of LCC 1 as a seepage pit for the effluent disposal system.
After the issuance of the 2007 Final EA and Negative Declaration/FONSI, the County conducted additional study and evaluation of the proposed LCC conversion project. The County eventually
concluded that the LCC conversion project described in the 2007 Final EA would not meet the need to provide a collection system and a treatment and disposal facility, close the LCCs, and provide for the future needs of the Pāhala community. This determination was based on several factors, including the following:
• The capacity, structure, and condition of LCC 1 are not known; the County attempted to
determine the structure and condition of LCC 1 via inspection by closed circuit television
but could not ascertain its condition due to technological limitations. Additionally, poor
results from soil percolation tests influenced the County to consider looking at a larger
land area to construct a secondary treatment system to fulfill a longer-term vision of a
higher level of wastewater treatment and options for plant expansion for possible
community growth.
• HAR 11-62-25 requires new and proposed effluent disposal systems to have a backup
disposal system capable of handling the peak flow. However, a second seepage pit would
most likely not be allowed as the site is located mauka of the UIC line. Also, if the existing
seepage pit were to fail, a replacement could not be constructed.
• The Ka‘ū Community Development Plan was adopted as Ordinance No. 2017-66 in
October 2017. This plan requires the County to provide for eventual construction of a
collection system and treatment and disposal facility to serve the entire Pāhala community.
Although the Ka‘ū Community Development Plan was adopted subsequent to the 2007
Final EA, the Pāhala LCC Replacement Project would need to be consistent with the plan.
Increasing flow to the converted existing LCC used as a seepage pit would not be allowed
because it is located mauka of the UIC line. Therefore, the use of the existing LCC as a
disposal system could prevent the County from providing the community’s desired future
wastewater needs.
• As discussed in Section 2.8.2(a), the use of a community septic tank would present odor
concerns and would not be capable of meeting state effluent quality standards. Also, the
County would need a variance to HAR 11-62 from DOH to install the system as proposed
in the 2007 Final EA, which is not a long-term sustainable option.
Based on the above considerations, the County has decided not to move forward with the Pāhala LCC Conversion Project described in the 2007 Final EA and Negative Declaration/FONSI, and is instead evaluating the alternatives described in this Final EA.
2.10 Other Considerations
2.10.1 Zoning Considerations
Lands within the Pāhala community are designated “Urban” by the State Land Use Commission. The wastewater treatment and disposal project site is designated “Agricultural.”
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The 14.9-acre treatment and disposal facility would be owned by the County of Hawaiʻi and managed and operated by the County of Hawaiʻi DEM. The treatment and disposal facility would
be a “public use” as defined by HCC § 25-1-5, as a use conducted by or a structure or building owned or managed by the federal government, the State of Hawaiʻi, or the County to fulfill a governmental function, activity, or service for public benefit and in accordance with public policy.
To ensure compliance with relevant code, the County would obtain a Plan Approval from the Planning Department for the treatment and disposal facility. Also, the County would submit a Special Permit application through the Planning Department to the County Planning Commission.
2.10.2 Land Transfer
Construction of the portions of the collection system located within County ROWs would not require further land transfer approvals. As previously discussed, three segments of the planned collection system would be located within privately owned parcels. The County would obtain easements from the landowner(s) as part of the design process.
HCC Chapter 23 (Subdivisions) states that all subdivision plats and all streets or ways within the
County created for the purpose of partitioning land shall be approved by the County Planning Department Director. Further, HCC § 23-11 includes requirements on lot sizes. The County would subdivide the 14.9-acre treatment and disposal facility based on HCC § 23-11, which states the following:
“standards of this chapter shall not be applicable to public utility or public rights-of-way
subdivisions and their remnant parcels; provided that the County Planning Department
Director, upon conferring with the County Director of Public Works and Manager-Chief
Engineer of the County Department of Water Supply, may require necessary
improvements to further the public welfare and safety.”
Lastly, HCC § 23-12 (Submission of application and plans; filing) states the following:
“(a) A person desiring to subdivide land or desiring to partition land by creation of a
street within the County shall submit an application for subdivision and preliminary and
final plans and documents for approval as provided in this chapter and State law; (b)
No subdivision plat may be filed with the Bureau of Conveyances or Land Court until
submitted to and approved by the Planning Department Director.”
The County has conducted a Phase 1 Environmental Site Assessment of the entire 42.5-
acre parcel comprising Site 7. This review did not identify any recognized environmental
concerns or liabilities associated with acquiring portions of Site 7.
2.10.3 Hawaiʻi Revised Statutes (HRS) Chapter 205 Considerations
Lands within the Pāhala community are designated as “Urban” by the State Land Use
Commission. The wastewater treatment and disposal project site is designated as “Agricultural.” According to HRS § 205-4.5, permissible uses within the agricultural districts are the following:
“(a) Within the agricultural district, all lands with soil classified by the Land Study Bureau's
detailed land classification as overall (master) productivity rating class A or B shall be
restricted to the following permitted uses:
(1) Cultivation of crops, including crops for bioenergy, flowers, vegetables, foliage, fruits,
forage, and timber;
(2) Game and fish propagation;
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(3) Raising of livestock, including poultry, bees, fish, or other animal or aquatic life that
are propagated for economic or personal use;
(4) Farm dwellings, employee housing, farm buildings, or activities or uses related to
farming and animal husbandry.
(5) Public institutions and buildings that are necessary for agricultural practices;
(6) Public and private open area types of recreational uses, including day camps, picnic
grounds, parks, and riding stables, but not including dragstrips, airports, drive-in
theaters, golf courses, golf driving ranges, country clubs, and overnight camps;
(7) Public, private, and quasi-public utility lines and roadways, transformer stations,
communications equipment buildings, solid waste transfer stations, major water
storage tanks, and appurtenant small buildings such as booster pumping stations,
but not including offices or yards for equipment, material, vehicle storage, repair or
maintenance, treatment plants, corporation yards, or other similar structures;
(b) Uses not expressly permitted in subsection (a) shall be prohibited, except the uses
permitted as provided in Sections 205-6 and 205-8.”
Under HRS § 205-6, use of agricultural lands for non-agricultural purposes requires approval of a Special Permit by the County Planning Commission who submits the petition to the Land Use Commission, Office of Planning and State Department of Agriculture for their review and comment. HRS § 205-6 (Special permit) states the following:
“(a) …the county planning commission may permit certain unusual and reasonable
uses within agricultural and rural districts other than those for which the district is
classified. Any person who desires to use the person's land within an agricultural or
rural district other than for an agricultural or rural use, as the case may be, may petition
the planning commission of the county within which the person's land is located for
permission to use the person's land in the manner desired. Each county may
establish the appropriate fee for processing the special permit petition...”
Based on the above, a Special Permit application for the proposed treatment and disposal facility would be prepared by DEM for submittal to the County Planning Commission.
2.11 Project Schedule and Implementation
Information regarding project schedules, including EPA compliance dates, project updates and milestones can be found on the EPA website at: https://www.epa.gov/uic/county-hawaii-administrative-order-consent-closure-cesspools-pahala-and-naalehu.
The County will also provide information about the construction schedule for the collection system and the treatment and disposal facility to the DOE Facilities Development Branch Public Works
Administrator on request. Impacts and mitigation measures for addressing construction-related dust, traffic, and noise are presented in Sections 3.14.2, 3.17.2, and 3.18.2. Further, the County will coordinate with the DOE Student Transportation Services Branch Manager and the School in
order to minimize construction-related impacts to student transportation services.
If funds are available, appropriated by County Council, and encumbered in accordance with applicable law, the County of Hawai’i DEM is the County agency authorized to implement each
phase of the project’s completion including:
• Project schedules and budgets;
• Completion of the HRS Chapter 6E (Historic Preservation) process;
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• Conduct and monitoring of necessary field investigations, as required;
• Preliminary and final design;
• Preparation of construction contract documents including plans, specifications, and
boilerplate;
• Obtaining required plan and document approvals and clearances;
• Arranging for funding and coordination of right of entry, easement, and property
acquisition;
• Ensuring required permits are identified and obtained;
• Coordinating construction contract advertisement, bidding, award recommendations,
payments, and reimbursements with County of Hawai‘i Department of Public Works
Contracting, CWSRF, and EPA;
• Construction management, construction and field inspection of the proposed action;
• Development of O&M Manuals and preparation of record drawings;
• Operator training;
• Filing required reports and certifications;
• Operation, maintenance, and repair of the constructed facilities; and
• Collecting sewer user charges.
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3 DESCRIPTION OF EXISTING CONDITIONS, IMPACTS AND
MITIGATION MEASURES
3.1 Climate
3.1.1 Existing Conditions
(a)All Alternative Sites
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 (University of Hawaiʻi at Hilo, 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. For calendar year 2017, the Hawai‘i
Rainfall Summary shows a total of 40.58 inches rain at Pāhala, about 71 percent of the average of 57.00 inches. Below-average totals were also observed at two other rainfall gauges nearby at Kahuku Ranch and South Point.
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 likely to change in coming decades. Average annual precipitation is also likely to change, but climate models are uncertain in projections for Hawai‘i.
Based on ensemble model projections available through the U.S. Environmental Protection
Agency’s (EPA’s) Climate Resilience Evaluation and Awareness Tool (CREAT) Climate Scenarios Projection Map, projections for the area surrounding Pāhala range from a minor
decrease in annual precipitation (up to a 1.2-percent decrease) to up to a 17.3-percent increase by 2060, depending on the model scenario (hot/dry vs. warm/wet) (EPA, 2020). Climate models also predict changes in the intensity of storm events. Projections range from a 1.0-percent to a 19.8-percent increase in 100-year storm intensity by 2035, depending on the scenario used for
the modeling (“stormy” vs. “not as stormy”). By 2060, projections range from a 1.9-percent to a 38.5-percent increase in storm intensity (EPA, 2020). Another climate concern for coastal areas and islands is sea level rise.
3.1.2 Impacts and Mitigation Measures
(a)All Alternative Sites
There is the potential for construction-related and operational greenhouse gas emissions under the proposed action. Heavy equipment during construction may temporarily emit greenhouse gases during their operation and trucks used to transport supplies and equipment may cause
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emissions outside of the Pāhala area. Operation of the wastewater system under the Proposed Action also has the potential for minor greenhouse gas emissions due to operations at, and one-
per-week vehicle trips to, the proposed treatment and disposal facility site. These emissions are expected to be minor and are not expected to contribute substantially to emissions from the
Pāhala area.
Changes in average annual temperature are unlikely to impact the proposed wastewater treatment and disposal facility and its effluent because there is no discharge to surface water sources and therefore the temperature of streams in the area is unlikely to be impacted by the
project. Because all project locations are at least 3.3 miles from the coast and at least 580 feet above mean sea level (msl), sea level rise is not expected to impact the proposed project.
The large amount of uncertainty in climate projections makes it difficult to determine potential impacts of increased storm intensity on the project, but it is likely that there is some change in storm intensity in the next few decades. The new infrastructure under the Proposed Action would
be designed to collect sanitary wastewater only; the community’s stormwater would be managed
by other means. Some nominal inflow of stormwater into wastewater collection systems through manhole covers and other hydraulic pathways is normal and can be expected to increase with increasing storm intensity in the future. Because the proposed wastewater treatment and disposal facility does not intercept stormwater flows, there is unlikely to be a direct impact on inflow to the plant, although more intense or more frequent storms could impact the open aerated lagoons, subsurface flow constructed wetland, and land application processes from precipitation falling directly on these systems. Hazards related to hurricanes, such as wind, rain, and flood loads, would be taken into account during detailed design. Applicable regulations and standards, including International Building Code (IBC) 2006, would be adhered to. All potentially affected processes would be bermed to contain the 100-year, 24-hour storm event while maintaining at least two feet of freeboard to account for the uncertainty of the climate model projections.
(b) No-Action Alternative
Under the No-Action Alternative, the existing large capacity cesspools (LCCs) are at risk of impacts due to climate change, specifically changes in precipitation and storm intensity. The
nature of the LCCs makes them more exposed to these threats, potentially leading to impacts to groundwater, surface water, and other resource areas.
3.2 Topography
3.2.1 Existing Conditions
The Pāhala community lies on the slope of Mauna Loa, west (mauka) of Māmalahoa Highway and occupies an area of about 0.61 square miles. The developed area of Pāhala slopes down at
about 6 percent from the northwest to the southeast, from an elevation of 1,000 feet above msl to 800 feet above msl over a distance of 3,500 feet. The slope of the streets in the community approximately follows the contours to maintain level or appropriately sloped grades to allow
vehicle travel. On certain streets, this condition results in house lots on the downhill side of the street to be several feet below the road surface, while those on the uphill side lie several feet above.
(a) Preferred Alternative (Site 7)
The 42.5-acre preferred location for the Proposed Action is generally situated on a southeast facing slope with an average slope of approximately 8.7 percent and a maximum of 18.9 percent. The elevation of the parcel ranges from 580 to 780 feet above msl.
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(b) Alternative Site 8
The 45.2-acre Site 8 parcel faces approximately southeast with an average slope of
approximately 9 percent and a maximum of 28.2 percent. The elevation of the parcel ranges from approximately 540 to 740 feet above msl. An unnamed branch of Hi‘onamoa Gulch crosses the site from northwest to southeast near the center of the parcel.
(c) Alternative Site 9
The 157-acre Site 9 parcel faces approximately southeast with an average slope of approximately 7 percent and a maximum of 10 percent. The elevation of the parcel ranges from approximately
300 to 600 feet above msl. Two unnamed south-flowing branches of Hi‘onamoa Gulch cross portions of the parcel.
3.2.2 Impacts and Mitigation Measures
(a) Preferred Alternative (Site 7)
Construction of the new wastewater collection system would require trenching in locations throughout the Pāhala community, primarily within the right-of-way (ROW) of public streets plus
three segments within easements. Trenches would typically be about 3 feet wide and at least 6 feet deep. Due to the existing topography, several locations may also require installation of pumps. Once the line is placed in the trench, the affected area would be backfilled to restore the existing topography, resulting in minimal localized effects to the site topography.
The construction of the wastewater treatment and disposal facility would involve grading, excavating, and fill activities on approximately 14.9 acres at Site 7. Excavation to depths of approximately 4 to 10 feet would be required to provide necessary capacity for the lagoons, constructed wetlands, and planted groves. An approximately 4-foot tall berm would be constructed on all four sides of the groves to contain rainfall from a 100-year, 24-hour storm event. As discussed in Section 3.7.2, stormwater and erosion control plans would be developed, necessary construction permits would be obtained, and appropriate stormwater and erosion
control measures would be implemented.
Abandonment of the two LCCs and the existing wastewater collection system would not affect topography within the affected areas.
(b) Alternative Site 8
Under this alternative, the topographic impacts and mitigation measures would be similar to those described above for the Preferred Alternative (Site 7), with the following differences:
• Construction of an additional 1,600 feet of collection system piping to reach Site 8 would
require additional trenching. The affected areas would be backfilled to restore the existing
topography.
• Due to the steeper slopes at Site 8, construction of the wastewater treatment and disposal
facility would require grading, excavating, and fill activities on approximately 4 additional
acres to accommodate the terracing required to construct the slow-rate land application
groves on the steeper site.
(c) Alternative Site 9
Under this alternative, the topographic impacts and mitigation measures would be similar to those described above for the Preferred Alternative (Site 7); however, an additional 3,200 feet of
trenching would be required to extend the collection system piping, potable water line, and fire protection line to Site 9. The affected areas would be backfilled to restore the existing topography.
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(d) No-Action Alternative
The No-Action Alternative would not involve grading, excavation, or fill activities, and therefore
would not impact topography in the Pāhala area.
3.3 Geology
3.3.1 Existing Conditions
(a) All Alternative Sites
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 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. The presence of lava tubes underneath the proposed collection system site and the alternative wastewater treatment and disposal facility sites is possible but unknown. The County is in the process of performing non-intrusive geophysical surveys of sites for the Proposed Action, which would be followed by geotechnical investigations where necessary to confirm the presence or absence of lava tubes.
3.3.2 Impacts and Mitigation Measures
(a) All Alternative Sites
Grading, excavating, and fill activities during construction of the wastewater treatment and
disposal facility and the new collection system would occur no deeper than approximately 10 feet
below grade and thus would have negligible impacts on the geology in the Pāhala area. If subsurface investigations determine that voids (such as lava tubes) are present, the site plan for
the facility and/or collection system may require adjustments where practicable. If/when bedrock
is encountered during excavation for the Proposed Action, removal would be accomplished using
hydraulic and/or pneumatic hammers consistent with other construction activities on the Hawaiian
Islands. Standard local practice for underground cavities encountered during excavations is to collapse unstable sections and backfill the void with engineered materials. Should any unanticipated archeological sites or materials be encountered, all work in the affected area would
cease and the Hawai‘i State Historic Preservation Division (SHPD) would be notified. Work in that
area would cease until clearance to proceed from SHPD. An archeological monitoring plan will be
prepared during design where deemed necessary by SHPD for their approval prior to ground
disturbing activities.
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Abandonment of the two LCCs and the existing wastewater collection system would not affect geology within the affected areas.
Impacts and mitigation measures associated with seismic hazards are discussed in Section 3.4.
(b) No-Action Alternative
The No-Action 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.
3.4 Seismic Hazard
3.4.1 Existing Conditions
(a) All Alternative Sites
Earthquakes in the Hawaiian Islands are primarily associated with volcanic eruptions resulting
from the inflation or shrinkage of magma reservoirs beneath, which shift segments of the volcano.
The Island of Hawai‘i experiences thousands of earthquakes each year; however, most are so small that they can only be detected by instruments. Although difficult to predict, an earthquake
of sufficient magnitude could cause structural or other damage to public facilities including wastewater collection systems. The seismic risk classification of the Island of Hawai‘i is Zone 4 (County of Hawai‘i, 2007).
Earthquakes may occur before or during an eruption or may result from the underground movement of magma that comes close to the surface. On the Island of Hawai‘i, earthquakes directly associated with the movement of magma are concentrated beneath the active Kilauea and Mauna Loa Volcanoes. Typically, the risk of seismic activity and degree of ground movement decreases with the distance from these active volcanoes. A few of the island’s earthquakes are less directly related to volcanism. These originate in the zones of structural weakness at the base of the volcanoes or deep within the earth beneath the island.
Several destructive earthquakes have occurred on the Island of Hawai‘i. The locations of larger damaging on-island earthquakes since 1868 have generally occurred in the southeast portion of the island near Kilauea, with the most recent destructive earthquake on this south flank occurring on June 26, 1989 with a magnitude of 6.1. More recently, a magnitude 6.9 earthquake occurred
on May 4, 2018 offshore and east of Kilauea, though this earthquake was classified as non-destructive.
3.4.2 Impacts and Mitigation Measures
(a) All Alternative Sites
Hawai‘i County Code (HCC) § 5-3 indicates the “International Building Code, 2006 Edition” (IBC)
– copyrighted and published in 2006 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 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 wastewater treatment and disposal facility would be designed and constructed to meet the requirements of the 2006 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 emergency generator diesel fuel
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from the facility during a seismic event. The County would also develop a facility management plan in accordance with applicable rules and regulations.
(b) No-Action Alternative
The No-Action Alternative includes no construction or modification to existing conditions, and therefore would not impact seismic hazard in the Pāhala area.
3.5 Volcanic Hazard
3.5.1 Existing Conditions
(a) All Alternative Sites
In 1997, the USGS prepared an updated volcanic hazard zone map for the Island of Hawai‘i. The map shows lava flow hazard zones for the five on-island volcanoes. The current map divides this island into zones ranked from 1 (highest hazard) through 9 (lowest hazard) based on the probability of coverage by lava flows. Hazard zones from lava flows are based mainly on the location and frequency of both historic and prehistoric eruptions. Hazard zones also consider the larger topographic features of volcanoes that affect the distribution of lava flows.
Pāhala has been assigned a rating of Zone 3, which designates areas that are less hazardous than Zones 1 and 2 because of the greater distance from recently active vents and (or) because of topography. One to five percent of Zone 3 areas have been covered by eruptions since 1800,
and 15 to 75 percent have been covered within the past 750 years.
3.5.2 Impacts and Mitigation Measures
(a) All Alternative Sites
Based on the volcanic hazard map, the potential for damage 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, at this time, the volcanic hazard designation would not affect the construction and operation of a collection system or 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.
(b) No-Action Alternative
The No-Action Alternative involves no change to the status quo, so the current risk faced by
Pāhala and the LCCs would remain consistent.
3.6 Soils
3.6.1 Existing Conditions
(a) All Alternative Sites
Figure 3.1 shows the soil types in the Pāhala area, based on the U.S. Department of Agriculture Natural Resources Conservation Service (NRCS) Soil Survey of the Island. Soils at all alternative sites for the proposed wastewater treatment and disposal facility are primarily classified as Map Unit 521 – Nā‘ālehu medial silty clay loam, 3 to 10 percent slopes. This soil profile consists of approximately 17 inches of medial silt loam over hydrous silty clay loam with a depth to bedrock greater than 59 inches. This soil series has moderately high to high permeability characteristics, and generally consists of well-drained soils that formed in volcanic ash. As shown in Figure 3.1,
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the northwest half of Site 8 is composed of a slightly different soil type, Map Unit 522 – a Nā‘ālehu medial silty clay loam, 10 to 20 percent slopes.
The western portion of the collection system and the wastewater treatment and disposal facility
alternative sites consist of ash fields on pāhoehoe lava fields with soils that are well drained with a runoff class of low. The remainder of the area for the collection system has a soil classified as
Map Unit 567 – Puʻuʻeo- Nā‘ālehu complex, 3 to 10 percent slopes with land consisting of basic
volcanic ash fields over aʻa lava flows. Soils in these areas are somewhat excessively drained with a runoff class of very low.
3.6.2 Impacts and Mitigation Measures
(a) All Alternative Sites
The collection system would be constructed below the travelways or shoulders of the streets in the Pāhala community. These were previously disturbed when the streets and shoulders were originally constructed, and therefore the collection system would not create new adverse impacts to soils in the area.
Construction of the wastewater treatment and disposal facility would require removal of macadamia nut trees and clearing and excavating for construction of various improvements as described in Section 2.3.1. The soils within the proposed treatment and disposal facility at Site 7, as well as similar locations at Sites 8 and 9 that are also part of the macadamia nut orchard, were previously disturbed during planting of the macadamia nut trees. A high-density polyethylene (HDPE) or concrete liner would be placed below the excavated areas for the lagoons and subsurface flow wetland, mitigating adverse impacts to soils in the area as well as groundwater.
The proposed location for slow-rate land application basins would also require excavation to allow placement of the soil medium (approximately 8 acres for Sites 7 and 9, and approximately 12 acres for Site 8). Although the soils would be disturbed, the natural permeability characteristics of the soil would mitigate adverse impacts due to construction. The Proposed Action would
incorporate appropriate stormwater and erosion control measures in accordance with approved plans to ensure that soil erosion and transport during construction activities are minimized. Continued operation of the land application basins is not expected to cause adverse impacts to
surrounding soils due to the physical and biological treatment that would occur as effluent percolates through the soil and is taken up by planted vegetation.
Abandonment of the two LCCs and the existing wastewater collection system would not affect
soils within the affected areas.
(b) No-Action Alternative
The No-Action Alternative would not involve any direct or indirect impacts to soils. Continued use
of the existing LCCs and wastewater collection system would not result in impacts to soils in the
Pāhala area.
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
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Figure 3.1. Pāhala Area Soils Map
Final EA, Pāhala LCC Replacement Project
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3.7 Surface Water
3.7.1 Existing Conditions
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.
(a) Preferred Alternative (Site 7)
There are no surface water sources located within the Pāhala community near the existing or proposed wastewater collection system or the existing LCCs. Similarly, there are no surface water sources located within Site 7. The National Wetlands Inventory (NWI) Wetlands Mapper and USGS topographic maps identify no wetland features or streams within Site 7, 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 Site 7. On August 2018, a biological field survey was conducted at Site 7 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.
(b) Alternative Site 8
The unnamed branch of Hi‘onamoa Gulch crosses the Site 8 parcel from northwest to southeast near the center of the parcel. The gulch is classified as a riverine wetland in the NWI, but it is unknown whether this has been confirmed through a field survey and delineation. No other wetlands or surface water bodies are known to be located on this parcel.
(c) Alternative Site 9
Two unnamed south-flowing branches of Hi‘onamoa Gulch cross portions of the Site 9 parcel. Also, an unnamed east-flowing branch of Pāʻauʻau Gulch originates in the Site 9 parcel near the southeast boundary of the Site 7 parcel; this branch flows into Pāʻauʻau Gulch approximately 4,000 feet east of the Site 9 parcel. These gulches are classified as riverine wetlands in the NWI, but it is unknown whether this has been confirmed through a field survey and delineation. No other wetlands or surface water bodies are known to be located on this parcel.
3.7.2 Impacts and Mitigation Measures – Construction Activities
(a) Preferred Alternative (Site 7)
Given the cumulative areal extent of disturbance for the wastewater treatment and disposal facility and the new collection system, the Proposed Action would require coverage under a National Pollutant Discharge Elimination System (NPDES) construction stormwater permit. The NPDES
permit would include best management practice (BMP) measures such as use of silt fences or filter socks along the perimeter of each construction site and sediment traps at drainage inlets. Further, to minimize the potential for inadvertent leaks or spills of fuels and other petroleum
products, construction vehicles and equipment would be well maintained and kept at a temporary staging area where runoff is controlled.
Construction trenches would require the contractor to submit erosion control and stormwater control plans to the County and the Department of Health (DOH). Typically, the plans would require installation of erosion and sediment control BMPs. This may include the use of perimeter
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controls, such as silt fences or filter socks. These BMPs would be used to surround all construction sites, including material storage and staging areas and all construction sites related
to the collection system, to control pollutants in stormwater flow from the sites during construction.
The construction contract documents would require that a Site-Specific Construction BMP plan be prepared, addressing the measures that will be implemented onsite to prevent stormwater
pollution. This may include spill response measures, waste management procedures, and other pollution prevention activities. The NPDES permit would also require periodic BMP inspections (and maintenance of associated documentation) to ensure the construction activities are
compliant with the BMPs, Stormwater Pollution Prevention Plan (SWPPP), and NPDES permit.
Construction of the treatment and disposal facility would result in an increase in impervious surfaces. HCC § 27-20 requires an on-site drainage plan to accommodate any runoff caused by a proposed development, and requires all runoff to be retained within the site under conditions up to the design storm event. An on-site drainage system within the developed area would collect runoff via grated inlets or swales. These flows would be conveyed to on-site drainage detention
systems, such as subsurface linear infiltration or depressed detention basins, to detain flows and volumes to their pre-development condition. Typically, a 1-hour, 10-year storm event is used to determine the size of the on-site drainage system. As stated in HCC § 27-20:
“(e) All developments requiring a site drainage plan under Section 25-2-72(3) shall
submit such a plan for review and approval by the director of public works. The site
drainage plan shall comply with sections 27-20(a) and (b) and section 27-24, and shall
include a storm water disposal system to contain run-off caused by the proposed
development, within the site boundaries, up to the expected one-hour, ten year storm
event, as shown in the department of public works “Storm Drainage Standards,” dated
October 1970, or any approved revision, unless those standards specify a greater
recurrence interval. Expected runoff may be calculated by any nationally-recognized
method meeting with approval of the director of public works. Runoff calculations shall
include the effects of all improvements.
(f) Storm water shall be disposed into dry wells, infiltration basins, or other approved
infiltration methods. The development shall not alter the general drainage pattern
above or below the development.”
To ensure that there is no adverse impact on adjacent or downstream properties due to post-
development flows, landscape buffers with dirt berms would be constructed around most of the perimeter of the property, acting as secondary containment in the event of a large storm event. The planted groves for the land application system would be constructed with an approximately 4-foot-high berm on all four sides to contain the peak treated effluent flows plus rainfall from a 100-year, 24-hour storm event. Once the berms are constructed, no adverse effects to the surrounding areas would be likely for a storm of that magnitude. See Section 3.23 for more information regarding stormwater drainage.
Overall, the potential for construction-related impacts on surface water resources is temporary and adherence to BMPs will minimize the potential for these impacts to occur.
Abandonment of the two LCCs and the existing wastewater collection system would not affect surface waters within the affected areas. A single NPDES permit would be secured for all elements of the project, including LCC closure.
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(b) Alternative Sites 8 and 9
All of the same information presented above for the Preferred Alternative (Site 7) is relevant to
Alternative Sites 8 and 9. The same permits would be required, and the same or similar construction practices and BMPs would be implemented to mitigate potential impacts.
One difference between the Preferred Alternative (Site 7) and Alternative Sites 8 and 9 is the
presence of south-flowing branches of Hi‘onamoa Gulch in Sites 8 and 9, as shown in Figure 3.1. Depending on the selected configuration of the wastewater treatment facility and the land application groves, Alternative Sites 8 or 9 could require trenching and construction of piping
across the unnamed branches of the gulch. A Stream Channel Alteration Permit would be required should the piping alter the stream banks. Extra attention would be required to ensure that BMPs are implemented to prevent erosion and sedimentation that could impact the surface water bodies. To avoid this potential impact for Site 9 and to minimize costs, the headworks, lagoons and the subsurface constructed wetlands could be sited in the upper portion of the site, or the area closest to the highway which would result in other impacts. The potential for impacts
to surface water is greater at Sites 8 and 9 due to the presence of these unnamed streams.
(c) No-Action Alternative
The No-Action Alternative includes no construction activities, and therefore would not lead to a construction-related impact to surface water.
3.7.3 Impacts and Mitigation Measures – Operation of Wastewater System
(a) Preferred Alternative (Site 7)
EPA defines land treatment as “the application of appropriately pre-treated municipal and industrial wastewater to the land at a controlled rate in a designed and engineered setting. The purpose of the activity is to obtain beneficial use of these materials, to improve environmental quality, and to achieve treatment goals in a cost-effective and environmentally sound manner” (EPA, 2006).
The soils at the Preferred Alternative site (Site 7) are suitable for slow-rate land treatment. Slow-rate land treatment consists of irrigation of land and vegetation with treated effluent. Significant further treatment is provided as the water percolates through the soil and the vegetation uses the
nutrients in the effluent as fertilizer and transpires a portion of the applied water. The proposed wastewater treatment and disposal facility would be designed to intermittently apply treated effluent to native trees and vegetation growing on permeable soils. After an application period or
wetting period, the surface can dry, and oxygen can enter the soil matrix, which aids aerobic biological treatment. The proposed project estimates a reduction of greater than 99 percent in the annual load of five-day biochemical oxygen demand (BOD5), total suspended solids (TSS), and phosphorus to the environment compared to the current LCCs, and a decrease of 83 percent in the annual load of nitrogen compared to the existing LCCs. As a result, operation of the collection system and the treatment and disposal facilities would not create adverse impacts to surface
water resources of the Pāhala area.
(b) Alternative Sites 8 and 9
All of the same potential impacts described for the Preferred Alternative (Site 7) would apply for
Alternative Sites 8 and 9. However, the presence of streams on both Sites 8 and 9, as shown in
Figure 3.1, heightens the risk of potential impact from the wastewater treatment and disposal facility on surface water resources. BMPs could help mitigate these potential impacts, and siting
of the facility and land application sites would be important to avoid adverse impacts to surface
water sources.
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(c) No-Action Alternative
The No-Action Alternative includes no modifications to the existing landscape. As such, any
impacts to surface water resources would be caused by the existing LCCs. Closure of the LCCs is mandated by EPA regulations due to increased risk of impacts to water supplies and public health from continued use of LCCs.
3.8 Groundwater
3.8.1 Existing Conditions
Groundwater occurs within portions of geologic formations where aquifers receive and store
water. Depending on geology of the area, many 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.
(a) Preferred Alternative (Site 7)
On April 3, 2018, in response to the pre-assessment notification, the DOH Safe Drinking Water Branch indicated that the proposed wastewater treatment and disposal project site at Site 7 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 State of Hawai‘i Department of Land and Natural Resources (DLNR) Commission on Water
Resource Management (CWRM) maintains information on various types of wells throughout the state. 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 Site 7. The USGS topographic map shows the tank lies at about 1,120 feet above msl, which is approximately 480 feet higher in elevation than Site 7. A private well is located within TMK 9-6-002:016, the parcel that contains the existing LCC 1 and lies adjacent to Site 7. The CWRM has indicated this well is used for agricultural purposes, not for domestic purposes.
(b) Alternative Sites 8 and 9
The existing conditions discussed above for the Preferred Alternative (Site 7) are similar to Alternative Sites 8 and 9. Compared to the Preferred Alternative (Site 7) parcel, Site 8 is located a similar distance away, while Site 9 lies further away from the existing County drinking water well
and the private well. There is a well to the southeast of the Site 9 parcel, but the parcel is not located within a 1,000-foot radius of the well.
3.8.2 Impacts and Mitigation Measures
(a) Preferred Alternative (Site 7)
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 treatment and disposal facility would require excavation for the lagoons, subsurface constructed wetland, and the planted groves. Preliminary plans show the lagoons would require
about 10 feet of excavation, the subsurface constructed wetland about 4 feet and the planted
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groves about 6 feet. Construction activities would follow an approved SWPPP to minimize potential adverse impacts to groundwater resources and stormwater during construction
activities.
The lagoons and the subsurface constructed wetlands would be lined to prevent infiltration to the groundwater. As previously described, the incoming sewage would be treated in the lagoons,
further treated in the subsurface wetland, and then disinfected prior to application of effluent to the planted groves. The use of a slow-rate land application system following treatment in lagoons and the subsurface constructed wetlands would be very effective at removing pollutants and
nutrients from the effluent. Compared to the existing LCCs, the proposed wastewater treatment and disposal facility would decrease loading of BOD5, TSS, and phosphorus by greater than 99 percent, and the release of nitrogen by 83 percent.
For these reasons, and because of the separation (both elevation and horizontal distance) between Site 7 and the uphill County drinking water well, construction and operation of the
treatment and disposal facility would not affect groundwater resources in the Pāhala area.
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.
(b) Alternative Sites 8 and 9
The groundwater impacts and mitigation measures discussed above for the Preferred Alternative (Site 7) would also apply to Sites 8 and 9. The construction of the proposed collection system and the treatment and disposal facility at either Site 8 or Site 9 would not affect groundwater resources in the Pāhala area. As discussed above, the closure of the LCCs would remove a potential source of adverse impacts to groundwater and drinking water resources.
(c) 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.
3.9 Flood Risk
3.9.1 Existing Conditions
(a) All Alternative Sites
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. The unnamed branch of Hi‘onamoa Gulch runs through Alternative Sites 8 and 9 and approximately 200 to 600 feet west of the Site
7 parcel.
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 project area 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-
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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.
On April 16, 2018, in response to the pre-assessment notification, the State of Hawai‘i DLNR,
Engineering Division stated the responsibility for conducting research as to the flood hazard designation for the project site lies with the project proponent. Also on April 16, 2018 and in response to the pre-assessment notification, the County of Hawai‘i Department of Public Works
confirmed that the proposed treatment and disposal facility site at Site 7 is designated as Zone X on the FIRM and is outside the 500-year floodplain. See Appendix A for the responses to pre-assessment consultation letters.
3.9.2 Impacts and Mitigation Measures
(a) All Alternative Sites
The Proposed Action 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.
(b) 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.
3.10 Agricultural Lands
3.10.1 Existing Conditions
In 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 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
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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.
Figure 3.2 and Figure 3.3 show the LSB and ALISH classifications, respectively, in the project areas.
The 2012 Census of Agriculture-County provides the most recent information related to acreage planted for various fruits and nuts across the state and for each county. These data show a total of 18,006 acres of macadamia nuts were planted in the state, 17,387 acres of which were planted in the County, comprising about 96.6 percent of the state total.
(a) Preferred Alternative (Site 7)
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 Site 7, 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 machine tillability.
The ALISH map, Figure 3.3, shows the collection system is located in “unclassified” lands. The
ALISH map shows the proposed wastewater treatment and disposal facility at Site 7 would be located on approximately 20 percent “prime”, 40 percent “other” and 40 percent “unclassified” land.
(b) Alternative Site 8
Site 8 is located on a mix of “prime” and “other” agricultural land, with slightly more than 50 percent
classified as “prime.” There is no “unclassified” land at Site 8. Depending on the selected site plan, the land application groves would potentially be located on land classified as “prime.”
(c) Alternative Site 9
Site 9 is made up primarily of “unclassified” land, with sections of both “prime” land (northwest corner of the parcel) and “other” land (northeast and southwest edges of the parcel). The proposed facility would likely be sited at the northern end of Site 9, on land that is a mix of
“unclassified” and “prime” land.
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Figure 3.2. Pāhala Area Land Study Bureau (LSB) Ratings Map
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Figure 3.3. Pāhala Area Agricultural Lands of Importance to the State of Hawai‘i (ALISH)
Classification Map
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3.10.2 Impacts and Mitigation Measures
(a) Preferred Alternative (Site 7)
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 wastewater treatment and disposal facility at Site 7 would require removal of approximately 14.9 acres of macadamia
nut trees. 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.
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.
See Section 5.8 regarding consistency with the Farmland Protection Policy Act.
(b) Alternative Site 8
As discussed above, 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 wastewater treatment and disposal facility at Site 8 would require removal of approximately 18.9 acres of macadamia nut trees, which would not substantially affect the total macadamia nut acreage in the state or the County.
Under HRS 205, use of agricultural lands for non-agricultural purposes requires approval of a Special Permit by the County Planning Commission who, for projects greater than 15 acres, submits their decision to the State of Hawaiʻi Land Use Commission (LUC) for their approval. The LUC approval process involves a presentation by the County and review of comments from the Office of Planning. The Commission can approve the County decision, add, amend, or revise any conditions from the County. The additional time required for the discretionary Special Permit approval would make it difficult for Site 8 to meet the conditions of the AOC.
(c) Alternative Site 9
As discussed above, 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 wastewater treatment and disposal facility at Site 9 would require removal of approximately 14.9 acres of macadamia nut trees, which would not substantially affect the total macadamia nut acreage in the state or the County.
(d) 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 that is used for irrigation of agricultural lands.
3.11 Solid and Hazardous Waste
3.11.1 Existing Conditions
(a) All Alternative Sites
In July 2017, a Phase 1 Environmental Site Assessment (ESA) was prepared for the County of
Hawaiʻi in accordance with best practices and the requirements presented in the American
Society for Testing and Materials (ASTM) Standard Practice E 1527-13 (ASTM E 1527-13). The Phase 1 ESA was conducted on the entire 42.5-acre parcel comprising Site 7 (preferred alternative), including the 14.9-acre location for the proposed treatment and disposal facility.
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Details on the Phase 1 ESA objectives and guidelines can be found by reviewing ASTM E 1527-13.
A review was conducted of standard environmental (regulatory) records and specified historical records covering Site 7. A review of historical aerial photographs (1972, 1977, 1985, 1992 and 2001) identified no recognized environmental concerns (RECs). The site was identified as sugar
cane land from 1972 to 1977 and was converted to a macadamia nut orchard by 1985.
The surrounding area, including Sites 8 and 9, consisted primarily of sugar cane and vacant land prior to use for macadamia nut production. No properties adjacent to Site 7 had a historical use
that would represent a REC.
The Phase 1 ESA concluded no further assessment of the Site 7 parcel and proposed project site for RECs is recommended at this time. While no Phase 1 ESA was conducted for Sites 8 and 9, similar results to those for Site 7 might be expected given their similar historical and current uses.
3.11.2 Impacts and Mitigation Measures
(a) All Alternative Sites
Construction activities would involve the use of equipment containing fuel and other petroleum products that could be hazardous if released. Construction contract documents would require that a Site-Specific Construction BMP plan be prepared, and that materials and equipment to clean up leaks or spills be kept on the project site during construction. In addition, contract documents would include specifications for weekly inspections and reports to ensure the construction activities comply with BMPs. These measures would mitigate adverse impacts to the project site and surrounding area from potential releases of these materials.
The proposed wastewater treatment and disposal facility would have an emergency generator that would use diesel fuel stored in an above-ground double-walled, concrete encased tank. A leak from the inner tanks would be contained in the interstitial space between the walls of the tank. Tanks of this nature are equipped with a monitor system to detect leaks in the inner wall. It
is expected that at least a 250-gallon fuel capacity would be required to provide the desired 3-day backup supply of fuel for the proposed project. According to EPA, above-ground double-walled concrete tanks do not require an additional secondary spill containment system around its base.
The fuel tank design would incorporate overfill prevention features to minimize potential spills.
Ongoing operation of the proposed collection system and treatment and disposal facility is not expected to result in the creation of any hazardous waste on a regular basis.
The lagoons would need to be cleaned of sludge approximately every 20 years, and the material removed at that point would be substantially degraded from biological activity. Municipal sewage sludge is typically not considered a hazardous waste, and the material would be tested prior to end use or disposal to verify compliance with applicable requirements. The sludge removed from the facility could be landfilled, composted, or applied to land as a soil amendment and fertilizer in accordance with state and federal requirements.
The Proposed Action includes closure of existing LCCs in Pāhala. LCCs are considered
underground injection wells and are regulated by EPA and the State of Hawai‘i DOH’s UIC rules. Under the Proposed Action, the existing LCCs are considered waste management units and would be closed in accordance with DOH UIC regulations.
Abandonment of the existing wastewater collection system would not result in the generation of solid or hazardous waste. Any sanitary wastewater remaining in the existing collection system would be diverted to the new collection system prior to closure.
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(b) No-Action Alternative
The No-Action Alternative would maintain the existing LCCs in Pāhala. Under State DOH rules,
LCCs are considered waste management wells and are regulated by the DOH UIC program. Ongoing operation of LCCs is no longer allowed by EPA and their closure is mandated.
3.12 Flora
3.12.1 Existing Conditions
(a) All Alternative Sites
In August 2018, a botanical field study was undertaken along the streets and areas adjacent to
the proposed wastewater collection system and at the preferred location (Site 7) for the proposed wastewater treatment and disposal facility. Botanical field studies were not conducted for Site 8 or Site 9; however, similar results to those for Site 7 might be expected since these sites are also currently used for macadamia nut production. Appendix C shows the Biological Survey Report.
The area surveyed for the proposed collection system is along existing roadways within Pāhala. The survey in these areas indicated the vegetation was composed of maintained yards with
ornamental plants.
The field survey for the proposed 14.9-acre wastewater treatment and disposal facility at Site 7 indicated 52 species of vascular plants: two ferns, one gymnosperm, and 49 species of
angiosperms (flowering plants). Only two species (Ipomoea indica and Waltheria indica, 4 percent of the total number of observed species) 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, endangered, or of any special concern.
The field study indicated no species of plants currently listed or proposed for listing under either federal or State of Hawai‘i endangered species regulations were present along the alignment for the proposed wastewater collection system or at the preferred site (Site 7) for the wastewater treatment and disposal facility. The field survey determined that federally delineated Critical Habitat was not present in the Pāhala area. No equivalent designation exists under State law in Hawai‘i.
The macadamia nut orchard at Sites 7, 8, and 9 is a valuable commercial botanical resource but not an environmentally sensitive one. Similarly, the Cook pines (Araucaria columnaris) that line Maile Street along the western border of Site 7 and elsewhere are considered an important part of the community landscape element.
3.12.2 Impacts and Mitigation Measures
(a) All Alternative Sites
Based on the results of the botanical field study, construction of the new collection system and
new wastewater treatment and disposal facility is not likely to cause any adverse impacts on federally or state-listed threatened, endangered, or special concern botanical species in the
Pāhala area and would not impact federally delineated Critical Habitat. The Proposed Action
would require removal of several of the Cook pines (Araucaria columnaris) that line Maile Street along the western border of Site 7. All other Cook pines found elsewhere would be retained with no changes.
On April 23, 2018, as part of the pre-assessment consultation process, the U.S. Fish and Wildlife Service (FWS) provided a letter with recommended measures to avoid and minimize impacts to flora (see letter with reference number 01EPIF00-2018-TA-0275 in Appendix A). On February 15, 2019, EPA and the County of Hawai‘i concluded consultation with FWS in accordance with
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Section 7 of the Endangered Species Act. This consultation did not identify any potential effects to listed plants; however, the Proposed Action would adhere to additional biosecurity protocols
provided by FWS to prevent the introduction of invasive species (see 01EPI1F00-2019-1-0153 in Appendix C-1).
Abandonment of the two LCCs and the existing wastewater collection system would not affect
flora within the affected areas.
(b) No-Action Alternative
The No-Action Alternative includes no modifications to the existing LCC system, and therefore
would not impact flora.
3.13 Fauna
3.13.1 Existing Conditions
(a) All Alternative Sites
Mammalian Survey:
In August 2018, a biological field survey was conducted for mammalian species at the preferred
site (Site 7). 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 biological survey was limited to visual
and auditory detection coupled with visual observation of scat, tracks, and other animal signs. The survey identified no mammalian species within the survey area at Site 7. There was also no indication that pigs (Sus scrofa) utilize the survey area, despite reports from the community that
the area is occasionally used for hunting. The biological survey report is included as Appendix C.
Biological field surveys were not conducted for Site 8 or Site 9; however, similar results to those for Site 7 might be expected since these sites are also currently used for macadamia nut production.
Avian Survey:
The biological field survey conducted in August 2018 also identified avian species in the Site 7 area. Six avian count stations were sited roughly equidistant from each other; two were placed along the proposed wastewater collection system alignment and four were placed within the proposed location for the 14.9-acre wastewater treatment and disposal facility at Site 7.
The avian survey found a total of 175 individual birds of 13 species representing nine separate families. 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. All of the recorded avian species are established alien species. No native avian species were recorded during this survey of Site 7. Biological field surveys were not conducted for Site 8 or Site
9; however, similar results to those for Site 7 might be expected since these sites are also currently used for macadamia nut production.
The findings of the avian survey are consistent with the location of Site 7 (and Sites 8 and 9) and
the monoculture of macadamia nut trees present at all sites. The field survey report indicated 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. The petrel is listed as endangered and the shearwater as threatened under both federal and state endangered species statutes. As discussed in the August 2018 report, these seabirds are susceptible to impacts from outdoor lighting, which can result in seabird disorientation, fallout, and injury or mortality. Seabirds are attracted to lights and after circling the
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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.
3.13.2 Impacts and Mitigation Measures
(a) All Alternative Sites
The field survey recorded no species of animals currently listed or proposed for listing under either
the federal or state endangered species statutes. The preliminary proposed site plan shows no new infrastructure constructed above the existing tree line that could present a hazard to waterbirds.
The operations building at the proposed wastewater treatment and disposal facility would include down-shielded light fixtures mounted below the roof overhang. The light fixtures near the headworks and ultraviolet light (UV) disinfection system would also be down-shielded. These
lights would be used only in the event of an emergency at night. All fixtures would meet requirements for outdoor lighting as set forth in HCC 14 (General Welfare). These measures would help avoid or minimize any potential adverse impacts to the Hawaiian Petrel and Newell’s Shearwater.
After construction of the wastewater treatment and disposal facility is completed, the new lagoons would potentially attract various species of waterbirds, including the listed Hawaiian coot (Fulica
alai), the endemic sub-species of the Hawaiian stilt (Himantopus mexicanus knudseni), and Hawaiian goose (Branta (=Nesochen) sandvicensis). Experience at other County wastewater facilities with aerated lagoons (e.g., the Kealakehe wastewater treatment plant) has demonstrated that the aerated lagoon wastewater treatment process can present a highly attractive breeding area for local bird species.
On April 23, 2018, as part of the pre-assessment consultation process, the FWS provided a letter with information on various avoidance and minimization measures to avoid adverse impacts to listed species (see letter with reference number 01EPIF00-2018-TA-0275 in Appendix A). The
letter included measures for the Hawaiian hoary bat, the Hawaiian hawk (Buteo solitarius), and Hawaiian goose. FWS also recommended further consultation to determine whether the lagoons, despite their potential attractiveness to nesting seabirds, could represent a sub-optimal breeding
environment.
EPA and the County of Hawai‘i concluded consultation with FWS in accordance with Section 7 of the Endangered Species Act. 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. 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 [(Oceanodroma castro)], Hawaiian Stilt, and Hawaiian Coot, and the threatened Newell’s Shearwater” (see letter with reference number 01EPIF00-2019-I-0153 in Appendix C-1). The
Proposed Action would 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
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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. The FWS letter also includes suggestions for biosecurity protocols to prevent the introduction of harmful invasive species into local natural areas and areas with native habitat. These measures would be incorporated into the Proposed
Action.
The existing wastewater collection system is an aging system that has flaws and cracks that can provide access to pests such as rats and cockroaches. When the new collection system is
installed, the existing system would be plugged, and the subsequent lack of use would reduce available habitat and pest food sources. The new collection system would be more resistant to developing cracks and openings, resulting in fewer opportunities for pests to access the sewer as compared to the existing system.
Closure and abandonment of the existing LCCs would eliminate potential pest attractants. In
addition, the wastewater treatment and disposal facility would be located farther from the Pāhala
community than the existing LCCs, thus conveying sewage to a more distant facility that would incorporate design elements to reduce attractiveness to pests. These design elements would include features such as appropriate removal and management of waste from screening mechanisms to reduce food sources; use of aerators in lagoons to agitate water sources that otherwise could attract mosquitoes; and intermittent dosing of effluent to avoid standing water in groves. The Proposed Action would not be expected to contribute to pest-related concerns in
Pāhala.
Abandonment of the two LCCs and the existing wastewater collection system would not affect fauna within the affected areas.
(b) No-Action Alternative
The No-Action Alternative includes no modifications to the existing LCC system, and therefore
would not be likely to impact fauna.
3.14 Air Quality
3.14.1 Existing Conditions
(a) All Alternative Sites
Ambient air quality standards (AAQS) have been established at both the national (NAAQS) and state level for six criteria pollutants: carbon monoxide, nitrogen dioxide, sulfur dioxide, lead, ozone, and particulate matter (PM10 and PM2.5). The state has also set a standard for hydrogen sulfide. Hawai‘i ambient air quality standards are comparable to the national standards, although in some cases the Hawai‘i standards are more stringent than the national standards, such as for
carbon monoxide. For some other parameters, such as particulate matter, the national standards are more restrictive.
The DOH operates a network of air quality monitoring stations at various locations around the
state. In December 2016, the DOH issued the Annual Summary 2015 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 at the Ka‘ū High School and Pāhala Elementary School.
Established August 2007, the station was placed to monitor SO2 and PM2.5 from volcanic emissions. Criteria pollutant levels remain below federal and state ambient air quality standards throughout the state.
Existing air quality in the project area is affected mostly by air pollutants from vehicular, industrial, natural and/or agricultural activities and processes. Also, volcanic emissions affect air quality on
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the Island of Hawai‘i more than the other islands in the state. Since 1983, volcanic emissions from
eruptions of Kīlauea Volcano have periodically affected the project area.
A recent analysis by the USGS shows the composition of volcanic smog (vog) depends on how much time the volcanic plume has had to react with the atmosphere. In areas closer to the volcano, such as Pāhala, vog contains both aerosols and unreacted sulfur dioxide (SO2) gas. SO2
gas is colorless and invisible, but the tiny particles in vog create a visible light-colored haze by scattering sunlight and thus reduce visibility.
Vog concentrations on the Island are primarily dependent on the amount of SO2 emitted from
Kīlauea, the distance from the source vents, and the wind direction and speed on a given day. From May through September, the main wind direction in the Hawaiian Islands is from the northeast (trade winds) which occur about 80 to 95 percent of the time. Under trade wind conditions, vog travels around the southern part of the island. Most of the vog stays below 6,000 to 8,000 feet above msl, the usual height of the trade wind inversion. This layer of the atmosphere increases in temperature with altitude, inhibiting the rise of cooler, vog-laden air. When trade
winds are absent, which occurs most often during winter months, the entire Island, or even the entire state can be affected by vog.
Volcanic eruptions are considered natural events and therefore EPA may exclude the exceedances of the 1-hour NAAQS from attainment determinations.
Consistent with its rural nature, the Pāhala area has no major stationary sources of air pollution.
Further, the low level of vehicle traffic on Māmalahoa Highway and on the streets in the community limits mobile sources of emissions.
3.14.2 Impacts and Mitigation Measures
(a) All Alternative Sites
Short-term impacts on air quality could occur during construction of the proposed wastewater collection system and the wastewater treatment and disposal facility. Short-term impacts from
fugitive dust emissions would likely occur during the construction phases. To a lesser extent, exhaust emissions from mobile construction equipment, traffic disruption associated with wastewater collection system construction, and from workers commuting to the construction site
may also affect air quality during the period of construction. State HAR, 11-60.1 (Air Pollution Control) requires that there be no visible fugitive dust emissions at the property line. Hence, an effective dust control plan would be implemented to ensure compliance with state regulations.
During construction, fugitive dust emissions would be controlled to a large extent by watering of active work areas, the use of wind screens, keeping adjacent paved roads clean, and by covering open-bodied trucks. Other dust control measures may include limiting the area that can be disturbed at any given time and/or mulching or chemically stabilizing areas where construction is not actively occurring. These dust control measures would be most applicable to construction activities at the wastewater treatment and disposal facility project site.
After construction, motor vehicle traffic from County employees and others visiting the treatment and disposal facility project site would be a minor source of increased air pollutant emissions. As discussed in Section 3.17 (Traffic), management of the facility requires weekly visits by a single operator based in Hilo and any intermittent visits for maintenance purposes. Given the low ambient levels of pollutants and infrequent visits to the facility, any increases would not result in exceedance of federal or state AAQS for the six criteria pollutants.
The treatment and disposal facility would have an emergency standby diesel-powered generator for use during periods of outage of the commercial electrical service. The generator would also
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be operated periodically for testing to ensure proper operation. The operation and testing should not cause an exceedance of air quality standards.
Wastewater treatment plants can be a source of nuisance odors to the surrounding community if not properly designed or operated. Typically, nuisance odors are most commonly associated with anaerobic (without oxygen) conditions and with processing of residual solids. Incoming raw
sewage flows to the proposed wastewater treatment and disposal facility would first be routed to the headworks, which is the facility where the solids are removed from the flows.
As previously discussed, to mitigate potential nuisance odors, the headworks would be equipped
with an odor control system with a GAC scrubber to remove odor. A package GAC scrubber passes the odorous air through a bed of activated carbon, which adsorbs the odorous constituents within the pore spaces of the carbon. The County currently operates GAC scrubbers at other facilities, and it has been proven to be an effective means of odor control both locally and nationwide. The treatment lagoons would be equipped with mechanical aerators capable of maintaining sufficiently aerobic (with oxygen) conditions within the water column, which would
prevent nuisance odor conditions from occurring under normal operating conditions. The disposal groves would be irrigated with fully treated and aerobic secondary effluent from the treatment process; irrigation with secondary effluent is not associated with development of nuisance odor conditions.
Also, as previously discussed, the aerated lagoon plant design would not result in the migration of aerosols outside of the site boundaries under normal operating conditions. In addition, disinfection processes selectively kill pathogens or render them incapable of reproduction or harm to humans. As outlined in the Preliminary Engineering Report (PER) Section 3.2 (Appendix B), continuous disinfection of the treated effluent would be provided to protect human health and the environment. The land application groves would incorporate a distribution system at the ground surface which will not produce aerosols (Appendix B, Section 4.5.1).
Overall, construction and operation of the wastewater collection system and treatment and disposal facility would not result in significant impacts to air quality of the Pāhala area. Mitigation measures would be implemented, as appropriate, to minimize any potential impacts. By locating
the facility at least 0.5 miles away from the developed area of the community (including the Ka‘ū
High School and Pāhala Elementary School), the Proposed Action would provide a buffer to mitigate potential concerns associated with nuisance odors or aerosol migration that could arise
outside of normal operating conditions.
Abandonment of the two LCCs and the existing wastewater collection system would not affect air quality within the Pāhala area.
(b) No-Action Alternative
The No-Action Alternative includes no modifications to the current LCC system, and therefore is not likely to impact ambient air quality in the Pāhala area. Historically, air quality in the Pāhala area has met ambient standards during operation of the LCCs.
3.15 Archaeological and Cultural Resources
3.15.1 Existing Conditions
(a) Preferred Alternative (Site 7)
A 2016 survey of available information identified the presence of one historic site in the immediate vicinity of the proposed wastewater collection system. In Pāhala, the Kaʻū High and Pāhala Elementary School is listed on the State of Hawai‘i register of historic places. No other historic sites were identified within the areas planned for improvements.
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In November 2016, as part of the initial planning for LCC closure, the County contracted for a 1-day archaeological field inspection of Site 7, including the preferred location for the proposed
wastewater treatment and disposal facility. The purpose of the inspection, which involved pedestrian sweeps of the entire 42.5-acre parcel, was to determine if any historic properties or significant archaeological features were present. The inspection report stated that it is apparent
that ground modifications undertaken during the plantation period destroyed any evidence of pre-contact agriculture or settlement activities. Furthermore, bulldozing associated with the creation of the macadamia nut orchard appears to have leveled any plantation-era land features.
The 2016 inspection identified surface artifacts as the only evidence of past human activity on Site 7. Artifacts included a single traditional artifact as well as more numerous late post-contact artifacts. The single traditional artifact was a crudely shaped discoidal hammerstone found on the ground surface near the northern edge of Site 7 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. Given the possible agricultural
activity that may have taken place in the region during the pre-contact period, it is not surprising that a traditional artifact was found within the inspection parcel.
The 2016 inspection stated that, while the 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 Site 7 parcel, as well as evidence from plantation-era documents that the opening of a lava tube containing human remains once existed in the southeastern corner of the parcel, indicate that further archaeological studies may be necessary by SHPD before any development can be initiated. The 2016 inventory report stated that, at minimum, an Archaeological Inventory Survey (AIS) was necessary to fully document, map, date and collect the surface artifacts. It may also be necessary to test for the presence of subsurface cultural deposits through hand excavation or mechanical trenching. The report also stated it would be
advisable to limit the development footprint to exclude the southeastern corner of the 42.5-acre parcel.
Prior to conducting the AIS testing plan, SHPD needed to approve the AIS testing plan. To meet
this requirement, the County submitted the AIS plan to SHPD on March 22, 2018. On April 25, 2018, SHPD requested clarification. Responses were submitted to SHPD on July 31, 2018 including the findings from the 2016 field survey report and a map of the proposed wastewater
treatment and disposal facility. The map showed that the preferred site for the facility would avoid the area in which the traditional artifact was found during the 2016 inventory.
On August 20, 2018, SHPD approved the AIS plan and, between September 18, 2018 and January 10, 2019 a team of qualified archaeologists conducted a pedestrian survey of the proposed project site and completed subsurface trenching to determine the presence of archaeological resources. The work was undertaken in accordance with SHPD requirements, with the AIS approach accepted by SHPD in their August 20, 2018 letter. The results of the survey and subsurface trenching showed no burials or lava tube openings were identified on site. The completed AIS submitted to SHPD in March 2019 documents that a sealed lava tube opening is located east of the proposed wastewater treatment and disposal facility site, outside the proposed property boundary, and outside of the area of potential effect considered in consultation with
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SHPD as required by Section 106 of the National Historic Preservation Act (NHPA). The AIS was made available to the public on EPA and County websites.3,4
The AIS investigation was designed to comply with both federal and State of Hawai‘i environmental and historic preservation review requirements. Use of federal (EPA) funding means that the project is a federal undertaking, requiring compliance with NEPA and Section 106 of the
NHPA. As a project utilizing County funds, the project is also subject to historic preservation requirements found in HRS § 6E-8 and HAR § 13-275.
The AIS background research related to the collection system identified two properties that were
issued State Inventory of Historic Places (SIHP) designations for identification purposes—specifically, the historic Wood Valley Road/Coastal Road corridor (SIHP # 50-10-69-31088) and the historic Volcano Road corridor (SIHP # 50-10-69-31089). Both corridors were assessed as significant under Criterion (d) for yielding important information for research on former rights of
way in the history of the Pāhala community. The AIS stated that constructed elements of the portions of these road alignments in the area of the collection system have been thoroughly
impacted by the development of modern roadways, becoming Pīkake Street (SIHP # 50-10-69-31088) and Maile Street (SIHP # 50-10-69-31089), in Pāhala within the original corridors. Due to the impacts and changes to these roads in Pāhala over time, these historic properties only maintain integrity of location of the old corridor. The AIS concluded SIHP #s -31088 and -31089 are not eligible for inclusion on the National Register of Historic Places or the Hawai‘i Register.
As part of the AIS, the entire collection system and wastewater treatment and disposal facility sites were covered in close pedestrian sweeps. The AIS found both project sites have been completely altered by past residential/town and agricultural development. Historic remnants of the
sugar plantation are present throughout Pāhala and surrounding the project sites, but these remnants are all located outside the limits of the collection system and the treatment and disposal facility sites.
The AIS confirmed no significant artifacts or cultural deposits were observed on the ground surface within the proposed wastewater treatment and disposal facility 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. Lastly, although outside of the area of potential effect considered in consultation with SHPD, research conducted during the AIS showed a sealed lava tube opening is located east and outside
of the proposed wastewater treatment and disposal facility site.
On March 29, 2018, the County, as the EPA designated representative, initiated consultation for this project pursuant to Section 106 of the NHPA. Consultation letters were delivered to invite comments from organizations that may attach religious or cultural significance to properties affected by the Proposed Action. A total of 14 letters were mailed to various Native Hawaiian Organizations (NHOs) requesting comments (see Section 10); no responses have been submitted to the County. The list of NHOs was generated by EPA for NHPA Section 106 and HRS Chapter 6E compliance using the U.S. Department of the Interior, Office of Native Hawaiian Relations, Native Hawaiian Organization Notification List (Updated December 4, 2017). The HRS Chapter 6E determination and Section 106 review packet were submitted to SHPD with the Draft
3 On March 11, 2019, the AIS was posted on the EPA web site: https://www.epa.gov/sites/production/files/2019-06/documents/cover-letter-
draft_archaeological_inventory_survey_pahala_wwtp-optim-2019-03-11.pdf.
4 The AIS was made available for download from the County’s website:
http://records.co.hawaii.hi.us/weblink/1/edoc/100962/Draft%20Archeological%20Inventory%20Survey%20-%20Pahala%20WWTP%20and%20Sewer%20System.pdf.
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AIS on March 13, 2019. In addition, the County sent a letter to SHPD on October 9, 2019, again requesting acceptance of the previously submitted Draft AIS findings.
On September 23, 2018, notice of availability of the Draft EA was published in the OEQC The
Environmental Notice. Subsequently, on September 26, 2018, a public notice was published in the Hawaii Tribune Herald, West Hawaii Today newspapers, and the online Ka‘ū News Brief. The
public notice announced that a public information meeting was to be conducted by the County on October 10, 2018 in Pāhala at the Ka‘ū Gym Multi-Purpose Conference Room to discuss the Draft EA as it related to DEM’s compliance with HRS 343 requirements. A second part of the meeting
addressed Section 106 of the NHPA involving consultation with NHOs and Native Hawaiian descendants with ancestral lineal or cultural ties to, cultural knowledge or concerns for, or cultural religious attachment to the proposed project area. During the October 10 meeting, attendees were invited to provide information about the proposed project area. Eight persons placed their names on a sign-in sheet to contribute during the second part of the meeting related to Section 106; however, no comments or information from the public were forthcoming during this meeting.
To request clarification of comments received on the Draft EA, a letter was sent to the Pele Defense Fund requesting information about potential known lava tubes in the project area via certified mail on November 14, 2018 but no response was received.
(b) Alternative Sites 8 and 9
Alternative Sites 8 and 9 have similar existing conditions for historical resources as presented above. Although Sites 8 and 9 were not surveyed, they are both currently used as macadamia nut orchards and thus would be expected to exhibit similar ground modifications as Site 7. The ground modifications from the plantation period would have destroyed any evidence of pre-contact agriculture or settlement activities, in addition to extensive disturbance from bulldozing during creation of the macadamia nut orchard.
3.15.2 Impacts and Mitigation Measures
(a) Preferred Alternative (Site 7)
Based on the AIS, no properties eligible for inclusion on the National Register of Historic Places or the Hawai‘i Register are present within the area of potential effects for the Preferred Alternative,
and no significant artifacts or cultural deposits on the ground surface and no cultural deposits or lava tubes were encountered during subsurface testing. Thus, in accordance with federal regulations (36 CFR § 800.5), the AIS results support a determination of “no historic properties
affected.” Further, under HRS § 6E-8 and in accordance with HAR § 13-275-7(a)(1), the County
of Hawaiʻi DEM’s project effect determination is “no historic properties affected.” Under 54 U.S.C. § 300308, the term ‘‘historic property’’ means any prehistoric or historic district, site, building, structure, or object included on, or eligible for inclusion on, the National Register.
Based on the above, 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 site of the proposed treatment and disposal facility is low due to historical ground modifications and ongoing harvesting activities; however, the Proposed Action would incorporate appropriate mitigation measures should archeological resources be discovered during construction. Specifically, the construction contract documents would state that, should archeological features such as walls, platforms, pavement or mounds, or remains such as artifacts, burial sites, or concentrations of shells or charcoal, be encountered during construction
activities, work shall cease immediately and the find shall be protected from further damage. The contractor would immediately contact SHPD (at 808.981.2979), who would assess the
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significance of the find and recommend appropriate mitigation measures, if necessary. The AIS and NHPA Section 106 consultation correspondence can be found in Appendix D and Appendix
D-1, respectively.
To date, SHPD has not responded to the County’s Draft AIS submittal from March 13, 2019; the EPA letter from September 26, 2019 requesting concurrence with the determination that no
historic properties will be affected by the undertaking; or the County’s follow-up letter from October 9, 2019 requesting concurrence with the Draft AIS findings. In accordance with 36 CFR § 800.4(d)(1)(i) and as specified in the September 26 letter, because no response was received
within 30 days of SHPD receipt of the adequately documented finding, EPA has fulfilled their Section 106 responsibilities for this undertaking. However, construction would not proceed until SHPD has approved the Draft AIS.
Abandonment of the two LCCs and the existing wastewater collection system would not affect archaeological and cultural resources within the affected areas.
(b) Alternative Sites 8 and 9
Under these alternatives, the potential impacts to archaeological and cultural resources and the necessary impact avoidance and minimization measures would likely be similar to those described above for the Preferred Alternative (Site 7). If Site 8 or Site 9 are selected for development, an AIS, including subsurface testing, would be conducted to confirm the presence or absence of resources on the proposed wastewater treatment and disposal facility site. If archaeological sites are discovered during construction, work would cease and SHPD would be contacted (at 808.981.2979) to determine appropriate mitigation measures, if necessary. EPA and the County of Hawai‘i would consult with SHPD in accordance with Section 106 of the NHPA and would incorporate impact avoidance and minimization measures as necessary to result in a finding of no adverse effects to historic properties.
(c) No-Action Alternative
The No-Action Alternative would not result in any disturbance to land within the Pāhala area and is therefore not expected to have any adverse impacts on archaeological or cultural resources.
3.16 Socioeconomic Characteristics
3.16.1 Existing Conditions
(a) All Alternative Sites
In March 2017, the State of Hawaiʻi Department of Business, Economic Development and Tourism released 2016 population estimates for the state and counties. This analysis estimates that Hawaiʻi County had a resident population of 198,449 persons in 2016, which represents an annual increase of 1.2 percent from 2010.
The U.S. Census Bureau provides the American Community Survey (ACS), which updates selected demographic, social, and economic information for various years. This includes age, racial composition, and economic information, including employment and household income by
Census Designated Place for several locations in Hawaiʻi County. The version of the ACS referenced is the 2012-2016 5-Year Estimates, released in 2017. See Table 3.1 below.
The ACS shows the Pāhala population has a similar age distribution to Hawai‘i County, although
Pāhala has a higher proportion of individuals in the “Under 5 to 19” age category, 28.5 percent
compared to 24.4 percent for the County. The median age for Pāhala is 42.4 years compared to 41.8 years for the County.
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Overall, Pāhala is characterized by a racial composition that includes a greater proportion of minorities than the County at large. 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 higher proportion of residents that have completed high school and some college
than the County overall, but a 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 (31.9 percent), and in education and health care (22.1 percent), compared to the County (12.6 percent and 19.7 percent, respectively).
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 3.1 below, 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.
3.16.2 Impacts and Mitigation Measures
(a) All Alternative Sites
In the short term, construction projects under the Proposed Action 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 Proposed Action would generate employment as the contractor would need workers to
undertake construction of the improvements for the wastewater collection system and the wastewater treatment and 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 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, the Proposed Action would result in positive employment benefits which would result in higher levels of income and overall economic benefits to the local economy.
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Table 3.1
Demographic, Economic, and Social Characteristics of Pāhala and Hawai‘i County
Item
Pāhala Hawai‘i County
Total Percent Total Percent
Demographic Characteristics
Total population 1,341 ----- 193,680 -----
Under 5 to 19 years 382 28.5 47,258 24.4
20 to 34 years 193 14.4 34,475 17.8
35 to 59 years 306 22.8 61,978 32
60 to 74 years 367 27.4 36,993 19.1
75 years and over 94 7.0 13,170 6.8
Median age 42.4 ----- 41.8 -----
Race
White 106 7.9 64,255 33.2
African American (incl. American Indian/Alaska Native) 0 0.0 1,897 1.0
Chinese 10 0.7 1,844 1.0
Filipino 484 36.1 17,794 9.2
Japanese 54 4.0 17,981 9.3
Other Asian 46 3.4 3,722 1.9
Native Hawaiian 50 3.7 20,980 10.8
Other Pacific Islander 18 1.3 4,725 2.4
Some other race 1 0.1 3,230 1.7
2 or more races 572 42.7 54,564 28.2
Social Characteristics
Less than 9th grade 98 10.9 3,681 2.7
High school to HS graduate 489 54.5 50,586 37.3
Some college to associate degree 204 22.7 43,761 32.3
Bachelor’s degree 97 10.8 24,704 18.2
Graduate or professional degree 10 1.1 12,649 9.3
Household Income Characteristics
Less than $24,999 130 33.6 17,337 26.3
$25,000 to 49,999 73 18.9 13,615 20.6
$50,000 to $99,999 126 32.6 20,291 30.7
$100,000 to $199,999 48 12.4 12,201 18.5
$200,000 or more 10 2.6 2,563 3.9
Median household income $47,625 ----- $53,936 -----
Employment Characteristics
Agriculture, forestry, fishing and hunting 120 26.2 3,713 4.4
Construction 26 5.7 6,806 8.2
Manufacturing and wholesale-trade 0 0 3,701 4.4
Retail trade 16 3.5 10,858 13.0
Transportation, warehousing, and utilities 14 3.1 4,250 5.1
Information tech, finance, insurance, and real estate 9 2.0 5,677 6.8
Professional, scientific, and technical services 48 10.5 8,709 10.4
Education and health care 101 22.1 16,437 19.7
Arts, entertainment, recreation 75 16.4 13,316 16.0
Other services, public administration 49 10.7 10,015 12.0
Source: 2012-2016 American Community Survey (5-Year Estimates) Hawai‘i Geographic Area Profiles – Census Designated Places: Neighbor Islands.
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The Proposed Action is not likely to directly impact long-term employment or education trends because the wastewater operator would likely be based in Hilo or Kona, meaning the project
would not involve long-term relocation of any staff to Pāhala. Additionally, the proposed wastewater collection system and treatment and disposal facility would not be designed to encourage or accommodate substantial population growth in Pāhala.
Despite the relatively high proportions of low-income, minority, and children residents in Pāhala compared to the County overall, the Proposed Action would not result in disproportionately high and adverse human health or environmental effects on these sensitive populations. As discussed
in Section 2.3.1 and Section 3.14.2, 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 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 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.
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) was raised by the community during the December 2017 public meetings and the October 2018 public meeting
for the 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, which do not require substantial maintenance and operation, and
abandonment of the existing wastewater collection system would have no impact on socioeconomic resources within Pāhala.
(b) No-Action Alternative
The No-Action Alternative includes no modifications to the current sewage system, and therefore is not expected to impact socioeconomic or demographic conditions in the Pāhala area.
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3.17 Traffic
3.17.1 Existing Conditions
(a) All Alternative Sites
Māmalahoa Highway (State Highway Route 11) is the major north-south roadway for the Pāhala area. This minor arterial highway provides two lanes, one lane in each direction, and shoulders within a 60-foot ROW. Pāhala is located about 51 miles south of Hilo and has two major access roads, Kamani Street on the northern end and Maile Street on the southern end.
In November 2010, State of Hawaiʻi Department of Transportation (DOT) conducted the most
recent traffic counts on Māmalahoa Highway at the Pāʻauʻau Bridge, mile marker 51.32, located just north of Kamani Street. The counts provide 24-hour and peak-hour counts for traffic in both directions. The 24-hour period counts show a total two-way volume of 2,449 vehicles, with 1,212 vehicles southbound and 1,237 vehicles northbound. The peak morning hours occurred between 7:00am to 8:00am and had a total two-way volume of 186 vehicles with 108 vehicles southbound and 78 vehicles northbound. The peak afternoon hours occurred between 4:00pm to 5:00pm and
had a two-way volume of 219 vehicles with 104 vehicles southbound and 115 vehicles northbound.
Within Pāhala, vehicle traffic primarily occurs on streets under the jurisdiction of the County of
Hawai‘i. The streets typically carry two-way traffic, one lane in each direction, within roadways with improved surfaces of 22 to 24 feet wide with no curbs and sidewalks. The shoulders consist mostly of grass swales which also serve to carry surface runoff along with the streets. These
roadways carry vehicle traffic from adjacent and nearby residential areas. As a result, the traffic volumes are relatively low, which is consistent with traffic generation by a rural community.
The wastewater collection system and the wastewater treatment and disposal project site are located outside of the Māmalahoa Highway ROW.
3.17.2 Impacts and Mitigation Measures
(a) Preferred Alternative (Site 7) and Alternative Site 8
Under these two alternatives, the wastewater collection system and the wastewater treatment
and disposal facility would be located outside of the Māmalahoa Highway ROW and would not require any disturbance or other impacts within the Māmalahoa Highway ROW. However, work on the collection system would require excavation of open trenches within the ROWs of several other roads within the Pāhala community (Maile, ʻIlima, Huapala, Hīnano, Hala, Puahala, Pīkake, and Kamani Streets). The contractor would be required to obtain permits to work within the County ROW and implement traffic control plans in the area of each open trench site that provide procedures for controlling traffic in the work area, including the placement of Manual on Uniform
Traffic Control Device compliant signs, traffic delineators or barriers, lane closures, flaggers to direct traffic, and special duty officers to oversee conditions at the site. The traffic control plans would provide directions to temporarily divert traffic or close travel lanes during the construction
period and would include measures to allow for emergency access during construction. Normally, such plans call for these diversions or closures during non-peak travel times to minimize disruptions to traffic flow. Typically, one traffic lane is kept open for two-way traffic during working
hours and two lanes are kept open after hours. When not in use, trenches would be covered with steel plates or surrounded by traffic barriers to prevent accidents. The County would be required to approve any traffic control plans. Any scheduled road closures would be required to be coordinated at least two weeks in advance with the Police Department for County approval. Additionally, the County would coordinate with the DOE Student Transportation Services Branch
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Manager and the School in order to minimize construction-related impacts to student transportation services.
Construction of the proposed wastewater treatment and disposal facility would require transport of construction equipment and supplies to the construction site, including excavators and other heavy equipment. Deliveries to the construction site could require temporary stoppage of traffic
on Maile Street to safely unload equipment and supplies. To minimize traffic disruptions, contractors typically try to conduct these activities during off-peak traffic hours. No long-term road closures would be required.
The wastewater treatment and disposal facility would require only weekly visits by a single operator based in Hilo or Kona and intermittent visits for maintenance purposes. As such, no impacts to traffic are expected from wastewater treatment and disposal facility staff. Sludge removal would occur approximately every 20 years, so no impacts to traffic are expected due to truck activity associated with sludge removal.
Abandonment of the two LCCs and the existing wastewater collection system would not affect
transportation within the Pāhala area.
Information regarding project schedules, including EPA compliance dates, project updates and milestones, can be found on the EPA website at: https://www.epa.gov/uic/county-hawaii-administrative-order-consent-closure-cesspools-pahala-and-naalehu. The County will also provide information about the construction schedule for the treatment and disposal facility and the collection system to the DOE Facilities Development Branch Public Works Administrator on request.
(b) Alternative Site 9
Transportation impacts under this alternative would be identical to those for the Preferred Alternative (Site 7) and Site 8, except it would require construction of piping and other utilities within the Māmalahoa Highway ROW to provide connections to the new wastewater treatment
and disposal facility in Site 9. This would require obtaining an easement from the State DOT for work within the highway ROW and could delay the start of construction.
(c) No Action Alternative
The No-Action Alternative would not impact traffic in the Pāhala area because no modifications to the current system would be made.
3.18 Noise
3.18.1 Existing Conditions
(a) All Alternative Sites
The A-weighted decibel scale (dBA) is a logarithmic scale generally used to measure noise levels
because it can account for the sensitivity of the human ear across the frequency spectrum. The Occupational Safety and Health Administration (OSHA) regulates workplace noise with standards for two different types of noise: constant and impulse. The OSHA limit for constant noise is 90
dBA for eight hours; however, the National Institute for Occupational Safety and Health recommends a constant noise limit of 85 dBA for eight hours to minimize hearing loss induced by occupational noise. The OSHA maximum sound level for impulse noise is 140 dBA. In areas
where workplace noise exceeds these sound levels, employers must provide workers with personal protective equipment to reduce noise exposure.
HAR 11-46 (Community Noise Control) sets forth various permissible sound levels by zoning districts or land uses. According to HAR § 11-46-3 and § 11-46-4, Class A zoning districts include
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all areas equivalent to lands zoned as residential, conservation, preservation, public space, open space, or similar type. Class B zoning districts include all areas equivalent to lands zoned for
multi-family dwellings, apartment, business, commercial, hotel, resort, or similar type. Class C zoning districts include all areas equivalent to lands zoned agriculture, country, industrial, or similar type.
All alternative sites for the proposed wastewater treatment and disposal facility are in Class C zoning districts. The proposed wastewater collection system would primarily be located in Class A zoning districts. The maximum permissible sound levels in each zoning district are presented
below in Table 3.2 and apply to stationary noise sources and equipment related to agricultural, construction, industrial activities.
Table 3.2
Permissible Sound Levels by Zoning District
Zoning District
Daytime:
7am to 10pm
Nighttime:
10pm to 7am
Class A 55 dBA 45 dBA
Class B 60 dBA 50 dBA
Class C 70 dBA 70 dBA
HAR 11-46 recognizes that construction noise must often exceed the established permissible sound levels and provides procedures by which an applicant may obtain a noise permit from DOH for excessive noise sources. The DOH may consider several factors in determining whether to grant the noise permit, including (but not limited to) the use of best available control technology to control noise levels; the extent and impact of nighttime activities; notification of the public of planned nighttime construction activity; and whether the noise emitting activity is in the public interest.
According to HAR § 11-46-5(4) (Exemptions), the operation of emergency generators can be
exempted if they are installed and used as required for the purpose of protecting public health and safety.
There are no current significant sources of noise impacting the proposed project areas. The
proposed wastewater treatment and disposal facility would be located in active macadamia nut orchards where the primary source of noise is ongoing orchard operations. The proposed wastewater collection system would primarily be located in residential areas with background
noise levels typical of a residential zone.
3.18.2 Impacts and Mitigation Measures
(a) All Alternative Sites
In the short term, noise levels would increase in the Pāhala area due to construction activities along the wastewater collection system and at the site of the proposed wastewater treatment and disposal facility. Noise is expected to be intermittent and unavoidable because construction vehicles and heavy equipment generate noise as part of normal operations. Mitigation of noise from construction activities to inaudible levels is not practical in all cases due to the intensity and exterior nature of the work. Depending on the results of geotechnical surveys, construction of the collection system and the wastewater treatment and disposal facility could involve excavation to a depth that would require removal of bedrock. If necessary, this would likely be accomplished by using backhoe-mounted hydraulic and/or pneumatic hammers to break up the bedrock for removal, resulting in temporarily elevated impulse noise levels.
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Construction activities for the Proposed Action would need to comply with provisions of HAR 11-46 (Community Noise Control). The majority of construction activity would occur during daytime
hours, and construction at the site of the proposed wastewater treatment and disposal facility is not expected to result in exceedances of the 70 dBA Class C zoning district noise threshold outside of the property boundary or in residential areas. However, construction of the collection
system would take place near residences in the Pāhala community. The construction contractor would be required to obtain 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 best available control technology to control noise levels from excessive noise sources; and would require the applicant/contractor to notify affected members of the public in advance of any planned nighttime construction activity (which must not exceed the permissible sound levels). Further, the Noise Reference Manual, Big Island
Edition also limits the use of certain types of equipment to hours of 9:00 a.m. to 5:30 p.m. Monday to Friday. DOH would be expected to grant the noise permit because the Proposed Action is in
the public interest. After a permit has been issued, the contractor may request a modification the permit.
Construction contract documents would require that workers are provided with, and wear, appropriate personal protective equipment to reduce noise exposure to below the OSHA maximum sound level.
After construction, the proposed wastewater treatment and disposal facility is not expected to be a significant source of additional ambient noise during routine operation. Operational noise would be confined to the aerators within the lagoons, emergency generator operation, and vehicle movements at the facility. HAR 11-46-5(4) exempts operation of emergency generators from the provisions of HAR 11-46 when installed and used as required and necessary for the protection of public health and safety, provided the best available control technology is implemented.
Emergency generator operation would occur only during emergencies and periodic testing and thus would be infrequent. In addition, construction and operation of the proposed wastewater treatment and disposal facility would not be anticipated to have any direct or indirect noise impact
on the Ka‘ū High School or Pāhala Elementary School, due to the distance between the proposed facility and the schools. Therefore, the Proposed Action is not likely to create an adverse impact
to the noise environment in the Pāhala area.
Abandonment of the two LCCs and the existing wastewater collection system would not affect the
noise environment in the Pāhala area.
(b) No-Action Alternative
The No-Action Alternative involves no construction activities or changes to the current system.
Therefore, no impacts to the noise environment in the Pāhala area would occur.
3.19 Visual Considerations and Light Pollution
3.19.1 Existing Conditions
(a) All Alternative Sites
The February 2005 County General Plan identified a number of sites as important visual
resources contributing to the natural beauty of the Ka‘ū District. These visual resources typically consist of scenic resources including major land forms, open spaces, viewing points, scenic drives, and other physical features. The natural beauty of the landscape in the southern part of
the Ka‘ū District is characterized by vistas from the mountain slopes to the oceans. The coastline is highlighted by Manuka Bay, Green Sands Beach, and Punaluu Black Sand Beach. Some of the natural beauty sites identified in the Ka‘ū District most pertinent to the Pāhala area include: 1)
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view of Mauna Loa from the highway; 2) scenic view of the shoreline between Pāhala and Punaluu; and 3) the lava flows of 1868, 1887, and 1907.
The Pāhala community consists almost entirely of single-family residential units and the related utility lines that service the homes. Generally, residential units are set back from the adjacent roadway so the views of nearby areas are not obstructed.
Exterior lighting is often used to enhance the safety and security of persons and property. Excessive and inappropriate exterior lighting, however, can generate light pollution. As described in Section 3.13.1, outdoor lighting can also result in adverse effects to seabirds by attracting them
at night and causing disorientation, fallout, and injury or mortality. The County of Hawai‘i regulates outdoor lighting under HCC Section 14-50. Streets in the Pāhala community are lined with street lights mounted on utility poles. The three alternative sites for the proposed wastewater treatment and disposal facility (Sites 7, 8, and 9) are used for macadamia nut production, with no existing outdoor lighting.
3.19.2 Impacts and Mitigation Measures
(a) Preferred Alternative (Site 7)
The Proposed Action is not expected to adversely affect the views or viewsheds identified in the County General Plan. The wastewater collection system would be installed below the streets and therefore would not impact views. The operations building, headworks cover structure, UV disinfection system cover structure, and low berms or walls around the basins would be the only above-grade structures and would not exceed 25 feet in height. The existing Cook pine trees along Maile Street, most of which would remain with no changes, would continue to obstruct the viewplanes from Maile Street. The facility site would be adjacent (mauka) to, and visible from, Māmalahoa Highway (State Route 11); however, impacts to the viewplane would be mitigated by the planted trees in the disposal groves and by the rise in elevation between the highway and the facility.
Exterior lighting at the proposed wastewater treatment and disposal facility would be designed in accordance with HCC Section 14-50 and would be limited to manually switched lights under the roof overhang at the entrance to the operations/electrical building, at the headworks area, and at
the UV disinfection system. Lights would be installed with down-shielding to prevent excess light pollution. When authorized personnel are not present on site, lights would not be on. Also, per consultation with FWS to avoid impacts to seabirds, nighttime construction activities would not
take place during the seabird fledging period (September 15 to December 15). In addition, construction and operation of the proposed wastewater treatment and disposal facility would not be anticipated to have any direct or indirect visual impacts on the Ka‘ū High School or Pāhala Elementary School, due to the distance between the proposed facility and the schools.
Abandonment of the two LCCs and the existing wastewater collection system would not affect visual resources or light pollution within the affected areas.
(b) Alternative Sites 8 and 9
Under Alternative Sites 8 and 9, the visual and light pollution impacts and mitigation measures would be similar to those discussed above for the Preferred Alternative (Site 7). Pine trees would be maintained between the wastewater treatment and disposal facility and public views from the adjacent streets to minimize visual impacts, except where necessary to accommodate the driveway into the facility. The planted trees in the proposed slow-rate land application basins would partially replace removed trees and exterior lighting at the facility would be minimal.
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(c) No-Action Alternative
The No-Action Alternative would not change the current conditions in the Pāhala area and no
visual impacts would occur.
3.20 Public Services – Police Protection
3.20.1 Existing Conditions
(a) All Alternative Sites
The Hawai‘i County Police Department provides police services to the Kaʻū District, which
includes Pāhala and other nearby communities. A single police station is located in Nā‘ālehu,
which serves the entire Kaʻū District. The Kaʻū Patrol District encompasses 700 square miles and is bound by the Kona District at Kaulanamauna and the Puna District at Keauhou Landing. Its officers operate out of a central station in Nā‘ālehu and a substation in Hawai‘i Ocean View Estates subdivision.
3.20.2 Impacts and Mitigation Measures
(a) All Alternative Sites
The Proposed Action is expected to create no additional demand for police protection and related services since it will not increase the resident population or visitors to the area. The Proposed Action should have minimal impact on the police department’s operations or ability to provide
adequate protection services to the surrounding community. If necessary, off-duty police staff may be hired to assist with directing traffic during construction activities.
Operation of the proposed wastewater treatment and disposal facility is not expected to impact
the Police Department. The facility would have a security fence around the perimeter with a locked entry gate.
Abandonment of the two LCCs could reduce the need for police protection services to handle public health threats in the event that there is damage to the LCCs (e.g., from volcanic or seismic activity). Otherwise, abandonment of the two LCCs and the existing wastewater collection system would not affect police protection services in the County.
(b) No-Action Alternative
The No-Action Alternative would not impact police protection services due to continued operation of the existing LCCs. In the event that there is damage to the LCCs from some unforeseen event (e.g., volcanic or seismic activity), police protection services may be required to handle public health threats resulting from damage to the LCCs.
3.21 Public Services – Fire Protection
3.21.1 Existing Conditions
(a) All Alternative Sites
Fire protection and related services are provided from a fire station located in Pāhala. The station and a volunteer station provide 24-hour fire protection and emergency medical services (EMS). The County has contracted with the State DOH for emergency medical ambulance services.
3.21.2 Impacts and Mitigation Measures
(a) All Alternative Sites
The proposed wastewater treatment and disposal facility would include a fire protection line to be used in the event of a fire. The emergency generator would include a double-walled diesel fuel tank of a type allowed by the County. The Proposed Action would not affect the operations of fire
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protection and EMS services in Pāhala and the proposed wastewater treatment and disposal facility would not require additional fire protection services on site. The construction plans would
be submitted to the Fire Department for review during the project design phase.
The treatment and disposal facility 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 Site 7 would be designed to comply with Chapter 18 of NFPA 2006 Uniform Fire Code as amended by the County.
Abandonment of the two LCCs could reduce the need for fire protection services to handle public health threats in the event that there is damage to the LCCs (e.g., from volcanic or seismic activity). Otherwise, abandonment of the two LCCs and the existing wastewater collection system would not affect fire protection services in the County.
(b) No-Action Alternative
The No-Action Alternative would not impact fire protection services due to continued operation of
the existing LCCs. In the event that there is damage to the LCCs from some unforeseen event (e.g., severe flood, volcanic or seismic activity), fire protection services may be required to handle public health threats resulting from damage to the LCCs.
3.22 Infrastructure – Water System
3.22.1 Existing Conditions
(a) All Alternative Sites
The County of Hawai‘i Department of Water Supply (DWS) provides water service to the Pāhala community from groundwater sources. The water lines are primarily located along or under the roadways in the area. In response to the pre-assessment notification, on April 5, 2018, the DWS noted that the wastewater treatment and disposal facility site is not serviced by the DWS. The nearest point of connection to the DWS system is at an existing 6-inch waterline at the intersection of Huapala Street and Maile Street, approximately 2,000 feet northeast of Site 7. Sites 8 and 9 are an additional 1,600 to 3,200 feet, approximately, from the DWS connection point.
All alternatives would be designed according to 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 Site 7 would be designed to comply with Chapter 18 of NFPA 2006 Uniform Fire Code as amended by the County.
3.22.2 Impacts and Mitigation Measures
(a) Preferred Alternative (Site 7)
The proposed wastewater treatment and disposal facility would require new potable water and
fire protection lines. Water would be provided by extending the existing DWS water main and by installing a service line to connect the new facility (specifically, the headworks operations building) to that extended water main. The lines would require trenching, primarily on Maile Street, and
construction plans would identify the horizontal and vertical clearances required to avoid existing water system and collection system lines. As required by DWS, construction plans would show the estimated maximum daily water usage calculations prepared by a professional engineer
licensed in the State of Hawaiʻi. After review of the calculations, DWS would determine if enough water is available and a water commitment could be issued.
Abandonment of the two LCCs and the existing wastewater collection system would not affect water system infrastructure in Pāhala.
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(b) Alternative Sites 8 and 9
Under Alternative Sites 8 and 9, the water system infrastructure impacts and mitigation measures
would be similar to those described above for the Preferred Alternative (Site 7). Compared to Site 7, approximately 1,600 feet of additional pipe within the ROW of Lower Maoula Road would need to be installed to provide Site 8 with potable water and fire protection lines. To provide Site 9 with
potable water and fire protection lines, approximately 3,200 feet of additional pipe within the ROW
of Maile Street and across Māmalahoa Highway would need to be installed.
(c) No-Action Alternative
The No-Action Alternative includes no modifications to the existing water infrastructure, and therefore would not cause any impacts to the water system in Pāhala.
3.23 Infrastructure – Drainage System
3.23.1 Existing Conditions
(a) Preferred Alternative (Site 7)
There is no existing County stormwater drainage system in Pāhala. Existing stormwater runoff
from the Pāhala District generally collects along the paved roadways within each subdivision and sheet flows towards Māmalahoa Highway, then disperses into open swales or grassed areas.
Current drainage patterns at the preferred site (Site 7) are influenced by two existing culverts that
allow stormwater to flow across the Māmalahoa Highway in the vicinity of the proposed wastewater treatment and disposal facility, as depicted in Figure 3.4. The first is a box culvert located at the intersection with Maile Street that conveys stormwater under the highway. The
second culvert is located approximately 600 feet east of the Maile Street intersection and was used to convey sugar mill flume water across the highway for disposal. The site slopes from approximately north to south (mauka to makai) such that, during rain events, surface flows pass through the existing orchard to the southern (makai) end where the flows eventually drain through the culvert at the Maile Street-Māmalahoa Highway intersection to the areas below (makai) the highway. Most of the land surface area below the existing macadamia nut orchard contains little to no vegetation to absorb or slow these flows. The gradient of Site 7 and surrounding area results in this natural pattern of surface flows which also existed when the area was planted in sugar cane and is not considered flooding.
(b) Alternative Sites 8 and 9
Similar to Site 7, Alternative Sites 8 and 9 slope from approximately north to south (mauka to makai) such that, during rain events, surface flows pass through the existing orchard to the southern (makai) end. For Site 8, the flows are eventually interrupted by Māmalahoa Highway where they may be diverted to other culverts along the road to the areas below (makai) the
highway. The unnamed branch of Hi‘onamoa Gulch crosses the Site 8 parcel from northwest to southeast near the center of the parcel and creates a depression or incision in the topography that may influence site drainage.
For Site 9, the surface flows pass through the existing orchard and continue downgradient to areas south of Site 9 that contain a larger extent of the same orchard. Two unnamed south-flowing
branches of Hi‘onamoa Gulch cross portions of the Site 9 parcel. Also, an unnamed east-flowing
branch of Pāʻauʻau Gulch originates in the Site 9 parcel near the southeast boundary of the Site
7 parcel; this branch flows into Pāʻauʻau Gulch approximately 4,000 feet east of the Site 9 parcel. These features also influence the topography and existing drainage at Site 9.
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Figure 3.4. Stormwater Culverts Near Site 7
3.23.2 Impacts and Mitigation Measures
(a) Preferred Alternative (Site 7)
The Proposed Action would incorporate appropriate stormwater and erosion control measures in accordance with approved plans to ensure that soil erosion and transport during construction activities are minimized. Construction of the proposed wastewater collection system would require trenches for new lines, and silt fences or filter socks would be used to minimize runoff from the disturbed area. The proposed wastewater treatment and disposal facility would include an on-site drainage system to address stormwater surface runoff caused by new impervious surfaces at the facility. The site would include a system to collect runoff via grated inlets or swales, and flows would be conveyed to on-site drainage detention systems, such as subsurface linear infiltration or depressed detention basins. Landscape buffers with dirt berms would also be constructed around most of the perimeter of the facility to act as secondary containment in the event of a large storm event. The on-site stormwater management system would meet the requirements of HCC § 27-20, which mandates drainage plans to accommodate runoff caused by the facility for a design storm event.
To meet the requirements of HCC § 27-20 (f), the project “shall not alter the general drainage pattern above or below the development.” Thus, for the design storm event, no increase in flow
amount would be directed to either of the culverts at the highway as a result of the site
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development. A drainage study would be prepared during the design process to evaluate the improvements necessary to comply with HCC 27 requirements. Construction of the wastewater
treatment and disposal facility would create an increase in impervious areas; however, the County standards are intended to protect nearby properties and areas from runoff from a developed area, thus adherence to the County standards would prevent adverse impacts to surrounding properties
from new development.
The wastewater treatment processes would be designed to accommodate peak flows, including precipitation that falls on the area occupied by the aerated lagoon treatment system. The PER
Section 2.2 (Appendix B), outlines the anticipated peak wastewater flows from the community, based on the applicable flow standard. Sufficient operational freeboard would be available to contain and to equalize lagoon flows. In addition, the slow-rate land application groves would be designed to completely contain both peak effluent flows and precipitation from a 100-year, 24-hour storm event. A geotechnical engineering assessment of berm stability would be conducted during the design process.
The tree groves would be designed in accordance with EPA’s “Process Design Manual, Land Treatment of Municipal Wastewater Effluents.” Effluent would be applied at a hydraulic loading rate that is a small percentage of the percolation rate of the soil, ensuring sufficient capacity for assimilation of peak effluent flow rates and precipitation from the design storm event and ensuring that design flows would not impact surrounding properties.
Stormwater runoff generated mauka of the wastewater treatment and disposal facility would be directed around the perimeter of the site via diversion swales that convey flow back to the existing drainage pattern that flows to the existing culvert at the Maile Street and Māmalahoa Highway intersection. During heavy rain events, stormwater may temporarily back up behind the culvert. Based on the roadway flooding concerns expressed by the community during the Pāhala public information meetings held in December 2017 and October 2018, the State DOT Hawai‘i District
office was contacted to discuss drainage at the facility site and the culvert at the Maile Street and
Māmalahoa Highway intersection. On February 20, 2019, the District office confirmed via telephone that the DOT owns and maintains the culvert and that they have no record of the
roadway being inundated by stormwater drainage at the Maile Street and Māmalahoa Highway intersection during precipitation events. There would be no changes to this culvert under the Proposed Action and the proposed facility would not be located within the area of the culvert.
Figure 2.3 shows the intersection of Maile Street and Māmalahoa Highway lies at about 580 feet above msl. Figure 2.2 shows the Pāʻauʻau Gulch crosses under Māmalahoa Highway about 0.88 miles north of that intersection at approximately 780 feet above msl or about 200 feet higher in
elevation than the culvert at the Maile Street and Māmalahoa Highway intersection. Due to this distance and the elevation difference, surface flows at Site 7 would not affect the gulch. Similarly, the Kaimani Street and Māmalahoa Highway intersection lies about 0.84 miles north of the proposed facility and at about 780 feet above msl. Surface flows at the facility would also not affect that intersection.
Abandonment of the two LCCs and the existing wastewater collection system would not affect drainage or runoff in the affected areas.
(b) Alternative Sites 8 and 9
Under Alternative Sites 8 and 9, the stormwater drainage infrastructure impacts and mitigation measures would be similar to those described above for the Preferred Alternative (Site 7). The wastewater treatment and disposal facility design would incorporate appropriate stormwater and
erosion control measures similar to those above. However, additional drainage design
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considerations or erosion control measures may be needed in order to prevent stormwater runoff from impacting the unnamed branches of Hi‘onamoa Gulch that intersect both Sites 8 and 9.
(c) No-Action Alternative
The No-Action Alternative would not result in a change to the impervious area within or near
Pāhala and would therefore not lead to an increase in runoff or other impacts to drainage in the
area.
3.24 Infrastructure – Electrical and Communications Systems
3.24.1 Existing Conditions
(a) All Alternative Sites
Electrical services to the Pāhala area are provided by Hawaiian Electric Light Company (HELCO) via pole-mounted overhead lines located along the roadways within the community. The HELCO lines are located along Māmalahoa Highway, leading to a substation west of the intersection of Kamani Street and the highway.
Hawaiian Telcom is the primary telecommunications provider within the County of Hawai‘i and
has overhead lines for telephone service in the Pāhala community.
3.24.2 Impacts and Mitigation Measures
(a) All Alternatives
The wastewater treatment and disposal facility would require electrical power. The natural treatment systems proposed require relatively low energy input as compared to other treatment options evaluated. It is anticipated that HELCO would bring overhead power lines to the selected
site and supply 480-volt, 3-phase power to the facility via a pole-mounted transformer. This would be connected to a service panel with a meter. The floating surface aerators would consume the majority of the electricity supplied to the site. An electrical room would house the electrical gear and plant control equipment. Exterior lighting at the site would be limited to manually switched lights at the entrance to the operations/electrical building and at the headworks area. A standby power system would be provided in the form of a diesel generator and aboveground fuel tank with capacity to support three consecutive days of operation. In addition, the electrical service panel would be equipped with a manual transfer switch and generator receptacle to allow connection of a portable trailer-mounted generator in the event of emergency generator failure during an extended power outage.
A land-line and/or cellular telephone telemetry system would be used to connect the wastewater treatment and disposal facility to DEM and facilitate communication with staff in Hilo or Kona.
To avoid damaging existing buried infrastructure during construction, the construction contractor would be required to call the one-call center prior to any construction activities to allow
demarcation of underground utilities to occur.
Abandonment of the two LCCs and the existing wastewater collection system would not affect electrical and communications infrastructure in the area.
(b) No-Action Alternative
The No-Action Alternative would not require any electrical power and includes no construction activities that could disrupt buried utility infrastructure. Therefore, no impacts to electrical and
telecommunications infrastructure would occur.
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4 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.
4.1 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.
4.1.1 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 U.S. Environmental Protection Agency (EPA) 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. As discussed throughout Section 3, the effects of the Proposed Action would generally be limited to the footprint of the project and the immediate vicinity, 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 is not part of a larger forest parcel that provides valuable habitat. Based on these considerations, EPA 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. 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. EPA 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-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
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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.
4.1.2 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 Pāhala, 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 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.
4.2 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
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• 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. As discussed in Section
3.19.2, 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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5 FEDERAL CROSS CUTTER REQUIREMENTS
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 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. These
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 for Special Appropriations Act
Project (SAAP) grants requires the inclusion of one additional cross cutter—specifically, the Clean Water Act, which has been added at the end of this section (see Section 5.19).
5.1 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. An Archaeological Inventory Survey (AIS), which included subsurface testing, was conducted to
confirm the presence/absence of archaeological resources on the preferred site. The AIS confirmed no significant artifacts or cultural deposits were observed on the ground surface within the proposed treatment and disposal facility site as the area experiences ongoing disturbance by
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macadamia harvesting operations and stormwater runoff. Further, no cultural deposits or lava tubes were encountered during the subsurface trenching. For more information, please refer to
Appendix D.
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.
5.2 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.
5.3 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.
The DOH operates a network of air quality monitoring stations at various locations around the state. In December 2016, the DOH issued the Annual Summary 2015 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 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 2015, 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 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 and the wastewater treatment and disposal facility are anticipated.
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5.4 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 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.
5.5 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. See detail discussion in Section 6 (Plans, Policies and Controls). A summary follows.
(1) Recreational Resources
Objective:
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;
(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;
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(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.
(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.
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 project site. The AIS confirmed no significant artifacts or cultural
deposits were observed on the ground surface within the proposed treatment and disposal facility 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. For more information, please refer to Appendix D.
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;
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(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.
(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.
(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:
(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.
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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 collection system and wastewater treatment
and disposal facility 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.
(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
(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.
In December 2017, a total of five community outreach sessions regarding the project were
conducted in the Pāhala community. A public information meeting for the Draft EA was held in
October 2018. The collection system and wastewater treatment and disposal facility are at least 3.3 miles from the coast, at least 580 feet above msl, and do not involve management of coastal resources and hazards.
(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.
In December 2017, a total of five community outreach sessions were conducted in the Pāhala community. A public information meeting for the Draft EA was held in October 2018. All project locations are at least 3.3 miles from the coast and at least 580 feet above msl.
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(9) Beach Protection
Objective:
(A) Protect beaches for public use and recreation.
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. The collection system and the
wastewater treatment and disposal facility project does not include improvements that would
affect public use beaches.
(10) Marine Resources
Objective:
(A) Promote the protection, use, and development of marine and coastal resources to assure
their sustainability.
Policies:
(D) Ensure that the use and development of marine and coastal resources are ecologically and
environmentally sound and economically beneficial;
(E) Coordinate the management of marine and coastal resources and activities to improve
effectiveness and efficiency;
(F) 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;
(G) 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
(H) 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 collection system and the
wastewater treatment and disposal facility project does not include improvements that would affect development of marine and coastal resources.
5.6 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
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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 preferred project site.
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 preferred site for the proposed wastewater treatment and disposal facility 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.
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.
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 letter with reference number 01EPIF00-2019-I-0153 in Appendix C-1). 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.
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5.7 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 2016 American Community Survey (ACS) (5-Year Estimates) is the most recent information
related to socioeconomic conditions in the state and County. The 2016 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
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.
Pāhala has more households in the “less than $24,999” income bracket (33.6 percent) than the County as a whole (26.3 percent).
Overall, Pāhala is characterized by a racial composition that includes a greater proportion of
minorities (92.1 percent non-White) than the County at large (66.8 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 Hawai‘i County, although Pāhala has a higher proportion
of individuals in the “Under 5 to 19” age category (28.5 percent) compared to the County as a whole (24.4 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. The design and location of the proposed wastewater treatment and disposal 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.
5.8 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
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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 wastewater treatment and disposal facility will be located on approximately 20 percent “prime”, 40 percent “other” and
40 percent “unclassified” land.
The proposed collection system will be located primarily within the streets and shoulders in Pāhala
and therefore will not affect farmlands. The preferred location for the proposed wastewater treatment and 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, removal of the 14.9-acre area required for the Proposed Action at the preferred site will not significantly 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 Replacement 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 site is selected, EPA will return a finalized copy of the form to the NRCS field office in
accordance with 7 CFR 658.4(g).
5.9 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
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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.
The Pāhala LCC Replacement Project 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.
5.10 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.
5.11 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.
5.12 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 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
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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.
5.13 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 field survey at the preferred site (Site 7) 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.
5.14 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
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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 project site. 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 Preferred Alternative, 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 site of the proposed treatment and disposal facility 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.
The AIS and NHPA Section 106 consultation correspondence can be found in Appendix D and Appendix D-1, respectively. To date, SHPD has not responded to the County’s Draft AIS submittal from March 13, 2019; the EPA letter from September 26, 2019 requesting concurrence with the
determination that no historic properties will be affected by the undertaking; or the County’s follow-
up letter from October 9, 2019 requesting concurrence with the Draft AIS findings. In accordance with 36 CFR § 800.4(d)(1)(i) and as specified in the September 26 letter, because no response was received within 30 days of SHPD receipt of the adequately documented finding, EPA has
fulfilled their Section 106 responsibilities for this undertaking. However, construction will not proceed until SHPD has approved the Draft AIS.
5.15 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 Site 7, 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 Site 7. On August 2018, a
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biological field survey was conducted at Site 7 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 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.
5.16 Rivers and Harbors Act (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 inclosure 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 preferred location for the
proposed wastewater treatment and disposal facility is sited 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 directly affect any streams or gulches. Based on this, the collection system and the treatment and disposal facility will not affect navigable waters.
5.17 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.
5.18 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.
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The State of Hawai‘i has no designated wild and scenic rivers. The Wild and Scenic Rivers Act is not applicable to this project.
5.19 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 Site 7, 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 Site 7. On August 2018, a biological field survey was conducted at Site 7 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 Proposed Action, 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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6 PLANS, POLICIES AND CONTROLS
This section discusses the State and County of Hawai‘i land use plans, policies and controls relating to the proposed project.
6.1 State Land Use Plans and Policies
6.1.1 Hawai‘i State Plan
The Hawai‘i State Plan, Hawai‘i Revised Statues (HRS) 226, as amended, provides goals, objectives, policies, and priorities for the state. The purpose of the Hawaiʻi State Plan is to set forth a plan that shall serve as a guide for the future long-range development of the state; identify the goals, objectives, policies, and priorities for the state; provide a basis for determining priorities and allocating limited resources, such as public funds, services, human resources, land, energy, water, and other resources; improve coordination of federal, state, and county plans, policies, programs, projects, and regulatory activities; and to establish a system for plan formulation and program coordination to provide for an integration of all major state, and county activities. The
proposed project’s consistency with applicable objectives and policies is discussed in Table 6.1. Applicable policies from Part I and III of the Hawaiʻi State Plan are provided in this table. Part II does not apply to the Pāhala Large Capacity Cesspool (LCC) Replacement Project.
Table 6.1
Hawai‘i State Plan Objectives and Policies
Objectives and Policies of the Hawai‘i State Plan Discussion
§ 226-4 State goals. In order to ensure, for present and future generations, those elements of choice and mobility that ensure that individuals and groups may approach their desired levels of self-reliance and self-determination, it shall be the goal of the State to achieve: (1) A strong, viable economy, characterized by stability, diversity, and growth, that enables the fulfillment of the needs and expectations of
Hawai‘i’s present and future generations. (2) A desired physical environment, characterized by beauty, cleanliness, quiet, stable natural systems, and uniqueness, that enhances the mental and physical well-being of the people. (3) Physical, social, and economic well-being, for individuals and families
in Hawaii, that nourishes a sense of community responsibility, of caring, and of participation in community life.
The Pāhala project will support the state economy by providing a wastewater collection system and a treatment and disposal facility to enhance the community and the physical well-being of the community.
§ 226-5 Objective and policies for population. (a) It shall be the objective in planning for the State's population to guide population growth to be consistent with the achievement of physical, economic, and social objectives contained in this chapter.
The Pāhala project does not include facilities or improvements that could guide or otherwise affect population
growth in this area of Hawaiʻi.
§ 226-6 Objectives and policies for the economy--in general. (a) Planning for the State's economy in general shall be directed toward achievement of the following objectives:
The Pāhala project does not include facilities or improvements that affect
the economy of this area of Hawaiʻi.
§ 226-7 Objectives and policies for the economy--agriculture. (a) Planning for the State's economy with regard to agriculture shall be directed towards achievement of the following objectives:
The Pāhala project does not include facilities or improvements which will affect agriculture of this area of
Hawaiʻi. The area used for the treatment and disposal facility will not adversely impact the total macadamia nut production on the state or County.
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Table 6.1
Hawai‘i State Plan Objectives and Policies
Objectives and Policies of the Hawai‘i State Plan Discussion
§ 226-8 Objective and policies for the economy--visitor industry. (a) Planning for the State's economy with regard to the visitor industry shall be directed towards the achievement of the objective of a visitor industry that
constitutes a major component of steady growth for Hawaiʻi's economy
The Pāhala project does not include facilities or improvements that will affect the visitor industry of this area of
Hawaiʻi.
§ 226-9 Objective and policies for the economy--federal expenditures. (a) Planning for the State's economy with regard to federal expenditures shall be directed towards achievement of the objective of a stable federal
investment base as an integral component of Hawai‘i’s economy.
The Pāhala project will include federal expenditures to provide a collection system and treatment and disposal facility for the community.
§ 226-10 Objective and policies for the economy--potential growth and
innovative activities. (a) Planning for the State's economy with regard to potential growth and innovative activities shall be directed towards achievement of the objective of development and expansion of potential growth and innovative activities that serve to increase and diversify Hawaiʻi's economic base.
The Pāhala project does not include facilities or improvements that will affect the potential growth of this area
of Hawaiʻi.
§ 226-10.5 Objectives and policies for the economy--information
industry. (a) Planning for the State's economy with regard to telecommunications and information technology shall be directed toward recognizing that broadband and wireless communication capability and infrastructure are foundations for an innovative economy and positioning
Hawai‘i as a leader in broadband and wireless communications and applications in the Pacific Region.
The Pāhala project does not include facilities or improvements that will affect the information industry of this
area of Hawaiʻi.
§ 226-11 Objectives and policies for the physical environment--land-
based, shoreline, and marine resources. (b) To achieve the land-based, shoreline, and marine resources objectives, it shall be the policy of this State to: (1) Exercise an overall conservation ethic in the use of Hawai‘i’s natural resources. (3) Take into account the physical attributes of areas when planning and designing activities and facilities.
The Pāhala project site is located at least 580 feet above mean sea level and at least 3.3 miles from the shoreline. As such, it will not affect shoreline or marine resources.
§ 226-12 Objective and policies for the physical environment--scenic,
natural beauty, and historic resources. (b) To achieve the scenic, natural beauty, and historic resources objective, it shall be the policy of this State to: (3) Promote the preservation of views and vistas to enhance the visual and aesthetic enjoyment of mountains, ocean, scenic landscapes, and other natural features.
The Pāhala project does not include facilities or improvements that will affect the scenic, natural beauty and historic resources of this area of
Hawaiʻi.
§ 226-13 Objectives and policies for the physical environment--land,
air, and water quality. (b) To achieve the land, air, and water quality objectives, it shall be the policy of this State to: (2) Promote the proper management of Hawai‘i’s land and water resources. (3) Promote effective measures to achieve desired quality in Hawai‘i’s surface, ground, and coastal waters.
The Pāhala project does not include facilities or improvements that will affect the physical environment of this
area of Hawaiʻi.
§ 226-14 Objective and policies for facility systems--in general. The Pāhala project is consistent with
the County of Hawaiʻi plans for facilities.
§ 226-15 Objectives and policies for facility systems--solid and liquid
wastes.
The Pāhala project does include facilities or improvements that will affect liquid waste facilities. The project provides a collection system and treatment and disposal facility for
Pāhala community and closes LCCs in conformance with U.S. Environmental Protection Agency (EPA) requirements.
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Table 6.1
Hawai‘i State Plan Objectives and Policies
Objectives and Policies of the Hawai‘i State Plan Discussion
§ 226-16 Objective and policies for facility systems--water. (a) Planning for the State's facility systems with regard to water shall be directed towards achievement of the objective of the provision of water to adequately accommodate domestic, agricultural, commercial, industrial, recreational, and other needs within resource capacities.
The Pāhala project does not include facilities or improvements that will affect water facilities.
§ 226-17 Objectives and policies for facility systems--transportation. (a) Planning for the State's facility systems with regard to transportation shall be directed towards the achievement of the following objectives:
The Pāhala project does not include facilities or improvements that will adversely affect transportation systems
serving this area of Hawaiʻi.
§ 226-18 Objectives and policies for facility systems--energy. (a) Planning for the State's facility systems with regard to energy shall be directed toward the achievement of the following objectives, giving due consideration to all:
The Pāhala project does not include facilities or improvements that will affect energy systems. Electrical service will be provided by Hawaiʻi Electric and Light Company (HELCO).
§ 226-18.5 Objectives and policies for facility systems--
telecommunications. (a) Planning for the State's telecommunications facility systems shall be directed towards the achievement of dependable, efficient, and economical statewide telecommunications systems capable of supporting the needs of the people.
The Pāhala project does not include facilities or improvements that will affect telecommunications.
§ 226-19 Objectives and policies for socio-cultural advancement--
housing. (a) Planning for the State's socio-cultural advancement with regard to housing shall be directed toward the achievement of the following objectives:
The Pāhala project does not include facilities or improvements that will affect housing.
§ 226-20 Objectives and policies for socio-cultural advancement--
health. (a) Planning for the State's socio-cultural advancement with regard to health shall be directed towards achievement of the following objectives:
The Pāhala project does not include facilities or improvements that will
affect the health of this area of Hawaiʻi.
§ 226-21 Objective and policies for socio-cultural advancement--
education. (a) Planning for the State's socio-cultural advancement with regard to education shall be directed towards achievement of the objective of the provision of a variety of educational opportunities to enable individuals to fulfill their needs, responsibilities, and aspirations
The Pāhala project does include
facilities or improvements that will affect the educational opportunities in
this area of Hawaiʻi.
§ 226-22 Objective and policies for socio-cultural advancement--social
services. (a) Planning for the State's socio-cultural advancement with regard to social services shall be directed towards the achievement of the objective of improved public and private social services and activities that enable individuals, families, and groups to become more self-reliant and confident to improve their well-being.
The Pāhala project does not include facilities or improvements that will affect social services of this area of
Hawaiʻi.
§ 226-23 Objective and policies for socio-cultural advancement--
leisure. (a) Planning for the State's socio-cultural advancement with regard to leisure shall be directed towards the achievement of the objective of the adequate provision of resources to accommodate diverse cultural, artistic, and recreational needs for present and future generations.
The Pāhala project does not include facilities or improvements that will affect the leisure activities.
§ 226-24 Objective and policies for socio-cultural advancement--
individual rights and personal well-being. (a) Planning for the State's socio-cultural advancement with regard to individual rights and personal well-being shall be directed towards achievement of the objective of increased opportunities and protection of individual rights to enable individuals to fulfill their socio-economic needs and aspirations.
The Pāhala project does not include facilities or improvements that will affect individual rights.
§ 226-25 Objective and policies for socio-cultural advancement--
culture. (a) Planning for the State's socio-cultural advancement with regard to culture shall be directed toward the achievement of the objective of enhancement of cultural identities, traditions, values, customs, and arts of
Hawai‘i’s people.
The Pāhala project does not include facilities or improvements that will affect the cultural advancement.
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Table 6.1
Hawai‘i State Plan Objectives and Policies
Objectives and Policies of the Hawai‘i State Plan Discussion
§ 226-26 Objectives and policies for socio-cultural advancement--
public safety. (a) Planning for the State's socio-cultural advancement with regard to public safety shall be directed towards the achievement of the following objectives:
The Pāhala project does not include facilities or improvements that will adversely affect public safety of this
area of Hawaiʻi.
§ 226-27 Objectives and policies for socio-cultural advancement--
government. (a) Planning the State's socio-cultural advancement with regard to government shall be directed towards the achievement of the following objectives:
The Pāhala project does not include facilities or improvements that will affect the advancement of government.
§ 226-101 Purpose. The purpose of this part is to establish overall priority guidelines to address areas of statewide concern. [L 1978, c 100, pt of § 2; am L 1984, c 236, § 14]
The Pāhala project does not include facilities or improvements that will affect overall priority guidelines of statewide concern.
§ 226-102 Overall direction. The State shall strive to improve the quality of life for Hawaii's present and future population through the pursuit of desirable courses of action in seven major areas of statewide concern which merit priority attention: economic development, population growth and land resource management, affordable housing, crime and criminal justice, quality education, principles of sustainability, and climate change adaptation.
The Pāhala project will affect short-term economic development and jobs during the construction period. The
Pāhala project will not affect long-term economic development, population growth and land resource management, affordable housing, crime and criminal justice, quality education and climate change adaption. Removal of cesspools is consistent with the principles of sustainability.
§ 226-103 Economic priority guidelines. (a) Priority guidelines to stimulate economic growth and encourage business expansion and development to provide needed jobs for Hawaii's people and achieve a stable and diversified economy. (e) Priority guidelines for water use and development: (1) Maintain and improve water conservation programs to reduce the overall water consumption rate. (2) Encourage the improvement of irrigation technology and promote the use of nonpotable water for agricultural and landscaping purposes.
The Pāhala project will stimulate economic development and jobs during the construction period.
§ 226-104 Population growth and land resources priority guidelines. (a) Priority guidelines to effect desired statewide growth and distribution:
The Pāhala project will not affect population growth but may help protect the environment and improve water quality in nearby surface water resources.
§ 226-105 Crime and criminal justice. Priority guidelines in the area of crime and criminal justice:
The Pāhala project will not affect crime
or criminal justice in the Pāhala area.
§ 226-106 Affordable housing. Priority guidelines for the provision of affordable housing:
The Pāhala project will not affect
affordable housing in the Pāhala area.
§ 226-107 Quality education. Priority guidelines to promote quality education:
The Pāhala project will not affect education in the Pāhala area.
§ 226-108 Sustainability. Priority guidelines and principles to promote sustainability include: (5) Promoting decisions based on meeting the needs of the present without compromising the needs of future generations.
The Pāhala project will close two large capacity cesspools, replacing them with secondary treatment and disposal systems, thereby protecting groundwater resources for future generations, potentially benefitting the health and vitality of the area coastal and marine ecosystem.
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Table 6.1
Hawai‘i State Plan Objectives and Policies
Objectives and Policies of the Hawai‘i State Plan Discussion
§ 226-109 Climate change adaptation priority guidelines. Priority guidelines to prepare the State to address the impacts of climate change, including impacts to the areas of agriculture; conservation lands; coastal and nearshore marine areas; natural and cultural resources; education; energy; higher education; health; historic preservation; water resources; the built environment, such as housing, recreation, transportation; and the economy.
The wastewater treatment and disposal facility will be designed to contain the 100-year, 24-hour storm event while maintaining sufficient freeboard to account for the uncertainty of climate model projections.
6.1.2 State Functional Plans
The Hawai‘i State Plan directs appropriate state agencies to prepare Functional Plans to address
statewide needs, problems, and issues through recommended policies and actions. A total of 14 Functional Plans were prepared to implement the State Plan provisions in the areas of agriculture, transportation, conservation lands, education, tourism, water resources, energy, recreation, historic preservation, health, housing, higher education, employment, and human services. The following presents a review of the Functional Plans which are applicable to the proposed project.
(a) Agriculture Functional Plan
Objective B: Achievement of an orderly agricultural marketing system through product
promotion and industry organization.
Policy B.2: Encourage the development of Hawaiʻi’s agricultural industries.
Objective C: Achievement of optimal contribution by agriculture to the state’s economy.
Discussion: Agriculture is the major source of economic activity in Kaʻū. The 2012 Census of Agriculture shows 18,006 acres of land in the State of Hawaiʻi were dedicated to growing
macadamia trees, of which 17,378 acres were located in Hawaiʻi County. Though the proposed wastewater treatment and disposal facility project site is currently planted with macadamia trees,
the proposed project will have negligible impact on the macadamia industry in Kaʻū as the 14.9-acre project site is relatively small compared to the 17,378 acres dedicated to macadamia
production in Hawaiʻi County. Moreover, the project site is situated on poorer-quality agriculture land. According to the Land Study Bureau Agricultural Productivity Ratings Map about 50 percent of the project site is classified as having Good productivity, while the 50 percent has a productivity rating of Poor. Furthermore, according to the Agricultural Lands of Importance to the State of
Hawaiʻi Classification System only 20 percent of the treatment and disposal project site is considered Prime Lands with roughly 40 percent deemed Other Lands, while the remaining 40 percent is Unclassified. Overall, the proposed wastewater treatment and disposal facility will be
sited and designed to minimize the use of agricultural lands for non-agricultural purposes. Removal of 14.9 acres from macadamia nut production will not adversely affect the total macadamia nut acreage in the state or the County. Further, use of the 14.9-acre area for the
treatment and disposal facility will not be contrary to the objective of contribution of agriculture to
the state’s economy.
(b) Historic Preservation Functional Plan
Objective B: Protection of Historic Properties
Policy B.2. Establish and make available a variety of mechanisms to better protect
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historic properties.
Objective C: Management and Treatment of Historic Properties
Policy C.3. Explore innovative means to better manage historic properties.
Policy C.4. Encourage proper preservation techniques.
Discussion: The wastewater collection system will be constructed primarily within the existing
County streets in the Pāhala community which has been previously disturbed when the streets were constructed. Preliminary analysis shows the wastewater treatment and disposal facility will be constructed in an area that does not contain archaeological resources. An Archaeological Inventory Survey (AIS), which included subsurface testing, was conducted to confirm the presence or absence of archaeological resources on the project site. The AIS confirmed no
significant artifacts or cultural deposits were observed on the ground surface within the proposed treatment and disposal facility 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. Under HRS § 6E-8 and in accordance with HAR § 13-275-7(a)(1), the County of Hawaiʻi Department of Environmental Management’s (DEM) project effect determination is “no historic properties affected.” Construction will not proceed until the State Historic Preservation Division (SHPD) has approved the AIS. For more information, please refer to Appendix D.
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 SHPD, who will assess the significance of the find and recommend an appropriate mitigation measure, if necessary.
6.1.3 State Land Use District
The State Land Use Law, HRS 205 (Land Use Commission), is intended to preserve, protect and encourage the development of lands in the state for uses that are best suited to the public health and welfare of Hawai‘i’s people. Under HRS 205, all lands in the State of Hawai‘i are classified
by the State Land Use Commission into four major categories referred to as State Land Use Districts. These districts are identified as the Urban District, Agricultural District, Conservation District, and Rural District.
Discussion: The wastewater treatment and disposal facility is located in the Agricultural District. Uses in the Agricultural District are governed by HRS 205. Permissible uses in the Agricultural District are set forth in HRS § 205-4.5 (a)(7) which states “Public, private, and quasi-public utility lines and roadways, transformer stations, communications equipment buildings, solid waste transfer stations, major water storage tanks, and appurtenant small buildings such as booster pumping stations, but not including offices or yards for equipment, material, vehicle storage, repair or maintenance, or treatment plants, or corporation yards, or other like structures.”
HRS § 205-4.5(b) states: “Uses not expressly permitted in subsection (a) shall be prohibited, except the uses permitted as provided in sections 205-6 and 205-8.” HRS § 205-6(a) states:
“Subject to this section, the county planning commission may permit certain unusual and reasonable uses within agricultural and rural districts other than those for which the district is
classified. Any person who desires to use the person's land within an agricultural or rural district other than for an agricultural or rural use, as the case may be, may petition the planning commission of the county within which the person's land is located for permission to use the
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person's land in the manner desired.” Based on the above, the County will apply for a Special Permit which will require approval by the County Planning Commission.
6.1.4 Chapter 344, State Environmental Policy
The State’s Environmental Policy is contained in Chapter 344 of HRS. The purpose of HRS 344 is to “establish a state policy which will encourage productive and enjoyable harmony between
people and their environment, promote efforts which will prevent or eliminate damage to the
environment and biosphere and stimulate the health and welfare of humanity, and enrich the
understanding of the ecological systems and natural resources important to the people of
Hawai‘i.”
HRS § 344-3 (Environmental policy) provides: It shall be the policy of the State, through its programs, authorities, and resources to:
Conserve the natural resources, so that land, water, mineral, visual, air and other natural
resources are protected by controlling pollution, by preserving or augmenting natural
resources, and by safeguarding the State’s unique natural environmental characteristics
in a manner which will foster and promote the general welfare, create and maintain
conditions under which humanity and nature can exist in productive harmony, and fulfill
the social, economic, and other requirements of the people of Hawai‘i.
Enhance the quality of life by:
(D) Establishing a commitment on the part of each person to protect and
enhance Hawaiʻi’s environment and reduce the drain on nonrenewable
resources.
HRS § 344-4 (Guidelines) states: In pursuance of the state policy to conserve the natural resources and enhance the quality of life, all agencies, in the development of programs, shall, insofar as practicable, consider the following guidelines:
(2) Land, water, mineral, visual, air, and other natural resources.
(A) Encourage management practices which conserve and fully utilize all
natural resources;
(B) Promote irrigation and waste water management practices which conserve
and fully utilize vital water resources;
(C) Promote the recycling of waste water;
Discussion: One of the purposes of the project is to close the LCCs which have been used for
years for disposal of untreated sewage from Pāhala community. Although use of the LCCs has not resulted in known adverse effects to groundwater resources or the drinking water sources for the community, closure of the LCCs will remove this possible source of contamination. Thus, the
Pāhala LCC Replacement Project will enhance the groundwater resources in the area. This will be compatible with the objective to prevent or eliminate damage to the environment. As discussed throughout Section 3, the Proposed Action will incorporate mitigation measures to protect and conserve natural resources.
6.1.5 Hawai‘i Coastal Zone Management Program
The Coastal Zone Management (CZM) Program was created through passage of the Coastal Zone Management Act of 1972. Hawai‘i’s CZM Program, adopted as HRS Chapter 205A, provides a basis for protecting, restoring and responsibly developing coastal communities and resources. The Hawai‘i CZM area includes all lands within the state and the areas seaward to the extent of the state’s management jurisdiction. Thus, the Pāhala project is located in the CZM area.
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A discussion of the project’s consistency with the objectives and policies of the CZM Program is provided below.
(a) Recreational Resources
Objective:
Provide coastal recreational opportunities accessible to the public.
Policies:
(E) 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;
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.
Discussion: All project locations are at least 3.3 miles from the shoreline and, as such, coastal recreational resources will not be affected.
(b) Historic Resources
Objective:
(B) 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:
(D) Identify and analyze significant archaeological resources;
(E) Maximize information retention through preservation of remains and artifacts or
salvage operations; and
(F) Support state goals for protection, restoration, interpretation, and display of historic
resources.
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The wastewater collection system will be constructed primarily within the existing County streets
within the Pāhala community which has been previously disturbed when the streets were
constructed. Preliminary analysis shows the wastewater 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 archeological resources
on the project site. The AIS confirmed no significant artifacts or cultural deposits were observed on the ground surface within the proposed treatment and disposal facility 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. Under HRS § 6E-8, and in accordance with HAR § 13-275-7(a)(1), the County of Hawaiʻi DEM’s project effect determination is “no historic properties affected.” Construction will not proceed until SHPD has approved the AIS. For more information, please refer to Appendix D.
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 SHPD, who will assess the significance of the find and recommend an appropriate mitigation measure, if necessary.
(c) Scenic and Open Space Resources
Objective:
(B) Protect, preserve, and where desirable, restore or improve the quality of coastal
scenic and open space resources.
Policies:
(E) Identify valued scenic resources in the coastal zone management area;
(F) 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;
(G) Preserve, maintain, and, where desirable, improve and restore shoreline open
space and scenic resources; and
(H) Encourage those developments which are not coastal dependent to locate in
inland areas.
Discussion: 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.
(d) Coastal Ecosystems
Objective:
(A) Protect valuable coastal ecosystems, including reefs, from disruption and minimize
adverse impacts on all coastal ecosystems.
Policies:
(F) Exercise an overall conservation ethic, and practice stewardship in the protection,
use, and development of marine and coastal resources;
(G) Improve the technical basis for natural resource management;
(H) Preserve valuable coastal ecosystems, including reefs, of significant biological or
economic importance;
(I) 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
(J) Promote water quantity and quality planning and management practices that
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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.
Discussion: All project locations are at least 3.3 miles from the shoreline and, as such, coastal ecosystems will not be adversely affected.
(e) Economic Uses
Objective:
(B) Provide public or private facilities and improvements important to the State’s
economy in suitable locations.
Policies:
(D) Concentrate coastal dependent development in appropriate areas;
(E) 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
(F) 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:
(iv) Use of presently designated locations is not feasible;
(v) Adverse environmental effects are minimized; and
(vi) The development is important to the State’s economy.
Discussion: All project locations are at least 3.3 miles from the shoreline. The collection system and the wastewater treatment and disposal facility have been sited in suitable locations to serve
the Pāhala community.
(f) Coastal Hazards
Objectives:
(A) Reduce hazard to life and property from tsunami, storm waves, stream flooding,
erosion, subsidence, and pollution.
Policies:
(C) Develop and communicate adequate information about storm wave, tsunami,
flood, erosion, subsidence, and point and nonpoint source pollution hazards;
(D) Control development in areas subject to storm wave, tsunami, flood, erosion,
hurricane, wind, subsidence, and point and nonpoint pollution hazards;
(F) Ensure that developments comply with requirements of the Federal Flood
Insurance Program;
(G) Prevent coastal flooding from inland projects.
Discussion: 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 collection system and wastewater treatment and disposal facility 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.
(g) Managing Development
Objective:
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(A) Improve the development review process, communication, and public participation
in the management of coastal resource and hazards.
Policies:
(D) Use, implement, and enforce existing law effectively to the maximum extent
possible in managing present and future coastal zone development;
(E) Facilitate timely processing of applications for development permits and resolve
overlapping or conflicting permit requirements; and
(F) 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.
Discussion: In December 2017, a total of five community outreach sessions regarding the project
were conducted in the Pāhala community. A public information meeting for the Draft EA was held in October 2018. All project locations are at least 3.3 miles from the shoreline. The collection
system and wastewater treatment and disposal facility do not involve management of coastal resources and hazards.
(h) Public Participation
Objective:
(B) Stimulate public awareness, education, and participation in coastal management.
Policies:
(D) Promote public involvement in coastal zone management processes;
(E) 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
(F) Organize workshops, policy dialogues, and site-specific mediations to respond to
coastal issues and conflicts.
Discussion: In December 2017, a total of five community outreach sessions were conducted in
the Pāhala community. A public information meeting for the Draft EA was held in October 2018. The County also conducted a meeting in March 2019 to gain further input from newly accessible
property owners and to fulfill a County commitment made in October 2018 to research and provide financing options available to owners of parcels that will become newly accessible to the County collection system. All project locations are at least 3.3 miles from the shoreline.
(i) Beach Protection
Objective:
(A) Protect beaches for public use and recreation.
Policies:
(I) 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;
(J) 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
(K) Minimize the construction of public erosion-protection structures seaward of the
shoreline.
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Discussion: All project locations are at least 3.3 miles from the shoreline. The collection system and the wastewater treatment and disposal facility project does not include improvements that
will affect public use beaches.
(j) Marine Resources
Objective:
(A) Promote the protection, use, and development of marine and coastal resources to
assure their sustainability.
Policies:
(L) Ensure that the use and development of marine and coastal resources are
ecologically and environmentally sound and economically beneficial;
(M) Coordinate the management of marine and coastal resources and activities to
improve effectiveness and efficiency;
(N) 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;
(O) 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
(P) 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 collection system and the wastewater treatment and disposal facility project does not include improvements that will affect development of marine and coastal resources.
6.2 Hawai‘i County Land Use Plans and Policies
6.2.1 Hawai‘i County General Plan
The existing General Plan was adopted in 2005. According to that plan, a comprehensive review process is to be initiated no more than 10 years after the previous review. A lot has happened on the Island of Hawai‘i since 2005, including population growth, natural disasters, technological advancements, and the emphasis on sustainability. These factors are being considered in the 2015 General Plan. The Planning Director is responsible for leading the review process and recommending amendments to the Plan. Since this review has not been completed, the 2005 General Plan will be used for analysis.
The February 2005 General Plan serves as a policy document outlining long range comprehensive development on the Island of Hawai‘i, providing broad goals, objectives, policies,
and implementing actions that portray the desired direction of the County’s future. Purposes of
the General Plan include:
• Guide the pattern of future development in this County based on long-term goals.
• Identify the visions, values, and priorities important to the people of this County.
• Provide the framework for regulatory decisions, capital improvement priorities,
acquisition strategies, and other pertinent government programs within the County
organization and coordinated with State and Federal programs.
• Improve the physical environment of the County as a setting for human activities; to
make it more functional, beautiful, healthful, interesting, and efficient.
• Promote and safeguard the public interest and the interest of the County as a whole.
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• Facilitate the democratic determination of community policies concerning the
utilization of its natural, man-made, and human resources.
• Effect political and technical coordination in community improvement and
development.
• Inject long-range considerations into the determination of short-range actions and
implementation.
The planning process utilized for the current comprehensive review and revision of the General Plan included an assessment of the General Plan elements relative to new data, laws, and methods of analysis. Each study element was then analyzed and evaluated in relation to all other elements, County and district goals, and the land use pattern. Potentially, a change in one element could affect other elements as well as the land use pattern. Similarly, a change in County and district goals could potentially be reflected in all elements and in the land use pattern.
The comprehensive review of the General Plan gathered and assessed the data related to each element to identify present conditions and problems and future possibilities. The study elements utilized in the General Plan included the following:
Economic: Describes the human, capital, and natural resources used to produce goods
and services for consumption in local and overseas markets.
Energy: Describes the energy situation for the County and explains the incentive for
promoting energy conservation and the development of indigenous energy resources
including solar, wind, hydrologic, and geothermal.
Environmental Quality: Identifies the factors affecting the island's environmental quality
and describes the precautions and safeguards necessary to maintain and improve the
quality of the environment for the physical, psychological, and social wellbeing of residents
and visitors.
Flooding and Other Natural Hazards: Pertains to the conservation and protection of life,
improvements, and natural resources from excess runoff due to either man-made
improvements, natural causes, or inundation from tsunamis and heavy seas.
Historic Sites: Identifies sites and buildings of historical and cultural importance.
Natural Beauty: Identifies areas of unique natural beauty that are a principle asset of the
island, and encourages programs for their conservation, preservation, and integration with
other elements.
Natural Resources and Shoreline: Describes the valuable and often irreplaceable
natural assets of the island and encourages programs for their proper management and
protection.
Housing: Addresses the requirements for and the quantity, quality, and distribution of
housing units in the County. This element also addresses critical housing problems of the
County.
Public Facilities: Pertains to the location and distribution of facilities for education, public
safety, social, health services and other government operations.
Public Utilities: Describes the distribution of power, light, and water; the collection and
disposal of solid waste and sewage; and the provision of other communication utilities that
are essential to the efficient functioning of a community.
Recreation: Examines the requirements of the County for active and passive outdoor
activities, cultural events and pastimes, as well as attendant facilities and areas.
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Transportation: Describes the requirements for air and water transport terminal facilities
linking the County with the rest of the State and overseas areas, and the island's network
of streets, highways, and roads.
Land Use: Studies the relationship of human activities to the uses of land and the location,
spatial relationship, and topography. This element is subdivided into the following
designations according to uses:
Agricultural: Encompasses all types of agricultural endeavors and specified industrial
uses, residential and ancillary community and public and accessory uses.
Commercial: Comprised of industries in the retail trade and service categories and certain
non-noxious enterprises from other industrial classifications.
Industrial: Includes uses that may not be compatible with commercial areas (such as
manufacturing and processing, wholesaling, large storage and transportation facilities,
power plants, and government baseyards) as well as other industrial, manufacturing, or
wholesaling uses.
Multiple Residential: Includes duplexes, apartments, town houses and similar types of
residential structures and ancillary community and public uses.
Open Space: Includes conservation lands, forest and water reserves, natural and
scientific preserves, and potential natural hazard areas.
Public Lands: Includes Federal, State, County, and University owned lands.
Resort: Consists primarily of areas with basic amenities and attributes that attract
developments of visitor accommodations and related facilities.
Single-Family Residential: Consists of single-family detached houses and ancillary
community and public uses.
Discussion: Based on the above, the Pāhala LCC Replacement project will be consistent with the Public Utilities element by providing a wastewater collection system designed to the applicable
current standards used by the County. As previously described, the current collection system includes lines located the backyard of many of the parcels in the community. The County must obtain permission from each landowner to access lines on private property to inspect, maintain,
repair, or replace the lines. The proposed collection system will be located within the public streets in the community or within accessible easements which allow the County to inspect, maintain, repair or replace the lines, all of which are essential to an efficient functioning community.
Pāhala currently disposes untreated sewage into LCCs, which have been banned by EPA. The proposed secondary treatment to replace the LCCs consists of aerated lagoons, a subsurface flow wetland, and a disinfection system. The disposal system consists of a slow-rate land application system that is a form of land treatment that is recognized by EPA. The treatment and disposal facility will provide a system to replace the banned LCCs which will be essential to an efficient functioning community.
The General Plan discusses sewers in Section 11.6. The plan states:
Adequate sewer disposal systems are vital to safeguard public health and preserve the
environment. An adequate system is one that minimizes contamination of both the
groundwater supply and the coastal waters, beaches and waterborne recreational areas
and is not a visual and odor nuisance.
About 77 per cent of the County's population is served by cesspools. There is an
increasing need to create a better system than individual cesspools, particularly in highly
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urbanized and shoreline areas. This is due to the possible pollution of groundwater as well
as cesspool seepage into coastal waters. More stringent pollution controls, especially in
water quality standards, are being imposed by regulatory agencies. The State Department
of Health (DOH) intends to promulgate rules that will prohibit cesspools in the County of
Hawaii. [In 2017, the State passed Act 125 requiring all cesspools statewide to be
upgraded/closed by 2050.]
Hawai‘i County presently operates municipal sewerage in Hilo, Pāpaʻikou, Kapehu,
Pepeʻekeo and Kealakehe. The remaining communities are served by private wastewater
treatment facilities or individual facilities such as cesspools or septic tanks.
In August 1991, the State Department of Health adopted rules that require the use of
septic systems in the most critical wastewater disposal areas. Critical wastewater disposal
areas are areas around the island where cesspools are permitted. Sewerage disposal
system designs must be examined with the particular area in mind. However, it is important
to note that the critical wastewater disposal areas may be eliminated in the near future
when the State Department of Health implements the prohibition of cesspools.
Specific standards are discussed in Section 11.6.3 Standards which includes the following.
(a) Incorporate sewage works standards proposed in the "Sewerage Study for All Urban
and Urbanizing Areas of the County of Hawaiʻi" and the "Water Quality Management
Plan for the County of Hawaiʻi."
(b) Sewerage systems shall be designed for a particular area, depending on topography,
geology, density of population, costs, and other considerations of the specific area.
(c) There shall be a minimum of visual and odor pollution emanating from sewerage
treatment facilities.
(d) Applicable standards and regulations of the State Department of Health, Chapter 23
"Underground Injection Control."
(e) Applicable standards and regulations of the State Department of Health, Chapter 54
"Water Quality Standards."
(f) Applicable standards and regulations of the State Department of Health, Chapter 55
"Water Pollution Control."
(g) Applicable standards and regulations of the State Department of Health, Chapter 62,
HRS, "Wastewater Systems."
(h) Applicable standards and regulations of Chapter 342, HRS; Act 282, Session Laws
of Hawai‘i 1985; and Act 302, Session Laws of Hawai‘i 1986, Relating to
Environmental Quality.
(i) All wastewater disposal systems shall conform to the applicable provisions of Chapter
11-62, Hawai‘i Administrative Rules for the Department of Health to ensure proper
treatment and disposal of wastewater and to prevent further contamination of
waterways, underground water sources, and the coastal waters.
Discussion: The proposed secondary treatment to replace the LCCs consists of aerated lagoons, a subsurface flow wetland, and a disinfection system. The disposal system consists of a slow-rate land application system that is a form of land treatment that is recognized by EPA. The treatment and disposal facility will be designed to meet rules and regulations applicable to the facility which will replace the banned LCCs. The design drawings and related calculations and analysis will be submitted to the DOH for review and comment. The design of the facility will require approval by the DOH before the DOH will issue an approval to operate the treatment and
disposal facility.
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6.2.2 Ka‘ū Community Development Plan
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. In October 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.
There are two types of County policies in the CDP:
1. “Land Use Policies” are the official land use policy guidance for the Ka‘ū CDP planning area and shall be implemented through all County of Hawai‘i actions. In addition, the Land Use Policies shall inform County recommendations to other agencies, including the State
Land Use Commission regarding district boundary amendments, special permits, and
other applications in Ka‘ū.
There are two aspects of Land Use Policies:
Policy Intent: These are general statements that express policy aims or objectives. From
a legal standpoint, these “hortatory” policies are open to interpretation when applied in specific instances.
Policy Controls: These limit the range of decisions that can be made in the future, like land use policies that specifically designate future settlement or transportation patterns. These
binding, sometimes restrictive policy controls often include use of the term “shall,” which, from a legal standpoint, means the policy is imperative or mandatory.
The CDP distinguishes these two aspects of Land Use Policy. The applicable one is:
2. “County Actions” are the official County policies to guide future County priorities and
initiatives, including operating and capital budgets. These policies are not mandated,
legally‐binding, or self‐implementing; rather, they often require additional legislative and
administrative directives before being implemented (e.g., land acquisition, capital
improvement appropriations, code changes, incentive measures).
All of the CDP Land Use Policies are designed to preserve the preferred future settlement pattern
and achieve the Community Objectives as Ka‘ū grows. There are Land Use Policies designed to protect coastal areas, agricultural lands, mauka forests, scenic areas, sensitive ecosystems, cultural resources, and public access. The following Land Use Policies speak more generally to
the preservation of the preferred settlement pattern in Ka‘ū, including the relative location of residential, commercial, industrial, and resort areas.
A series of 15 policies are shown in the Ka‘ū CDP to guide land uses within Pāhala. Figure 6.1 shows the land use policy map for Pāhala.
Policy 1 Rehabilitate and develop within existing zoned urban areas already served by
basic infrastructure, or close to such areas, instead of scattered development.
Policy 2 Concentrate commercial uses within and surrounding central core areas in
Pāhala, Nāʻālehu, and Ocean View and do not allow strip or spot commercial
development outside of the designated urban areas.
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Figure 6.1. Community Development Plan Land Use Policy Map
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Policy 3 Commercial facilities shall be developed in areas adequately served by
necessary services, such as water, utilities, sewers, and transportation
systems. Should such services not be available, the development of more
intensive uses should be in concert with a localized program of public and
private capital improvements to meet the expected increased needs.
Policy 4 Industrial development shall be located in areas adequately served by
transportation, utilities, and other essential infrastructure.
Policy 7 With the adoption of the Ka‘ū CDP, the Land Use Policy Map is adopted as the
official policy for the Ka‘ū CDP planning area. Future land use decisions in the
Ka‘ū CDP planning area shall be consistent with the Land Use Policy Map
boundaries, designations, and policies herein, unless the CDP and the General
Plan are in direct conflict.
Policy 8 In the “Low Density Urban (LDU)” Land Use Policy Map category in the Ka‘ū
CDP planning area, changes of zone shall only be permitted to Single-Family
Residential (RS), Multiple-Family Residential (RM-7.5 or higher), Residential-
Commercial Mixed Use (RCX-7.5 or higher), or Open (O).
In Pāhala, this policy supports a rezone of TMKs (3)9-6-002:016 & 023:034 from
Agricultural (A-1a) and Industrial (ML-20 and MG-1a) to RS and/or O to take advantage
of existing water and road infrastructure.
Policy 9 If infill capacity is exceeded in areas designated “Low Density Urban (LDU)” on
the Land Use Policy Map in Pāhala, it would be appropriate to designate TMK
(3)9-6-005:001 as LDU to take advantage of existing water and road
connections.
Policy 39 The urban growth boundary between agricultural areas (designated “Important
Agricultural Land” or “Extensive Agriculture”) and developed areas (designated
“Rural,” “Low/Medium/High Density Urban,” “Industrial,” or “Resort”) is parcel-
specific in the Ka‘ū CDP planning area, except at Punaluʻu and the
Low/Medium Density Urban and Industrial nodes in Ocean View. Areas outside
designated developed areas shall be preserved as agricultural lands, open
space, scenic view planes, and natural beauty areas, unless the CDP and the
General Plan are in direct conflict.
Policy 44 Through permit conditions, development agreements, deed restrictions, and/or
other means, ensure that areas in the “Important Agricultural Land” and
“Extensive Agriculture” Land Use Policy Map categories continue to be utilized
for agricultural uses and not for speculative or other residential development.
Policy 69 Protect, restore, and enhance the sites, buildings, and objects of significant
historical and cultural importance to Hawai‘i.
Policy 70 Protect all rights, customarily and traditionally exercised for subsistence,
cultural and religious purposes and possessed by ahupua‘a tenants who are
descendants of native Hawaiians who inhabited the Hawaiian Islands prior to
1778, subject to the right of the State to regulate such rights.
Policy 71 Review and comment by DLNR’s State Historic Preservation Division (SHPD)
shall be requested for any permit or entitlement for use which may affect any
building, structure, object, district, area, or site that is over fifty years old, except
as provided in HRS section 6E-42.2.
Policy 72 In the “Low Density Urban” (LDU) and “Medium Density Urban” Land Use
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Policy Map categories, in those cases where provisions of the zoning and
subdivision codes are inconsistent with the character of surrounding
neighborhoods, variances or PUDs that maintain consistent village/town
character should be encouraged.
Policy 73 The development of commercial facilities should be designed to fit into the
locale with minimal intrusion while providing the desired services. Appropriate
infrastructure and design concerns shall be incorporated into the review of
such developments.
Policy 74 As appropriate to maintain community character while also accommodating
drainage, walkability, maintenance, and other site-specific needs when
improving existing roads in Pāhala, Nāʻālehu, and Wai‘ōhinu, retain the current
road design, including pavement width and lack of curbs, gutters, sidewalks,
or paved shoulders and swales.
Policy 75 As appropriate to maintain community character while also accommodating
drainage, walkability, maintenance, and other site-specific needs, new roads
(both public and private) in the Ka‘ū CDP planning area may be constructed
without curbs, gutters, sidewalks, or paved shoulders and swales.
Policy 90 Implement protocols for receiving community input at meetings in Ka‘ū during
capital project siting and design. Consult with and solicit input from community
members with generational knowledge to minimize the impact of proposed
changes to the use of land on cultural practices, cultural sites, and culturally
significant areas, including burials.
Discussion: The Pāhala LCC Replacement Project is consistent with land use policies as the improvements are designed to serve the designated areas shown in the Land Use Policy Map,
which shows Pāhala as primarily low density urban. The collection system and the wastewater
treatment and disposal facility will be consistent with the policy related to infill of commercial
development within the Pāhala community. The collection system improvements are consistent with the policy to maintain the community character as the improvements will retain the existing
pavement, including retention of streets, shoulders, and drainage systems.
Section 4.3 of the CDP protects agricultural land and open space from non-agricultural development with the CDP Land Use Policy Map, urban growth boundaries, limits on Special
Permits and lots sizes, and restrictions on residential development. It also prioritizes agricultural subdivision standards, revisions in water catchment variance rules, stronger farm dwelling regulations and tax incentive programs, development of transfer of development rights and land bank programs, State Important Agricultural Land designations, and expedited lot consolidation in existing rural subdivisions.
Policy 40 Special permits of any kind in the “Important Agricultural Land” and “Extensive
Agriculture” Land Use Policy Map categories should not be permitted in the
Ka‘ū CDP planning area, except for the following uses (as defined in HCC
chapter 25):
• Agriculture and Related Economic Infrastructure: Animal hospitals,
Veterinary establishments, Fertilizer yards utilizing only manure and
soil, for commercial use
• Cottage Industry related to Agriculture: Bed and breakfast
establishments, Guest ranches, Lodges, Home occupations
• Community Facilities: Community buildings, Public uses and
structures, Shooting ranges, ATV courses (in areas without cultural,
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natural resource, or scenic value)
• Quarries whose permit conditions address geotechnical, engineering,
safety, private road use, oversight, and any site-specific issues.
• Urban Uses in Ocean View: Uses consistent with the LDU, MDU, and
Industrial LUPAG categories indicated on the Ka‘ū CDP Land Use
Policy Map in Ocean View, until the SLU boundaries are amended
(from Agriculture to Urban).
The Planning Commission shall also include in any Special Permit approval (or recommend for
approval to the State Land Use Commission) appropriate performance conditions to achieve CDP
objectives and implement CDP policies. (HRS 205-6(c) and Planning Commission Rules 6-
3(a)(5)(G), 6-7, & 6-8)
Discussion: The collection system and the wastewater treatment and disposal facility will be
owned the County of Hawai‘i and managed and operated by the County of Hawai‘i DEM. As such, the improvements will be a public use and structure. The DEM will file a Special Permit for review and approval by the County Planning Commission.
Section 5 of the CDP prioritizes improvements in infrastructure, facilities, and services, including Section 5.8 applicable to Environmental Management as shown below.
• 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.
Discussion: 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.
Further, the Preliminary Engineering Report (PER) Section 5.6 (Appendix B) provides information
related improvements needed to wastewater services to the Pāhala community as envisioned in the CDP. The PER Section 5.6.2 states:
“To accommodate the flow increase anticipated from the full buildout of the Pāhala wastewater collection system, the [wastewater treatment and disposal facility] (WWTP) will require facility upgrades. The recommended upgrades include headworks and odor control expansion within the 14.9-acre site. Additionally, the lagoon system will require modifications. Lagoon 1 will be converted to a complete mix aerated lagoon environment
to accommodate wastewater treatment needs. In a complete mix aerated lagoon, sufficient mixing energy is provided to maintain the lagoon solids in suspension always. A completely mixed aerated lagoon system performs as an activated sludge process
without solid recycle. The higher mixing energy, as compared to a partial mix lagoon, creates greater opportunity for contact between the naturally-occurring micro-organisms in the lagoon and dissolved organic matter. As a result, complete mix lagoons provide
greater levels of treatment within a smaller volume than partial mix lagoons. However, facilities must be provided downstream of complete mixed lagoons to allow removal of settleable solids from the water column. To provide a place for solid settling, lagoons 2 through 4 will continue to act as partial mix aerated lagoons downstream of the complete
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mix lagoon 1. Lagoon 4 will require no aeration and will continue to be covered to deprive algae of sunlight and allow suspended solids to settle out of the system effluent.
Utilizing this lagoon system approach, the Pāhala WWTP will require modification at full buildout flow, but is not anticipated to expand beyond the initial build 14.9-acre site.”
6.2.3 County of Hawai‘i Zoning
Hawai‘i County Code (HCC) Chapter 25 regulates land use in accordance with adopted land use policies. The code presents permitted uses and structures, development standards, and height controls for each zoning district.
The wastewater treatment and disposal facility will be owned the County of Hawai‘i and managed and operated by the County of Hawai‘i DEM. The facility will be a “public use” as defined by HCC § 25-1-5, as a use conducted by or a structure or building owned or managed by the federal government, the State of Hawai‘i or the County to fulfill a governmental function, activity or service for public benefit and in accordance with public policy.
HCC § 25-2-71 (c)(1) states: Plan approval shall be required in all applicable districts prior to the
construction or establishment of public uses, structures and buildings and community buildings,
as permitted under section 25-4-11.
HCC § 25-4-11(c) states: Public uses, structures and buildings and community buildings are
permitted uses in any district, provided that the director has issued plan approval for such use.
6.2.4 County of Hawai‘i Special Management Area
Pursuant to the Hawai‘i CZM Program, HRS Chapter 205A, the counties have enacted ordinances establishing Special Management Areas (SMAs) that are in close proximity to the shoreline. Any
“development” within the SMA requires an SMA Use permit administered by the County of Hawai‘i Planning Department. Through the SMA permit system, the County assesses and regulates developments proposed for areas located within the SMA. The Pāhala LCC Replacement Project
is located within the Pāhala community which lies about 3.8 miles from the shoreline area and is
not located within an SMA. As such, the project will not be subject to requirements of an SMA use permit.
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7 PUBLIC PARTICIPATION
7.1 Community Outreach Program
A community outreach program was conducted to exchange information about the Pāhala Large Capacity Cesspool (LCC) Replacement Project and to work with affected residents and the general community on how to implement the project on both personal and community levels.
These talk story sessions are designed to optimize community conversations in informal and comfortable sessions. The first round of community outreach on the current effort to implement
the Pāhala LCC Replacement Project included five sessions as follows:
1. Tuesday, December 12, 2017 at 6:00 p.m. – Ka‘ū Gym Multi-Purpose Conference Room
2. Wednesday, December 13, 2017 at 10:00 a.m. – Pāhala Community Center
3. Wednesday, December 13, 2017 at 6:00 p.m. – Pāhala Community Center
4. Thursday, December 14, 2017 at 10:00 a.m. – Ka‘ū Gym Multi-Purpose Conference Room
5. Thursday, December 14, 2017 at 6:00 p.m. – Pāhala Community Center
The target outcomes for the first round of engagement were the following:
• Assure residents the project team was there to listen. In these talk story sessions, the
project team emphasized the need to listen to understand the community and how to
continue conversations. Further, the project team stressed in each session that these
community outreach discussions are taking place very early in the planning and
implementation process. Hence, it was stressed that, while there may be limited
information at this time, the team was there to listen and convey questions and comments
to Department of Environmental Management (DEM). That way, in the next round of
meetings, DEM will be able to provide more information to address community concerns.
• Help residents understand what is being proposed. It was important to present project
information in ways that are simple, accurate, relevant and conducive to continuing
dialogue.
• Establish a point of departure to move towards future actions and solutions. Pāhala
residents have had different experiences with wastewater disposal over the years. For
some, they transitioned from a plantation-operated system to a County-run operation. For
others, they installed their own systems. The talk story sessions were intended to clearly
differentiate between previous efforts and the current proposed project.
• Comply with U.S. Environmental Protection Agency (EPA) deadline of December 15,
2017, to hold initial public meeting. DEM and EPA established a schedule for
completion of key milestones. The talk story sessions comprised several initial public
meetings and were organized to comply with this schedule. The approach was intended
to initiate a process that engages all Pāhala residents, while recognizing that the project
will affect some people directly during construction and operation of the new collection
system and new wastewater treatment and disposal facility.
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February 2020 Page 7-2
Invitations and announcements for the talk story sessions were intended to reach all audiences, as follows:
• Property owners with C. Brewer lines on their property were mailed letters from DEM
inviting them to these sessions. The letters included stamped, mail-in postcards to
facilitate the RSVP process.
• Fliers were hand-delivered to “newly-accessible properties.”
• Organizational leaders were provided copies of fliers announcing meetings and asked to
circulate among their members.
• Fliers were posted in public venues, such as the post office, the Pāhala Community Center
and the Ka‘ū Hospital.
• Several online announcements were included in Ka‘ū News Briefs available at
http://haunewsbriefs.blogspot.com/.
The format for each meeting was as follows:
1. Introductions and Pāhala relationship: Participants were asked to introduce
themselves and describe their relationship to Pāhala. They were encouraged to talk about generational presence, length of residence, schools and so on.
2. Life in Pāhala: Participants were asked to discuss:
• What they valued most about Pāhala;
• Pāhala’s biggest challenges; and
• Their ideas and vision for the future of Pāhala.
3. Experience with the existing sewer system: Participants were asked to share their recollections and experience with wastewater disposal in Pāhala. They were also asked
to share what they knew about the proposed project.
4. The proposed project: Project background and overview were presented in a slide presentation.
5. Questions and comments: Project representatives encouraged participants to ask questions and voice their reactions.
6. What one message do you want DEM to hear? Each participant was asked to share
“one thing” that they wanted to share with the County.
This first round of community outreach met the following objectives:
• Residents understood the project team was there to listen. Participants responded
enthusiastically to questions about Pāhala, and openly discussed previous experience
with wastewater disposal in their town and concerns and views about the proposed
project. When the project team could not respond to questions, participants were assured
that their comments were noted and there will be follow up.
• Those who attended appeared to have acquired at least a rudimentary understanding
about how the new collection, treatment, and disposal system would work. They were able
to ask questions about transmission of wastewater to the treatment and disposal facility,
and how the lagoons and land disposal system would work. Participants indicated they
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February 2020 Page 7-3
knew that this system is different from wastewater disposal systems they may have
previously experienced.
• Participants were able to discuss their understanding, or lack thereof, of the wastewater
system and their own personal situation. By the end of each session, they expressed
understanding that the proposed project is a departure from previous discussions and
current operations.
• The milestone date for an initial community meeting (December 15, 2017) was met.
Online and paper versions of the Ka‘ū News Briefs and the Ka‘ū News Calendar reported on these meetings.
The proposed project was modified in response to the community input received and was described in the Draft Environmental Assessment (EA). A second round of meetings with the community was conducted in concert with the Draft EA public review and comment period (see
Section 7.2 below).
Based on the first round of community outreach, the following community outreach activities have been conducted to continue to engage constructive and meaningful community input.
• Information Follow-up. Project representatives made a commitment to follow up on
topics raised in the first round of community outreach. The following lists how topics were
addressed in the Draft EA or other forms of communication.
o Site selection process. Several participants asked why the tentative site was selected
and suggested other sites. It is recommended that a summary table of previously
considered sites and selection rationale, as well a related map, be presented. See
Section 2 for site selection discussion.
o Flooding at tentative site. Participants claimed that this site is prone to flooding. If possible, there should be some response. See Section 3.9 for further discussion.
o Cost range and homeowner assistance possibilities. Property owner participants had
many questions about how project implementation would affect them financially and
personally. In response, the DEM convened separate meetings in October 2018 with
property owners of 1) former C. Brewer properties with sewer lines that will connect to
the proposed collection system and 2) “Newly accessible” properties that front roadways in which new sewer lines will be located. Hawai‘i County Code (HCC)
Chapter 21, Sewers, Section 21-5 requires that when new sewer lines are placed in
public roadways, properties fronting such roadways must connect to these lines. An
additional meeting was held by DEM in March 2019 to discuss funding programs
available to owners of newly accessible parcels.
o Clarification on sewer fee structure. There was often confusion about who pays what and why. Information on the fee structure should be presented clearly.
o Short-and long-term impact on macadamia nut cultivation. It is recommended by the
participants that a preliminary order of magnitude cost of project impact be estimated
and presented in terms of the overall macadamia nut cultivation operation in Pāhala. Further, the project team should describe, in general terms, the possible lease arrangements with the future macadamia nut operator.
o Conceptual plan of full buildout. Participants were concerned that the tentative site is
not large enough to support serving all Pāhala, while still maintaining visual buffers. It
is recommended that a very preliminary schematic be presented that shows full
Final EA, Pāhala LCC Replacement Project
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February 2020 Page 7-4
buildout. As discussed in Section 4.1, the Ka‘ū Community Development Plan calls for
expansion to accommodate future needs but does not present a timeline for this
expansion. As of this writing, 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 was therefore excluded from the analysis of cumulative improvements and impacts.
• Other topics raised in the first round of community outreach tended to be related to details
that will be determined as the project nears implementation. These topics are as follows,
and information will be shared with the community when it becomes available.
o Conditions of existing pipes. Participants raised questions about what was on their property and possible problems. It is recommended that information on previous
County evaluation and potential future assessments be made available prior to or
during construction.
o Possible land application trees. Some information has already been provided, and
status of selecting trees should be provided.
o Fencing around perimeter of wastewater treatment and disposal facility. Options for fence location, height, and materials should be provided.
o Tour of Honokaa wastewater treatment plant. Residents showed interest in
attending a tour of the Honokaa plant with DEM and the project team.
• Next Round of Meetings. The next round of community meetings was conducted upon
publication of the Draft EA (see below):
o Information meeting on the Draft EA. The community had two opportunities to provide comments on this Draft EA. First, public notification was posted in local media, public venues, and mailed to property owners directly affected by the
Proposed Action. These notifications included information on how the public could
access the Draft EA on the Office of Environmental Quality Control (OEQC)
website and submit comments. Second, DEM convened a voluntary and optional
informational meeting.
o Meeting with property owners who will be directly affected by the proposed project.
As noted earlier, DEM convened separate meetings with property owners of 1)
former C. Brewer properties with sewer lines that will connect to the proposed
collection system and 2) “newly accessible” properties that front roadways in which
new sewer lines will be located. The purpose of these meetings was to discuss
how the proposed project will affect individual property owners in terms of cost, financing and logistics, such as construction timing and activities.
7.2 Outreach Since the Publication of the Draft EA
On September 10, 2018, letters containing information on the availability of the Draft EA, the comment period, and the October 10, 2018 public information meeting were mailed to all property
owners on record adjacent to the proposed collection system. This direct mailout included an invitation from DEM to workshops conducted prior to the October 10 public information meeting. The workshop for owners served by C. Brewer lines was held on October 8, and the mailout for this meeting also included anyone with a current sewer account. The workshop for owners of newly accessible properties was convened on October 9. In addition to the direct mailout, online
announcements for the October 8 and 9 workshops were available on the Ka‘ū News Briefs
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February 2020 Page 7-5
website. Fliers were posted in public venues such as the community shopping center, realtor
office, grocery store, library, and the Pāhala Community Center.
On September 26, 2018, a public notice was published in both the Hawaii Tribune Herald and West Hawaii Today to advertise the October 10, 2018 public information meeting conducted by
the County in Pāhala at the Ka‘ū Gym Multi-Purpose Conference Room to discuss the availability
of the Draft EA and process for submitting comments. A public notice was also published in the
October 1, 2018 online and print editions of the Ka‘ū Calendar and made available on the Ka‘ū News Briefs web site http://kaunewsbriefs.blogspot.com.
All materials circulated, posted and published for the October 2018 meetings included the electronic link to the Draft EA at http://health.hawaii.gov/oeqc/. The Draft EA was made available online on the County of Hawai‛i and EPA websites and in public libraries in Nāʻālehu and Pāhala beginning on September 23, 2018. Upon public request, 11 printed copies of the Draft EA were made available at both the Nāʻālehu and Pāhala libraries on November 7, 2018. The County’s transmittal requested the library make the copies available for checkout. The Draft EA was also
posted on the County of Hawaii and EPA websites at:
• http://records.co.hawaii.hi.us/weblink/1/edoc/96064/Pahala%20FINAL%20DRAFT%20E
A%20and%20Appendices_508_9-11-18.pdf
• https://www.epa.gov/uic/proposed-pahala-community-large-capacity-cesspool-
replacement-project-draft-environmental
The County provided staff at the October 10, 2018, public information meeting to personally assist commenters in preparing written comments on the Draft EA. In addition, during this meeting, the
County identified community volunteers attending the meeting who were proficient in Hawaiian, Tagalog, and English to assist anyone who identified as needing assistance in providing written comments on the Draft EA.
The public notice also stated that a second part of the meeting on October 10, 2018 would address Section 106 of the National Historic Preservation Act (NHPA) involving consultation with Native Hawaiian Organizations and Native Hawaiian descendants with ancestral lineal or cultural ties to, cultural knowledge or concerns for, or cultural religious attachment to the proposed project area. Eight persons placed their names on a sign-in sheet to contribute during the Section 106 part of
the meeting; however, no comments or information from the public were forthcoming during this meeting.
On October 26, 2018, letters were mailed to property owners on record adjacent to the proposed collection system informing them of the republished Draft EA and extension of the public comment period to December 10, 2018. Further, on November 8, 2019, the OEQC The Environmental
Notice noted the republication of the Draft EA.
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The County voluntarily convened an additional public meeting in Pāhala on March 21, 2019. The purpose of this meeting was to gain further input from newly accessible property owners and to
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. At the meeting, DEM provided the preliminary results of the County investigation into
funding sources and options available for newly accessible property owners once the new collection system and wastewater treatment and disposal facility have been designed, permitted and constructed. 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 Hawai‘i Revised Statues (HRS) Chapter 342D to establish a low-interest
loan program offering financial assistance to cesspool owners to connect to wastewater treatment systems approved by the Department of Health (DOH), was also discussed; however, this bill was subsequently not passed during the 2019 legislative session.
7.3 Response to Comments and Revisions to the Draft EA
The Draft EA was released for public comment on September 23, 2018. Initially, a 30-day public comment period was planned; however, due to requests from the public for additional time, EPA
and the County of Hawaiʻi agreed to republish the Draft EA on November 8, 2018 which extended the comment period. The comment period closed on December 10, 2018. Appendix E includes the EPA and County responses to comments received on the Draft EA on or before that date. In
total, 77 comment letters were received, some of which included multiple individual or duplicate comments.
No substantial changes to the Proposed Action were necessary as a result of comments on the
Draft EA. However, in response to comments received, the Final EA incorporates revisions to provide clarity through minor text changes and to provide additional information where necessary. Please refer to Appendix E for additional information. Additionally, the Final EA incorporates
revisions to reflect minor changes to the scope of the Proposed Action (e.g., the use of ultraviolet instead of chlorine disinfection); to reflect the outcomes of consultations with state and federal agencies (e.g., Section 106 of the NHPA, Section 7 of the Endangered Species Act); and to provide additional clarifications and supporting statements beyond those specifically in response to comments. These revisions do not change any of the key findings presented in the Draft EA.
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8 FINDINGS AND DETERMINATION
8.1 Chapter 343, Hawaiʻi Revised Statutes (HRS) – Department of Environmental
Management (DEM) Finding of No Significant Impact (FONSI)
Short-term construction impacts include disruption to the project site and surrounding areas during construction, decline in air quality from construction activities, and increase in noise levels.
Once construction has been completed, the short-term adverse impacts will no longer occur.
Based on analysis of the impacts, the County has determined a Finding of No Significant Impact (FONSI) for the Pāhala Large Capacity Cesspool (LCC) Replacement Project. The significance
criteria to make this determination are set forth below and in Hawaiʻi Administrative Rules 11-200 (Environmental Impact Statement Rules).
8.1.1 Significance Criteria
1) Involve an irrevocable commitment to loss or destruction of any natural or cultural
resources;
The Pāhala LCC Replacement Project collection system and wastewater treatment and disposal
facility sites do not provide habitat for federal or State of Hawaiʻi listed or candidate threatened or endangered species of flora or fauna. The collection system will be constructed primarily within areas that were disturbed during construction of the existing County streets, plus three short segments within easements in the Pāhala community. The treatment and disposal facility site has previously been cleared, graded, and planted with a macadamia nut orchard. Thus, the proposed use of the Pāhala LCC Replacement Project sites will not result in the loss or destruction of natural resources.
Preliminary analysis shows the treatment and disposal facility will be constructed in an area that is unlikely to contain archaeological resources due to historical ground modifications. However, an Archaeological Inventory Survey (AIS), including subsurface testing, was conducted to test for the presence of archaeological resources on the project site. In March 2019, following completion
of the AIS, and in accordance with Section 106 of the National Historic Preservation Act (NHPA), the County submitted the AIS for review by the Hawaiʻi State Historic Preservation Division (SHPD) to determine whether additional mitigation measures are appropriate to avoid or minimize
adverse effects to archaeological resources.
The contract drawings will state that, should archaeological sites such as walls, platforms, pavements or mounds, or remains such as artifacts, burials, or 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 Hawaiʻi SHPD (at 808.981.2979), who will assess the significance of the find and recommend appropriate mitigation
measures, if necessary.
Based on the above, and the findings of the AIS, construction of the wastewater treatment and disposal facility and related improvements is determined to have no effect on historic properties.
2) Curtail the range of beneficial uses of the environment;
The Pāhala LCC Replacement Project sites will use lands within the Pāhala community that have been used for County streets and planted with a macadamia nut orchard for a number of years. The treatment and disposal facility will occupy a total area of 14.9 acres within a portion the macadamia nut orchard. The remainder of the orchard will still be available for the production of
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February 2020 Page 8-2
macadamia nuts. Thus, the Pāhala LCC Replacement Project will not curtail the beneficial uses of the environment.
3) Conflict with the State's long-term environmental policies or goals as expressed in Chapter
344, HRS, and any revisions thereof and amendments thereto, court decisions, or executive
orders;
The Pāhala LCC Replacement Project will not involve actions or activities that would adversely affect natural resources of the project sites. The Pāhala LCC Replacement Project will be consistent with the guidelines of Hawaiʻi Revised Statutes (HRS) 344, as it will provide treatment
and disposal for wastewater from the Pāhala community. Moreover, the Pāhala LCC Replacement Project will construct a wastewater collection system according to County standards
and a treatment and disposal facility according to DOH guidelines. Lastly, the Pāhala LCC Replacement Project will allow closure of LCCs that have been used to dispose untreated sewage
into the subsurface. As such, the Pāhala LCC Replacement Project will not conflict with the state's long-term environmental policies or goals as expressed in HRS 344.
4) Substantially affect the economic or social welfare of the community or state;
The Pāhala LCC Replacement Project will allow the County to provide wastewater collection, treatment and disposal facilities meeting the needs of the Pāhala community. It will be an integral part of the infrastructure needed to maintain the health and welfare of the Pāhala community.
Therefore, the Pāhala LCC Replacement Project will have a beneficial impact on the economic and social welfare of the community.
5) Substantially affect public health;
Pāhala LCC Replacement Project will involve the design, construction and operation of wastewater collection, treatment and disposal facilities that will maintain and enhance the public
health of the Pāhala community. Thus, the Pāhala LCC Replacement Project will have a beneficial effect on public health.
6) Involve substantial secondary impacts, such as population changes or effects on public
facilities;
The Pāhala LCC Replacement Project will be a public facility serving the Pāhala community. For
the most part, construction of the Pāhala LCC Replacement Project is expected to involve the use of local contractors, which means that there will not be an extensive secondary effect on the population of the Island of Hawai‘i or the Pāhala community. Thus, construction of the Pāhala
LCC Replacement Project will not create secondary impacts, such as population changes or effects on public facilities.
7) Involve a substantial degradation of environmental quality;
The Pāhala LCC Replacement Project is anticipated to result in short-term impacts to noise, air quality, and traffic in the immediate vicinity of the project site during the period of construction. The collection system and the treatment and disposal facility sites do not contain federal or state-listed or candidate threatened or endangered species of flora or fauna. As discussed under Criterion #1, the project is determined to have no effect on historic properties, in accordance with the outcome of the NHPA Section 106 consultation and findings of the AIS.
Based on the above findings, the Pāhala LCC Replacement Project will not result in a substantial degradation of environmental quality.
8) Have a cumulative effect upon the environment or involves a commitment for larger
actions;
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The Pāhala LCC Replacement Project does not involve a commitment to further actions to other County of Hawai‘i related projects in the vicinity. As a result, the Pāhala LCC Replacement Project
will not have a cumulative effect upon the environment or involve a commitment by the County to larger actions.
9) Affect a rare, threatened or endangered species;
The Pāhala LCC Replacement Project sites do not contain federal or state-listed or candidate threatened or endangered species of flora. Also, the Pāhala LCC Replacement Project sites do not provide habitat for federal or state-listed or candidate threatened or endangered species of
fauna. On February 15, 2019, the U.S. Fish and Wildlife Service (FWS) provided a letter that concluded that FWS has analyzed potential impacts to listed species due to the implementation of Pāhala LCC Replacement Project. Based on the inclusion of the avoidance and minimization measures, FWS stated that any potential impacts will be discountable or insignificant and therefore concurred 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. The Pāhala LCC Replacement Project 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.
10) Detrimentally affect air or water quality or ambient noise levels;
Operation of construction equipment will increase noise and exhaust emission levels in the
immediate vicinity of the Pāhala LCC Replacement Project sites during the construction period.
Once construction has been completed, the Pāhala LCC Replacement Project will contribute almost no additional noise or air emissions to the local area or detrimentally affect air or water
quality. The treatment and disposal facility will include an odor control system to limit odors typically associated with a wastewater treatment facility.
11) Affects or likely to suffer damage by being located in an environmentally sensitive area
such as a floodplain, tsunami zone, beach, erosion-prone area, geographically hazardous land,
estuary, fresh water or coastal water;
The Flood Insurance Rate Map (FIRM), Community Panel No. 155166 1800F, effective date
September 29, 2017 shows the Pāhala area is located in Zone X, area of minimal flood hazard above the 500-year flood level. This was confirmed by the County of Hawai‘i Department of Public Works. A small portion of the collection system site is located within the Zone X defined as areas of 0.2-percent annual chance flood; areas of 1-percent annual chance flood with average depths of less than 1 foot.
The Pāhala LCC Replacement Project sites are not located within the tsunami evacuation zone. The sites are also outside of the County of Hawai‘i Special Management Area and coastal shoreline area. Thus, the Pāhala LCC Replacement Project sites are not located in an environmentally sensitive area.
12) Substantially affect scenic vistas and viewplanes identified in county or state plans or
studies;
The wastewater collection system will be within the County roadways beneath the surface of the
travelways. Thus, the collection system will not affect viewplanes in the Pāhala area.
The treatment and disposal facility will consist of an operations building, headworks with a cover
structure, aerated lagoons, subsurface constructed wetlands, UV disinfection system with a cover
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Pāhala, Ka‘ū District, Hawai‘i
February 2020 Page 8-4
structure, and a series of slow-rate land application basins with planted trees. The operations building, headworks cover structure, UV disinfection system cover structure, and low berms
around the basins will be the only above-grade structures. The existing Cook pine trees along Maile Street, most of which will remain with no changes, will continue to obstruct the viewplanes from Maile Street. The facility site will be adjacent (mauka) to, and visible from, Māmalahoa
Highway (State Route 11); however, impacts to the viewplane will be mitigated by the planted trees in the basins and by the rise in elevation between the highway and the facility. Thus, development of the Pāhala LCC Replacement Project sites will not present an adverse impact to
the public views from other areas.
13) Require substantial energy consumption.
The Pāhala LCC Replacement Project is a new facility that will be planned and designed to minimize use of electrical power. Thus, it will not create a substantial increase in energy consumption.
8.1.2 Determination
Based on these findings and the assessment of potential impacts from the Pāhala LCC Replacement Project, the project does not require preparation of an Environmental Impact Statement and a FONSI is determined.
8.2 National Environmental Policy Act – EPA Finding of No Significant Impact
(FONSI)
In 2006, a U.S. Environmental Protection Agency (EPA) Special Appropriations Act Project (SAAP) grant was awarded to the County of Hawaiʻi for the Ka‘ū LCC Replacement Project (XP-
96942401). The grant’s federal funding amount is $1.842 million and currently expires in October 2020. The purpose of the award is for the design and construction of wastewater system
improvements to replace LCCs in the Ka‘ū District. The grant award and current work plan provide funding to replace the LCCs serving the Pāhala community.
EPA’s award of a grant for the Pāhala LCC Replacement Project is a federal action requiring
compliance with the National Environmental Policy Act (NEPA), 42 U.S.C. §§ 4321-4347. In accordance with NEPA, Council on Environmental Quality (CEQ) Regulations at 40 Code of Federal Regulations (CFR) §§ 1500-1508, and EPA NEPA regulations at 40 CFR Part 6, EPA
and the County prepared a Draft EA describing the potential environmental impacts associated with, and the alternatives to, the proposed project. The Draft EA included a preliminary FONSI in Section 8.2 that documented EPA’s finding that the proposed project is not expected to have a significant effect on the environment. In accordance with 40 CFR 6.203(b)(1), the preliminary FONSI was made available for public review and comment through the Draft EA comment period. The Final FONSI has been prepared separately from the Final EA and will be available on EPA’s website and through public notice.
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9 LIST OF PERMITS AND APPROVALS
State of Hawaiʻi Department of Health
Approval to Construct
Approval to Use
National Pollutant Discharge Elimination System Construction Stormwater Permit
Underground Injection Well Abandonment
Noise Permit
Noise Variance (only if required)
County of Hawaiʻi
Special Permit
Plan Approval
Grading Permit
Building Permit
Electrical Permit
Plumbing Permits
Fence Permit
Sign Permit (only if required)
Permit to Work Within County Right-of-Way
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10 CONSULTED PARTIES
10.1 Pre-Assessment Consultation
In accordance with the requirements of Hawai'i Administrative Rules Title 11 (State of Hawai'i Department of Health), Chapter 200 (Environmental Impact Statement Rules), Section 9 regarding early consultation, the following agencies were consulted during the pre-assessment
phase of the Draft Environmental Assessment (EA). Each agency was sent a copy of a project summary and a request for their written comments on the project. Those who formally replied
are indicated with a ▲. All written comments and responses are reproduced in Appendix A.
Federal
▲U.S. Army Corps of Engineers
▲U.S. Fish and Wildlife Service (FWS)
U.S. Department of Agriculture National Resources Conservation Service
National Oceanic and Atmospheric Administration
National Park Service Hawaiʻi Volcanoes National Park
State of Hawaiʻi
Department of Agriculture
Department of Business, Economic Development and Tourism (DBEDT)
DBEDT, Hawaiʻi State Energy Office
DBEDT, Land Use Commission
▲DBEDT, Office of Planning
▲Department of Accounting and General Services
Hawaiʻi Emergency Management Agency
Department of Health (DOH)
DOH, Office of Environmental Quality Control
DOH, Office of Director
DOH, Environmental Management Division
▲DOH, Environmental Planning Office
▲DOH, Clean Water Branch
▲DOH, Safe Drinking Water Branch
▲DOH, Wastewater Branch
▲Department of Land and Natural Resources (DLNR)
▲DLNR, Engineering Division
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▲DLNR, Division of Forestry and Wildlife
DLNR, State Historic Preservation Division
DLNR, Commission on Water Resources Management
Office of Hawaiian Affairs
▲Department of Transportation
▲Department of Hawaiian Home Lands
University of Hawaiʻi, Environmental Center
Hawaiʻi State Library
Hilo Regional Library
County of Hawaiʻi
▲Hawaiʻi Fire Department
Department of Parks and Recreation
▲Planning Department
▲Police Department
▲Department of Public Works
▲Department of Water Supply
Elected Officials
Congresswoman Tulsi Gabbard
State Senator Russell Ruderman
State Representative Richard H.K. Onishi
Councilmember Maile David
Native Hawaiian Organizations
Hawaiʻi Island Burial Council
Association of Hawaiian Civic Clubs
Charles Pelenui Mahi ʻOhana
Friends of ʻIolani Palace
Hawaiian Civic Club of Hilo
Kamehameha Schools
Kanu o kaʻĀina Learning ʻOhana
Koʻolau Foundation
Makuʻu Farmers Association
Na Koa Ikaika Ka Lāhui Hawaiʻi
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Office of Hawaiian Affairs
Pacific Agricultural Land Management Systems
Partners in Development Foundation
Piʻihonua Hawaiian Homestead Community Association
Other
Hawaiʻi Gas
Hawaiian Electric Light Company
Hawaiian Telcom
Spectrum Hawaiʻi
Mr. Stason Nishimura
Mr. Lance Uno
Ms. Julia Neal
10.2 Agencies and Organizations Consulted on the Draft EA
Availability of the Draft EA for review and comment was published in the Office of Environmental Quality Control Environmental Notice dated September 23, 2018. The U.S. Environmental
Protection Agency (EPA) directly notified the agencies, organizations, and individuals listed in Section 10.1 regarding the availability of the Draft EA for review and comment. Legal notice was posted in the Hawaiʻi Tribune Herald, West Hawaiʻi Today, and Ka‘ū News Brief. Additionally,
EPA concluded consultation with the Hawai‘i State Historic Preservation Division in accordance with Section 106 of the National Historic Preservation Act, and with the FWS in accordance with Section 7 of the Endangered Species Act.
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11 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. Kuamo‘o, R. T. Nishimoto, S. Hau, J. M. Fitzsimons, D. A. Polhemus, and W. S. Devick.
2008.
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 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.
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.
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State of Hawai‘i. Department of Agriculture. 2012 Census of Agriculture – County Data 2012.
State of Hawai‘i. Department of Health. Annual Summary 2015 Air Quality Data. December
2016.
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, 2012-2016 American Community Survey. U.S. Census Bureau’s American Community Survey Office, 2017. Web. August 1, 2018.
U.S. Department of Agriculture Soil Conservation Service. Ka‘ū River Basin Study, County of Hawai‘i. February 1994.
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.
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.
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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.
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ENVIRONMENTAL ASSESSMENT
for the
Pāhala Large Capacity Cesspool (LCC)
Replacement Project
EPA Grant XP-96942401
VOLUME 2: APPENDICES
Pāhala, District of Ka‘u, County of Hawai‘i, Hawai‘i
TMK: 9-6-002:018
U.S. Environmental Protection Agency
Region 9
75 Hawthorne Street
San Francisco, California 94105
County of Hawai‘i
25 Aupuni Street
Hilo, HI 96720
FINAL
February 2020
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February 2020
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Appendix A
Responses to Pre-Assessment Consultation Letters
February 2020
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Appendix B
November 2019 Preliminary Engineering Report (PER)
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Pahala Wastewater
Treatment Plant
Preliminary Engineering
Report
Prepared for
County of Hawaii, Department of Environmental Management
June 2018
November 2019
Pahala Wastewater Treatment Plant
Preliminary Engineering Report
Prepared for
County of Hawaii, Department of Environmental Management
June 2018
November 2019
THIS WORK WAS PREPARED BY ME OR UNDER MY SUPERVISION.
April 30, 2020
Signature Expiration Date of the License
2261 Aupuni Street, Suite 201
Wailuku, Hawaii 96793
iii
Table of Contents
List of Figures ........................................................................................................................................ vi
List of Tables .........................................................................................................................................vii
List of Abbreviations ...............................................................................................................................ix
1. Introduction .................................................................................................................................. 1-1
1.1 Background ........................................................................................................................ 1-1
1.2 Existing System .................................................................................................................. 1-1
1.3 Report Contents ................................................................................................................. 1-1
2. Flow and Load Projections ........................................................................................................... 2-1
2.1 Service Area ....................................................................................................................... 2-1
2.2 Flow Projections ................................................................................................................. 2-3
2.3 Influent Characteristics ...................................................................................................... 2-3
2.4 Influent Mass Loads .......................................................................................................... 2-3
2.5 Mass Loads to the Environment via Existing LCCs ............................................................ 2-4
3. Effluent Management Options and Regulatory Requirements .................................................... 3-1
3.1 Effluent Management Options ........................................................................................... 3-1
3.1.1 Ocean Discharge .................................................................................................. 3-1
3.1.2 Subsurface Disposal via Injection Wells .............................................................. 3-1
3.1.3 Water Recycling .................................................................................................... 3-2
3.1.4 Land Treatment .................................................................................................... 3-2
3.1.5 Drain Field ............................................................................................................ 3-3
3.1.6 Recommendation ................................................................................................. 3-3
3.2 Treatment Requirements ................................................................................................... 3-3
4. Wastewater Treatment Evaluations ............................................................................................. 4-1
4.1 Preliminary Treatment ....................................................................................................... 4-1
4.1.1 Screening ............................................................................................................. 4-1
4.1.2 Influent Flow Measurement ................................................................................. 4-2
4.1.3 Influent Flow Sampling ......................................................................................... 4-2
4.1.4 Preliminary Design of Headworks ........................................................................ 4-2
4.1.5 Odor Control ......................................................................................................... 4-4
4.2 Aerated Lagoon Treatment System ................................................................................... 4-5
4.2.1 Aerated Lagoon Kinetics ...................................................................................... 4-5
4.2.2 Aeration in Lagoon Systems ................................................................................. 4-5
4.2.3 Aerated Lagoon Configuration ............................................................................. 4-7
4.2.4 Lagoon Liner ........................................................................................................ 4-8
4.2.5 Lagoon Cover ....................................................................................................... 4-9
4.2.6 Lagoon Sludge Management ............................................................................ 4-11
Pahala Wastewater Treatment Plant Preliminary Engineering Report Table of Contents
iv
4.3 Subsurface Flow Constructed Wetland ........................................................................... 4-11
4.3.1 Denitrification in Subsurface Flow Constructed Wetlands ................................ 4-11
4.4 Disinfection ..................................................................................................................... 4-12
4.4.1 Calcium Hypochlorite ........................................................................................ 4-12
4.4.2 Ultraviolet Light (UV) Disinfection ...................................................................... 4-16
4.4.3 UV System Design Summary ............................................................................. 4-16
4.4.4 Cost Evaluation ................................................................................................. 4-17
4.4.5 Disinfection Recommendation .......................................................................... 4-17
4.5 Effluent Management ..................................................................................................... 4-18
4.5.1 Design ............................................................................................................... 4-18
4.6 Ancillary Systems ............................................................................................................ 4-20
4.6.1 Water ................................................................................................................. 4-20
4.6.2 Access Road ...................................................................................................... 4-20
4.6.3 Stormwater Management ................................................................................. 4-21
4.6.4 Pre-development Stormwater Conditions ......................................................... 4-21
4.6.5 Electrical Systems ............................................................................................. 4-26
4.6.6 Telemetry Systems ............................................................................................ 4-26
4.6.7 Operations Building ........................................................................................... 4-26
4.6.8 Site Fencing....................................................................................................... 4-26
4.6.9 Alternative Energy ............................................................................................. 4-26
5. Preliminary Design of Improvements ........................................................................................... 5-1
5.1 Site Plan ............................................................................................................................. 5-1
5.2 Process Schematic ............................................................................................................ 5-1
5.3 Design Criteria ................................................................................................................... 5-4
5.4 Environmental Benefits ..................................................................................................... 5-6
5.5 Cost Estimates ................................................................................................................... 5-8
5.6 Future Expansion ............................................................................................................... 5-8
5.6.1 Full Buildout Flows ............................................................................................... 5-8
5.6.2 Improvements ...................................................................................................... 5-8
6. Implementation ............................................................................................................................ 6-1
7. Alternative Treatment Options Evaluation ................................................................................... 7-1
7.1 Option Descriptions ........................................................................................................... 7-1
7.1.1 Option 1: Aerated Lagoons/Constructed Wetland/Land Application .................. 7-1
7.1.2 Option 2: R-1 Treatment/Land Application .......................................................... 7-1
7.1.3 Option 3: R-1 Treatment/Seasonal Water Recycling .......................................... 7-2
7.1.4 Option 4: R-1 Treatment and Storage for 100% Water Recycling ....................... 7-4
7.1.5 Option 5: Maximum Practical Treatment ............................................................ 7-6
7.2 Cost Comparisons .............................................................................................................. 7-7
7.2.1 Capital Costs ........................................................................................................ 7-7
7.2.2 Operation and Maintenance Costs ...................................................................... 7-7
Pahala Wastewater Treatment Plant Preliminary Engineering Report Table of Contents
v
7.2.3 Recycled Water Sale Proceeds ............................................................................ 7-8
7.2.4 Life-Cycle Costs .................................................................................................... 7-8
7.3 Non-Economic Discussion ................................................................................................. 7-9
7.3.1 Labor Requirements ......................................................................................... 7-10
7.3.2 Operational Complexity ..................................................................................... 7-10
7.3.3 Energy Consumption ......................................................................................... 7-11
7.3.4 Sludge Management ......................................................................................... 7-11
7.4 Living Machine® ............................................................................................................. 7-11
7.5 Septic Tank Alternatives ................................................................................................. 7-12
7.5.1 Community Septic Tank .................................................................................... 7-12
7.5.2 Converting LCC to Seepage Pit.......................................................................... 7-12
7.5.3 Leachfield Disposal ........................................................................................... 7-13
7.5.4 Conversion to Individual Wastewater Systems ................................................. 7-13
7.5.5 Gray Water Systems/Composting Toilets ......................................................... 7-14
7.6 Package Plant ................................................................................................................. 7-14
8. Alternative Site Evaluation ........................................................................................................... 8-1
8.1 Methodology ...................................................................................................................... 8-1
8.2 Site Locations .................................................................................................................... 8-1
8.3 Criteria ............................................................................................................................... 8-3
8.4 Criteria Weighting Factors .................................................................................................. 8-7
8.5 Raw Scores ........................................................................................................................ 8-8
8.6 Weighted Analysis .............................................................................................................. 8-9
8.7 Results ............................................................................................................................ 8-10
8.8 Conclusion ...................................................................................................................... 8-10
9. References ................................................................................................................................... 9-1
Cost Estimates ................................................................................................................. A-1
Collection System Plan ....................................................................................................B-1
Wastewater Flow Calculations ......................................................................................... C-1
Pahala Wastewater Treatment Plant Preliminary Engineering Report Table of Contents
vi
List of Figures
Figure 1-1. Pahala Existing Sewer Collection System and LCC Service Area ..................................... 1-2
Figure 2-1. Pahala WWTP Service Area .............................................................................................. 2-2
Figure 3-1. Irrigation Demand Assessment ........................................................................................ 3-2
Figure 4-1. In-Channel Cylindrical Screen .......................................................................................... 4-2
Figure 4-2. Headworks ....................................................................................................................... 4-3
Figure 4-3. Activated Carbon Scrubber (GAC) .................................................................................... 4-4
Figure 4-4. High Speed Floating Aerator ............................................................................................ 4-7
Figure 4-5. Normal Lagoon Configuration Schematic ........................................................................ 4-7
Figure 4-6. Floating HDPE Shade Balls ........................................................................................... 4-10
Figure 4-7. Floating shade balls with current and turbulence in reservoir. ..................................... 4-10
Figure 4-8. Subsurface Flow Constructed Wetland Concept ........................................................... 4-11
Figure 4-9. Typical Calcium Hypochlorite Feed System ................................................................... 4-13
Figure 4-10. Chlorine Contact Tank Configuration .......................................................................... 4-15
Figure 4-11. Land Application System Schematic ........................................................................... 4-19
Figure 4-12. Existing Drainage System ........................................................................................... 4-22
Figure 4-13. Flood Insurance Rate Map .......................................................................................... 4-24
Figure 4-14. Operations Building Preliminary Floor Plan ................................................................ 4-28
Figure 5-1. Preliminary Site Plan ........................................................................................................ 5-2
Figure 5-2. Recommended Facility Process Schematic ..................................................................... 5-3
Figure 5-3. Environmental Benefits of Proposed Project ................................................................... 5-7
Figure 7-1. Option 1 Schematic Diagram ........................................................................................... 7-1
Figure 7-2. Option 2 Schematic Diagram ........................................................................................... 7-2
Figure 7-3. Option 3 Schematic Diagram ........................................................................................... 7-2
Figure 7-4. Irrigation Demand Assessment ........................................................................................ 7-3
Figure 7-5. Option 3 Recycled Water Demand Assessment ............................................................... 7-3
Figure 7-6. Comparison of Irrigation Demands at Pahala and Kealakehe ......................................... 7-4
Figure 7-7. Option 4 Schematic Diagram ........................................................................................... 7-5
Figure 7-8. Seasonal Storage Reservoir Analysis ............................................................................... 7-6
Figure 7-9. Option 5 Schematic Diagram ........................................................................................... 7-7
Figure 7-10. Life-Cycle Costs of Options............................................................................................. 7-9
Figure 7-11. Comparison of Electrical Energy Requirements.......................................................... 7-11
Figure 8-1. Pahala Site Alternatives ................................................................................................... 8-2
Pahala Wastewater Treatment Plant Preliminary Engineering Report Table of Contents
vii
List of Tables
Table 2-1. Pahala WWTP Flow Projections ......................................................................................... 2-3
Table 2-2. Summary of Assumed Influent Characteristics ................................................................. 2-3
Table 2-3. Projected Influent Mass Loads .......................................................................................... 2-3
Table 2-4. Mass Loads to the Environment via Existing LCCs ............................................................ 2-4
Table 3-1. Nutrient Water Quality Standards for Class AA Embayments ........................................... 3-1
Table 3-2. Applicable HAR 11-62 Land Disposal Requirements ........................................................ 3-3
Table 4-1. Normal Configuration Aeration and Mixing Requirements ................................................ 4-8
Table 4-2. Lagoon Shade Ball Cover Application Parameters ............................................................ 4-9
Table 4-3. Calcium Hypochlorite Summary ..................................................................................... 4-13
Table 4-4. Chlorine Demand............................................................................................................ 4-14
Table 4-5. Chlorine Contact Tank .................................................................................................... 4-14
Table 4-6. UV Disinfection Design Summary ................................................................................... 4-16
Table 4-7. Estimated Disinfection Costs ......................................................................................... 4-17
Table 4-8. Ultraviolet Disinfection – Advantages and Disadvantages ............................................ 4-17
Table 4-9. Potential Land Application System Tree Species ........................................................... 4-18
Table 4-10. Potential Water Demands ............................................................................................ 4-20
Table 5-1. Preliminary Design Criteria ................................................................................................ 5-4
Table 5-2. Environmental Benefits of Proposed Project..................................................................... 5-7
Table 5-3. Pahala WWTP Order of Magnitude Construction Cost Estimate ....................................... 5-8
Table 5-4. Pahala WWTP Full Buildout Flow Projections .................................................................... 5-8
Table 6-1. Implementation Schedule ................................................................................................. 6-1
Table 7-1. Summary of Capital Cost Estimates .................................................................................. 7-7
Table 7-2. Summary of O&M Cost Estimates ..................................................................................... 7-8
Table 7-3. Summary of Annual Recycled Water Sale Proceeds ......................................................... 7-8
Table 7-4. Summary of Life-Cycle Cost Estimates .............................................................................. 7-9
Table 7-5. Comparison of Operational Labor Requirements ........................................................... 7-10
Table 7-6. Comparison of Operator Certification Requirements per HAR 11-61 ............................ 7-10
Table 8-1. Environmental, Social and Cultural Criteria ...................................................................... 8-3
Table 8-2. Location and Site Characteristics ..................................................................................... 8-4
Table 8-3. Collection System and Service Area Criteria ..................................................................... 8-5
Pahala Wastewater Treatment Plant Preliminary Engineering Report Table of Contents
viii
Table 8-4. Land Use and Availability Criteria ...................................................................................... 8-6
Table 8-5. Relative Weighting Factors ................................................................................................ 8-7
Table 8-6. Alternatives Analysis – Raw Scores ................................................................................... 8-8
Table 8-7. Alternatives Analysis – Weighted Scoring ......................................................................... 8-9
Table 8-8. Alternative Site Ranking ................................................................................................. 8-10
Pahala Wastewater Treatment Plant Preliminary Engineering Report Table of Contents
ix
List of Abbreviations
AB aggregate base
AC asphalt concrete
BMP Best Management Practices
BOD5 5-day biochemical oxygen demand
CCH City and County of Honolulu
cfs cubic feet per second
COH County of Hawaii
CFR Code of Federal Regulations
DNA deoxyribonucleic acid
DEM Department of Environmental Management
DOH Department of Health
ELLF end-of-lamp-life
FIRM Flood Insurance Rate Map
FOG fats, oils, and grease
ft3 cubic feet
FTE full-time equivalent
GAC granular activated carbon
gpm gallons per minute
H2S hydrogen sulfide
HAR Hawaii Administrative Rules
HDPE high density polyethylene
HELCO Hawaii Electric Light Company
hp horsepower
hp/Mgal horsepower per million gallons
hr hour
hp-hr horsepower-hour
L liter
lbs pounds
LCC large capacity cesspools
LPHO low pressure high output
MBR membrane bioreactor
Mg milligrams
Mgal million gallons
mm millimeter
MSL mean sea level
N nitrogen
NPV net present value
O&M Operation and Maintenance
P Phosphorus
Psi pounds per square inch
RNA ribonucleic acid
ROW right-of-way
scfm standard cubic feet
SCS Soil Conservation Service
SR slow rate
TSS total suspended solids
UIC Underground Injection Control
USEPA United States Environmental Protection
Agency
UV ultraviolet
WQV Water Quality Volume
WWTP Wastewater Treatment Plant
1-1
Introduction
1.1 Background
The town of Pahala is located in the Kau district of the Island of Hawaii. According to the 2010
United States Census, the town population is approximately 1,350 persons.
The Pahala community was established as the result of the sugar operations of the C. Brewer
Company. A portion of the community is serviced by a sewer system that was privately built, owned,
and operated by the C. Brewer Company. The wastewater collected by the sewer system discharges
into large capacity “gang” cesspools. Many years after its establishment, the private sewer system
ownership was conveyed to the County of Hawaii (COH) Department of Environmental Management
(DEM).
In 1998, the U.S. Environmental Protection Agency (USEPA), promulgated regulations, 40 Code of
Federal Regulations (CFR) 144.14, that require the elimination of large capacity “gang” cesspools
(LCCs). The County intends to construct a new sewer collection system located within public right-of-
way (ROW) and replace the existing LCCs with a wastewater treatment plant to address the
wastewater treatment and disposal needs of the Pahala community.
This report summarizes a proposed wastewater treatment plant (WWTP) needed in order to treat and
dispose of the wastewater flow that is currently discharged to the LCCs, plus additional sewer
connections. The report presents the existing and estimated future flows and loads to the treatment
plant, the proposed treatment processes, recommendation for the WWTP upgrades needed to meet
the future treatment needs, and an initial opinion of the cost to construct the improvements project.
1.2 Existing System
Figure 1-1 shows the collection system network and service areas for the LCCs. The collection
system is a network of gravity sewers that discharge to two existing LCCs. A detailed analysis of the
existing wastewater collection system was completed by others (M&E Pacific, December 2004). The
report concluded that the Pahala community existing sewer system consists of about 3,000 linear
feet of 6-inch diameter and 10,000 linear feet of 4-inch diameter pipelines. Residential laterals
connect to 4-inch sewers that discharge into 6-inch sewer mains, predominately found in private
property, which transmit wastewater to the LCCs. There are approximately 8 manholes in the sewer
system. There are no pump stations and the system is not designed to collect stormwater.
1.3 Report Contents
Section 2 presents flow and load projections for the new WWTP. Section 3 evaluates effluent
management options, and the treatment requirements for the preferred option. Section 4 presents
evaluations conducted to develop the preliminary design of the proposed WWTP, which is presented
in Section 5. An implementation plan is briefly presented in Section 6, followed by discussion of
other treatment options that were considered and evaluated. The report concludes with a site
selection consideration in Section 8.
Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 1
1-2
INSERT FIGURE
Figure 1-1. Pahala Existing Sewer Collection System and LCC Service Area
2-1
Flow and Load Projections
This section summarizes the flow and load projections for the new WWTP.
2.1 Service Area
Within the town of Pahala, there is an existing wastewater collection that services approximately 109
properties. The collection system is currently located within easements in private properties and is
treated and disposed through two LCCs. Figure 2-1 shows the service area for the new WWTP. The
Kau Community Development plan indicates that the sewer system may eventually be expanded to
service the entire community; however, the initial collection system and WWTP presented in this
report will service the properties currently connected to the LCCs or located adjacent to the new
collection system. Although this report does not include design for the full buildout service area, the
proposed WWTP has been designed to accommodate modifications within the proposed 14.9-acre
site for the anticipated future expansion of the service area.
Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 2
2-2
Figure 2-1. Pahala WWTP Service Area
Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 2
2-3
2.2 Flow Projections
Wastewater flow projections were developed using the City and County of Honolulu’s (CCH) current
(2017) wastewater standards. Table 2-1 summarizes the flow projections.
Table 2-1. Pahala WWTP Flow Projections
Description Value Peaking Factor
Average dry weather flow 189,000 gallons per day 1.0
Peak day wet weather flow 662,000 gallons per day 3.5
Peak hour wet weather flow 630 gallons per minute 4.8
The WWTP will be designed to provide an average dry weather flow capacity of 190,000 gallons per
day.
2.3 Influent Characteristics
The properties within the existing service area are primarily residential, but do include several
commercial, apartment, and industrial zoned parcels. The wastewater characteristics of the WWTP
influent are assumed to be similar to typical domestic wastewater. Table 2-2 provides a summary of
the assumed influent characteristics.
Table 2-2. Summary of Assumed Influent Characteristics
Parameter Value
5-day biochemical oxygen demand (BOD5) 300 mg/L
Total suspended solids (TSS) 300 mg/L
Total nitrogen 40 mg/L
Total phosphorus 7 mg/L
2.4 Influent Mass Loads
Table 2-3 summarizes the projected loads to the WWTP, based on the proposed average dry weather
capacity of 190,000 gallons per day and the influent characteristics presented in Table 2-2.
Table 2-3. Projected Influent Mass Loads
Description Value
BOD5 480 lbs./day
TSS 480 lbs./day
Total nitrogen 60 lbs./day
Total phosphorus 10 lbs./day
Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 2
2-4
2.5 Mass Loads to the Environment via Existing LCCs
Currently, 109 properties discharge without treatment to two LCCs, as shown in Figure 2-2. These
types of cesspools are a public health and environmental concern because of their likelihood of
releasing disease causing pathogens and other contaminants, such as nitrate, to groundwater. The
current annual mass loads to the environment via the existing LCCs based on the flow projections
and assumed wastewater characteristics presented above are summarized in Table 2-4.
Table 2-4. Mass Loads to the Environment via Existing LCCs
Parameter Annual Load
BOD5 174,000 lbs./year
TSS 174,000 lbs./year
Total N 23,000 lbs./year
Total P 4,000 lbs./year
3-1
Effluent Management Options and
Regulatory Requirements
Effluent management options are evaluated in this section, followed by an assessment of regulatory
requirements for the recommended effluent management system.
3.1 Effluent Management Options
Effluent management options are evaluated below.
3.1.1 Ocean Discharge
Ocean discharge of treated effluent is not considered a viable option for this small community due to
the long distance to the shoreline (approximately 3 miles), high cost to construct an outfall, stringent
receiving water quality standards, high receiving water monitoring cost due to the distance to Hilo
harbor, and difficulty and length of time required to secure the required permits.
The coastal waters in the Pahala area are classified as “AA” marine waters by DOH. HAR 11-54
does not allow zones of mixing in waters up to a distance of 300 meters (one thousand feet) off
shore if there is no defined reef area and if the depth is greater than 18 meters (ten fathoms). The
water quality criteria for nutrients for Class AA embayments are listed in Table 3-1. If a mixing zone
is not provided, then a WWTP discharging to the coastal waters would be required to treat water to
meet the applicable water quality criteria. Treatment to the specified levels is not feasible with
current technologies. Therefore, ocean discharge is not feasible.
Table 3-1. Nutrient Water Quality Standards for Class AA Embayments
Parameter Geometric mean not to exceed Not to exceed the given value
more than 10% of the time
Not to exceed the given value more
than 2% of the time
Total nitrogen 200 µg/L 350 µg/L 500 µg/L
Ammonia nitrogen 6 µg/L 13 µg/L 20 µg/L
Nitrate + nitrate nitrogen 8 µg/L 20 µg/L 35 µg/L
Total phosphorus 25 µg/L 50 µg/L 75 µg/L
3.1.2 Subsurface Disposal via Injection Wells
Per Hawaii Administrative Rules (HAR), Title 11, Chapter 23, disposal to groundwater via an injection
well is not allowed mauka of the State of Hawaii Department of Health (DOH) Underground Injection
Control (UIC) line. Since the town of Pahala is located mauka of the UIC line, an injection well is not a
viable option.
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3.1.3 Water Recycling
An irrigation assessment was prepared to assess the viability of water recycling as the primary
effluent management system, assuming the recycled water would be used to irrigate macadamia nut
trees. Figure 3-1 is a summary of the assessment that shows there is typically no irrigation demand
for six months of the year due to high rainfall. In addition, the DOH requires that all water recycling
programs have a 100 percent backup disposal system in place to handle flow that does not meet
recycled water quality standards or when recycled water supply exceeds demand. Therefore, water
recycling is not a viable primary effluent management strategy for the community. However, water
recycling treatment, storage, and distribution systems could be added in the future.
Figure 3-1. Irrigation Demand Assessment
0
1
2
3
4
5
6
7
8
JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
In
c
h
e
s
o
f
W
a
t
e
r
Month
Precipitation Evapotranspiration Irrigation Requirement
3.1.4 Land Treatment
The USEPA defines land treatment as “the application of appropriately pre-treated municipal and
industrial wastewater to the land at a controlled rate in a designed and engineered setting. The
purpose of the activity is to obtain beneficial use of these materials, to improve environmental
quality, and to achieve treatment goals in a cost-effective and environmentally sound manner”
(USEPA, September 2006).
Land treatment systems rely on soil and vegetation to achieve treatment objectives, rather than
energy-intensive mechanical equipment. As such, they are considered to be a form of “natural”
treatment (Crites, et. al., 2014).
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Land treatment is not a new concept. “Land application of wastewater was the first ‘natural’
technology to be rediscovered (after passage of the Clean Water Act of 1972). In the 1840s in
England, it was recognized as avoiding water pollution as well as returning nutrients in wastewater
back to the land. In the 19th century it was the only acceptable method for waste treatment, but it
gradually slipped from use with the invention of modern devices” (Crites, et. al., 2014).
The soils at the proposed WWTP location are suitable for slow rate (SR) land treatment. SR land
treatment consists of irrigation of land and vegetation with effluent. Significant treatment is
provided as the water percolates through the soil. The vegetation uses the nutrients in the effluent
as fertilizer, and transpires a portion of the applied water.
3.1.5 Drain Field
A drain field (i.e., leach field) could potentially be constructed for subsurface disposal of treated
effluent. Preliminary assessment of the concept based on the site soil characteristics indicate
approximately 20,000 linear feet of drain field trench would be required to accommodate the
anticipated flow. It would be difficult to evenly distribute effluent throughout a drain field of this size.
In addition, DOH regulations require a redundant drain field for subsurface disposal systems, making
this option expensive to implement. This option is considered impractical for the community.
3.1.6 Recommendation
A slow rate land treatment system is recommended for effluent management for the community.
3.2 Treatment Requirements
The DOH regulates land treatment as “land disposal” per Hawaii Administrative Rules (HAR) 11-62.
Table 3-2 lists the applicable effluent requirements for land disposal applicable to the project that
were in effect at the time this report was prepared.
Table 3-2. Applicable HAR 11-62 Land Disposal Requirements
Description Value HAR Reference
BOD5 30 mg/L monthly average
60 mg/L peak 11-62-26
TSS 30 mg/L monthly average
60 mg/L peak 11-62-26
Disinfection Except for subsurface disposal systems, continuous disinfection of the treated effluent shall be provided 11-62-24
Setbacks Treatment units shall be not less than 25 feet from property lines nor less than 10 feet from any building 11-62-23.1
Public accessibility control 6-foot-high fence surrounding treatment units 11-62-08
4-1
Wastewater Treatment Evaluations
This section presents the evaluations conducted in development of the proposed WWTP.
4.1 Preliminary Treatment
The preliminary treatment system will include screening, influent flow measurement, and influent
sampling equipment.
4.1.1 Screening
Screening is recommended to protect the downstream system operations from large objects, debris,
and rags that can be present in wastewater. Aerated lagoon treatment systems require a minimum
of coarse screens to protect the aeration equipment. 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. An aerated
lagoon treatment system can benefit from ¼-inch screening to reduce the amount of floatable debris
on the lagoon shoreline, creating a cleaner facility that is less attractive to birds. Since the Pahala
WWTP will not be continuously staffed, a screening process requiring minimal attention is desirable.
Furthermore, the screenings volume is expected to be small, subsequently screenings disposal is
expected to be infrequent; weekly at most. Therefore, the screenings must be washed of organic
debris to prevent the accumulation of nuisance odors and flies in the screenings barrel or bag
between screening disposal events.
4.1.1.1 In-channel cylindrical screen
We recommend 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. The screening portion consists of an inclined screen basket inserted into the
wastewater channel. The screening basket can consist of bars, perforated plates or sieves,
depending on the application and clear opening required. The controls can be set to allow a mat to
build up on the screening surface, allowing finer screening of the wastewater. Controlled by head
loss, a rake arm starts rotating within the screen basket, pushing the screenings off the rake and
into a perforated screenings hopper located at the screen’s central axis. A shafted auger along the
screen axis conveys the screenings from the hopper through an inclined tube, which dewaters and
compacts the screenings. The tube includes a perforated dewatering section. The discharged
screenings are about 40-percent dry, and can be discharged into a bin or directly into a bagging
system. Figure 4-1 illustrates the process. Manufacturers include Lakeside and Huber. The key
benefit to this system is the integrated screenings washing system, minimizing additional screenings
handling and odor potential.
For this installation, the headworks will include two in-channel cylindrical screens, one will be on-line
when the other is redundant, plus a bypass channel with manually cleaned bar rack.
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Figure 4-1. In-Channel Cylindrical Screen
4.1.2 Influent Flow Measurement
Influent flow measurement is recommended to allow assessment of flows and loads to the biological
treatment process, and to assess the biological treatment process performance. A Parshall flume
will be provided upstream of the screening system to continuously record influent flow rates.
Parshall flumes work well for influent measurement because the flume can operate in an open-
channel configuration, can accommodate wide ranges of flows, and is self-cleaning. A straight
approach length of at least 20 times the flume throat width will be provided upstream of the flume to
provide favorable hydraulic conditions.
4.1.3 Influent Flow Sampling
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 optimization of aeration rates in the biological treatment process. Periodic influent sampling is
also recommended to monitor for changes in the influent characteristics.
4.1.4 Preliminary Design of Headworks
Figure 4-2 shows a plan and section of the proposed headworks. Influent wastewater will enter the
upstream end of the headworks channel. Stop plates will be used to divert the flow to one of the two
the in-channel cylindrical screens, or to the manually-cleaned bar rack. The slide gates will be
designed to allow automatic overflow to the other channels in the event of mechanical screen
failure. The washed and compacted screenings will be deposited in a bag or 55-gallon drum for
periodic disposal. The Parshall flume and automatic refrigerated composite sampler will be located
upstream of the screens. The channels will be covered with fiberglass or aluminum plate to facilitate
foul air collection, which will be conveyed to an odor control unit. In addition, a free-standing roof
structure will be constructed over the headworks to protect the operators and equipment from rain
and sun.
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Figure 4-2. Headworks
Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 4
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4.1.5 Odor Control
A notorious location for foul odor is the headworks of a wastewater treatment plant. This odor is
caused by hydrogen sulfide (H2S), which is formed under anaerobic conditions of the wastewater
collection system. Due to H2S low solubility in wastewater, when there is an excessive concentration
of H2S in the wastewater or if there is turbulence, H2S gas escapes into the atmosphere. This
release produces the 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.
Treatment of foul odors can be approached in two ways: preventing odors through liquid treatment
or controlling odors in the gas phase. While liquid treatment provides control of odors prior to their
release, gas phase treatment involves the collection and treatment of gases once they have been
released from wastewater. Treatment methods can be aimed at one type of odor, or can treat a
range of odors.
4.1.5.1 Granular Activated Carbon
A granular activated carbon (GAC) scrubber is recommended for the Pahala WWTP headworks. A
GAC scrubber passes odorous air through a bed of activated carbon, which adsorbs 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. Figure 4-3 illustrates the process. The County currently operates GAC scrubbers
at other facilities, and purchases the GAC media in bulk to reduce costs.
Figure 4-3. Activated Carbon Scrubber (GAC)
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4.2 Aerated Lagoon Treatment System
The biological wastewater treatment needs at the Pahala WWTP will be met by a series of aerated
lagoons. A floating cover will be installed on the last cell to reduce algae in the effluent. The
preliminary design of the aerated lagoon treatment system is developed in this section.
4.2.1 Aerated Lagoon Kinetics
The Pahala WWTP design is reliant on partial mix aerated lagoon environments to provide the
community’s wastewater treatment needs for the initial buildout condition. Partial mix aerated
lagoon kinetics are described below.
4.2.1.1 Partial mix model
Partial mix aerated lagoons are based on the concept of allowing solids to settle in lagoons while
providing only enough aeration and mixing to meet the oxygen requirements of the naturally
occurring micro-organisms in the system. The solids tend to settle in areas of the lagoon that are
subject to less mixing energy, where they anaerobically decompose. Infrequent sludge removal is
required to maintain sufficient lagoon treatment volume.
Removal of BOD5 in partial-mix aerated lagoons depends on the hydraulic detention time. The
design model for partial mixed ponds of equal size in series is (Crites, et. al., 2006):
nnktCo
Cn
)/(1[
1
+=
Where Cn = effluent BOD5 concentration in cell n , mg/L
Co = influent BOD5 concentration, mg/L
k = partial-mix first-order reaction rate constant, day-1
t = total hydraulic residence time in the lagoon system, day
n = number of cells in the series
If the lagoons in a system are of unequal size, then the equation must be applied to each lagoon in
the series. The Ten-States Standards recommends using a value of 0.276 day-1 at 20 ºC for the
reaction rate constant (Great Lakes – Upper Mississippi River Board, 1997).
4.2.1.2 Mixing in Lagoon Systems
The energy required for mixing in aerated lagoon systems is generally provided by the aeration
system. For partial mix systems the aeration system is sized to provide enough oxygen to maintain
aerobic conditions and no more. For mechanical aeration systems energy input of at least 30
horsepower per million gallons (hp/Mgal) of lagoon volume is required to keep solids in suspension
(Rich, 1999).
4.2.2 Aeration in Lagoon Systems
Oxygen requirements in aerated lagoon systems are based on the organic loading entering the cell.
Supplying oxygen at a rate of 1.5 times the BOD5 mass entering the cell has been found to be
sufficient to treat the wastewater. The following equation is used to estimate the oxygen transfer
rate (Crites, et. al., 2006):
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)20()025.1()(−
−=
Tw
S
Lsw
a
C
CC
NN
α
Where N = Equivalent oxygen transfer to tap water at standard conditions (lbs/hr)
aN = Oxygen required to treat the wastewater (lbs/hr)
α = (oxygen transfer in wastewater)/(oxygen transfer in tap water)
swC = PCss)(β = oxygen saturation value of the waste, mg/L
β = wastewater saturation value/tap water oxygen saturation value = 0.9
ssC = tap water oxygen saturation value at temperature Tw
P = ratio of barometric pressure at the site to barometric pressure at sea level
LC = minimum dissolved oxygen concentration to be maintained
SC = oxygen saturation value of tap water at 20ºC and 1 atm pressure
wT = wastewater temperature, ºC
Oxygen can be supplied to aerated lagoon systems using mechanical aerators or diffused aeration
systems. Mechanical aerators are commonly rated by the number of pounds of oxygen the units will
supply under standard conditions per horsepower-hour (lbs. O2/hp-hr). Diffused air requirements are
calculated using the following equation (Crites and Tchobanoglous, 1998):
)1440)()()((2 air
oxygen
air OAOTE
WQ γ=
Where airQ = Required air flow (ft3/min)
oxygenW = Oxygen requirements (lbs/day)
AOTE = Actual oxygen transfer efficiency, expressed as a fraction
O = Fractional percent of oxygen in air by weight (0.2315) 2
airγ = Specific weight of air (0.075 lbs/ft3 at 1 atmosphere and 20ºC
The oxygen transfer efficiency of a diffused air system is a function of the air bubble size and the
depth of the water column. Smaller air bubbles result in higher oxygen transfer efficiencies than
larger bubbles, as do diffusers that are set at deeper depths within the water column.
4.2.2.1 High speed floating aerators
High-speed floating aerators are commonly used for aerated lagoon systems. The units consist of a
motor and impeller attached to a float. The units are typically anchored to the lagoon shore using
cables. High-speed floating aerators are designed to pump water from the lagoon and spray it into
the air, allowing oxygen to diffuse into the water droplets. The high-speed floating aerators can be
Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 4
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outfitted with draft tubes to enhance deep water lagoon mixing or anti-erosion plates to ensure water
is drawn from the surface. Figure 4-4 shows a typical high-speed floating aerator.
Figure 4-4. High Speed Floating Aerator
Advantages of this system include low capital costs, relatively high oxygen transfer efficiency, good
mixing efficiency, and simple operation and maintenance. The chief disadvantage of the system is
the creation of aerosols as the lagoon water is sprayed into the air.
Manufacturers of this type of aerator include Aqua-Aerobics, Aerator Products and Europlec/Aeromix
Systems Inc.
High-speed floating aerators are recommended for the Pahala WWTP due to their relatively high
oxygen transfer efficiency, low capital cost, and simple operation and maintenance. High-speed
floating aerators are easy to remove from service, and can be easily moved between lagoons or cells,
if needed.
4.2.3 Aerated Lagoon Configuration
The normal operating condition for the Pahala WWTP will be to operate the four lagoon cells in series
as partial mix environments. Figure 4-5 is a schematic representation of the normal operating mode.
The fourth cell will be outfitted with a floating cover to preclude algae growth. Having four lagoons
will allow the County to take a lagoon out of service for maintenance.
Figure 4-5. Normal Lagoon Configuration Schematic
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Table 4-1 summarizes the results of the aeration and mixing calculations for the normal operational
configuration treating the design average dry weather flow rate of 190,000 gallons per day.
Comparison of the minimum aerator requirements shown in Table 4-1 with the proposed aerator
layout shown in Figure 4-4 reveals that the aerator power supplied exceeds the minimum
requirements. An aerator control system will be provided that will intermittently turn the aerators on
and off in accordance with the operator settings to supply sufficient oxygen to the system.
Table 4-1. Normal Configuration Aeration and Mixing Requirements
Cell Volume
(gal)
Influent BOD5
(mg/L)
Effluent BOD5
(mg/L)
Minimum Aerator
Requirement (hp)
Mixing Density
(hp/Mgal)
1 80,000 300 139 27 34
2 80,000 139 64 13 16
3 80,000 64 30 6 7
4 80,000 30 <30 2 3
4.2.4 Lagoon Liner
Lagoon liners are required to prevent wastewater seepage into the ground. The liner will be exposed
to sunlight, so resistance to ultraviolet light (UV) degradation is a key factor in the selection of the
liner material, as is the compatibility of the material with typical domestic wastewater characteristics
and ease of liner maintenance. An 80-mil textured high density polyethylene (HDPE) geomembrane
is recommend for this application.
Textured HDPE is known to have excellent UV resistance, good chemical resistance, and generally is
not affected by fats, oils, and grease (FOG). Maintenance of HDPE requires a specialty contractor
who can complete fusion weld repairs. Unlike smooth HDPE, textured HDPE presents minimal
slipping hazard to operations personnel. Furthermore, the anticipated useful service of an HDPE
liner in typical Hawaii municipal wastewater treatment conditions is 25 to 30 years.
Alternatively, the lagoons may be constructed of concrete.
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4.2.5 Lagoon Cover
In the normal operating mode, the final cell in the lagoon series will be covered in order to deprive
algae of sunlight. This will reduce the algae concentration, which can increase total suspended
solids (TSS) levels in the system effluent. The cover should float on the surface of the water, be UV
resistant, suitable for windy environments, and allow for rainwater to pass through the cover to
prevent ponding. A floating shade ball cover is proposed for this installation.
Floating shade balls covers have been used for decades in in the mining, water and wastewater
treatment industries. Figure 4-6 shows the design elements of a typical shade ball, and Figure 4-7
shows how shade balls provide cover on a reservoir. In addition to reducing algae growth, shade ball
covers deter waterfowl from storage ponds. The black, UV-stable HDPE resin has known to withstand
a range of challenging chemical and environmental conditions. Table 4-2 summarizes technical data
for the balls.
Table 4-2. Lagoon Shade Ball Cover Application Parameters
Requirement Description
Algae Control Balls – 90% shade coverage
Temperature 500C to 950C
Wind Resistance Balls ballasted with potable water tested in winds of 120 mph (category 3 hurricane)
Waterfowl Safety Waterfowl do not recognize ball-covered pond as a water body and will not nest on the unstable surface
Lifecycle/Warranty The shade balls are warrantied for 10 years, with an expected resin life of 25+years
Operations and Maintenance
Self-cleaning, self-levelling and require little to no maintenance
Balls will move out of the way of maintenance barge, and can be restrained with booms
Little installation effort required
Precipitation does not affect the cover
Sustainability
Resin is recyclable, paraben free and suitable for drinking water applications
Ballast is potable water
Resin can be made from recycled plastic
Environment
Balls have been installed in chemically harsh environments (mining industry), in drinking water reservoirs, and in tropical locations
Balls reduce algae formation and corresponding disinfectant byproducts in chlorination applications
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Figure 4-6. Floating HDPE Shade Balls
Figure 4-7. Floating shade balls with current and turbulence in reservoir.
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4.2.6 Lagoon Sludge Management
Partial-mix aerated lagoons are designed to allow solids to settle to the bottom of the lagoon, forming
a sludge layer. The sludge slowly anaerobically digests in the bottom of the lagoon. The mechanical
aerators in the lagoon maintain an aerobic water cap at the surface of the lagoon that oxidizes any
odors that are released from the anaerobic sludge layer at the bottom of the lagoon. Sludge is
removed infrequently, typically every 15 to 30 years, when the sludge blanket thickness begins to
affect treatment performance or in conjunction with lagoon liner replacement. Aerated lagoon
operators typically monitor sludge blanket thicknesses semi-annually to assess sludge accumulation.
Sludge removal contractors are typically employed to dredge the solids, dewater, and haul to a
landfill for disposal. Sludge from aerated lagoons is typically not offensive when dewatered due to
the long residence time in the bottom of the lagoon.
Alternatively, the sludge can be recycled if a permitted land application site is available and the
sludge meets State and Federal requirements for land application or composted with green waste at
a permitted composting facility.
4.3 Subsurface Flow Constructed Wetland
A subsurface flow constructed wetland is recommended to provide additional treatment and
polishing of the aerated lagoon effluent. It is anticipated that the aerated lagoon system will convert
ammonia that is present in the wastewater influent into nitrate via a process called nitrification. A
subsurface flow constructed wetland will remove this nitrogen from the wastewater via a process
called denitrification. Reduction of nitrogen loading through the constructed wetland will decrease
the area required for overland flow effluent management.
Subsurface flow wetlands consist of shallow lined basins that are filled with gravel media and
planted with emergent wetland vegetation. Water is introduced to the gravel media layer and flows
horizontally through the basin. The water level in the wetland is maintained below the gravel surface
at all times. Treatment occurs through physical, chemical, and biological mechanisms as the water
flows horizontally through the gravel media bed. Figure 4-8 is an illustration of the concept.
Figure 4-8. Subsurface Flow Constructed Wetland Concept
4.3.1 Denitrification in Subsurface Flow Constructed Wetlands
Denitrification is a biological process whereby nitrate molecules are transformed into nitrogen gas
molecules by naturally-occurring bacteria. The denitrifying bacteria require five conditions for the
process to occur:
• A place to grow.
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• A source of nitrate.
• An anoxic (low-oxygen) environment.
• A source of carbon.
• Adequate water temperature.
The equation used to predict denitrification in subsurface flow constructed wetlands is shown below
(Crites, et.al., 2014). 𝐶𝐶𝑒𝑒𝐶𝐶𝑜𝑜=exp(−𝐾𝐾𝑇𝑇𝑡𝑡)
where: 𝐶𝐶𝑒𝑒 = effluent nitrate-nitrogen concentration (mg/L) 𝐶𝐶𝑜𝑜 = influent nitrate-nitrogen concentration (mg/L) 𝐾𝐾𝑇𝑇 = temperature-dependent rate constant = 1.00(1.15)(𝑇𝑇−20) days-1 when T>1°C 𝑡𝑡 = hydraulic residence time (days)
Subsurface flow constructed wetlands are capable of providing additional treatment benefits beyond
nitrogen reduction, such as removal of organic carbon, suspended solids, phosphorus, metals, trace
organics, and pathogens. The additional treatment benefits are not primary design parameters, but
should be considered as additional polishing treatment benefits that may be realized for the Pahala
WWTP.
4.4 Disinfection
Disinfection processes selectively kill pathogens or render them incapable of reproduction or harm to
humans. Disinfection at WWTPs is employed for the purposes of protection of public health,
reduction of organic matter, inorganics, nutrients, odor, aesthetics, and maintaining waste-
assimilative capacity of receiving water bodies. The protection of public health through the control of
disease-causing microorganisms is the primary reason for wastewater disinfection (WEF, 1996). As
the last barrier of protection from pathogenic organisms, disinfection at WWTPs is an important
process. To address disinfection, both a calcium hypochlorite system and a UV system were
evaluated.
4.4.1 Calcium Hypochlorite
Calcium hypochlorite is the most common 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.
The solid can be directly applied to wastewater at very small WWTPs. Figure 4-9 shows a typical
calcium hypochlorite feed system.
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Figure 4-9. Typical Calcium Hypochlorite Feed System
The advantages of using calcium hypochlorite for disinfection at small, remote WWTPs is that it is
available in concentrated form as powder, pellets, or tablets. This makes the transportation and
storage of disinfectant optimal for small WWTPs. Table 4-3 summaries calcium hypochlorite
characteristics.
Table 4-3. Calcium Hypochlorite Summary
Description Characteristic
Transported form Solid
Typical transported concentration 70%
Largest transported volume available 55 lb. pails
Decay Rate Decays 3-5% per year
pH N/A
Hazards Toxic if ingested (usually through dust or liquid form)
Storage constraints Must be stored in a cool, dry, dark place
Special equipment Tablet feeder
Particular issues Heats and combusts if not stored properly Scaling in pipes, Off gassing
4.4.1.1 Dose and Contact Time
The effectiveness of a chlorination system is highly dependent on the characteristics of the
wastewater, the initial mixing and contact time, and the chlorine dose used. For nitrified effluent, the
recommended dose is between 8 and 18 mg/L. The WWTP will discharge to a land application
system during normal flow and wet weather periods when the secondary effluent will be diluted by
precipitation falling onto the overland flow terraces. For planning purposes, a 10 mg/L dose was
assumed to be sufficient for the WWTP for most circumstances, but equipment will be sized to
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4-14
provide chemical feed at a rate of up to 100 lbs./day, which will ensure an adequate chlorine dose
for peak wet weather discharge flows.
Table 4-4 lists the chlorine demand for various flow conditions.
Table 4-4. Chlorine Demand
Description Flow Chlorine Demand
Average dry weather flow 0.19 mgd 16 lbs./day
Peak day wet weather flow 0.662 mgd 55 lbs./day
The recommended minimum contact time for chlorination is 15 minutes (Ten States Standards
Wastewater, Recommended Standards for Wastewater Facilities, 1997, Great Lakes – Upper
Mississippi River Board of State and Provincial Public health and Environmental Managers). The size
of the chlorine contact tank will need to accommodate a 15-minute contact time for the peak
discharge rate. For this application, the peak discharge rate will be equal to the peak day wet
weather flow, due to the flow equalization provided by the aerated lagoons. Table 4-5 summarizes
the contact tank dimensions, while Figure 4-10 shows a conceptual contact tank configuration.
Table 4-5. Chlorine Contact Tank
Description Value
Peak discharge rate 460 gpm
Minimum chlorine contact tank 15 minutes
Tank volume required 920 cubic feet
Channel water depth 5 feet
Channel width 3 feet
Tank channel total length 61 feet
Tank dimensions including channel walls 13 feet x 24 feet
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Figure 4-10. Chlorine Contact Tank Configuration
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4.4.2 Ultraviolet Light (UV) Disinfection
A common alternative to a chlorine disinfection is ultraviolet light (UV). Ultraviolet systems destroy
microorganisms by affecting their deoxyribonucleic acid (DNA) and ribonucleic acid (RNA) and impeding
their ability to reproduce. A UV disinfection system is comprised of lamps, a reactor, and control
panel. Wastewater can flow either parallel or perpendicular to the lamps in the reactor, while the
control box provides a starting voltage and maintains the continuous current needed. Currently,
most systems are equipped with an automated lamp cleaning system, to maintain lamp efficiency
levels.
A UV system’s effectiveness is dependent on the characteristics of the wastewater, the dose, and the
exposure time. In the case of UV radiation, the most important factor is the transmittance of the
water, which has a direct effect on the ability of UV light to penetrate through the liquid and reach
microorganisms present at the required intensity. Ideally, the discharge undergoing treatment
should not have a transmittance lower than 55 percent, with the intensity decreasing the farther the
microorganisms are from the lamp. The optimum wavelength to effectively inactivate
microorganisms is between 250 and 270 nanometer.
The main types of UV lamps used for wastewater disinfection are conventional low-pressure lamps,
low pressure high output (LPHO) lamps and medium pressure lamps. Several UV systems include
lamps with automated sleeve cleaning.
4.4.3 UV System Design Summary
A UV disinfection system requires a about the same size footprint as chlorine. Disinfection occurs as
the organism is exposed to the UV radiation as the water flows past the UV lightbulbs. The Trojan
UV3000+ system is used at numerous facilities across the US, including some treatment plants in
Hawaii. The estimated cost included in this report are based on an assumed UV transmittance of 65
percent. The amalgam lamp used with the UV3000+ system has an end-of-lamp-life factor (ELLF) of
0.98 indicating little loss in UV light output over the life of the lamp. This ELLF has been tested and
approved by the State of California and is also accepted by the State of Hawaii for reuse
applications. The system would use LPHO lamps with automatic sleeve cleaning. LPHO lamps are
energy efficient and the UV300+ system is furnished with automatic sleeve cleaning devices to
reduce labor requirements. Each UV lamp is enclosed in a quartz sleeve to separate it from the water
medium. Each lamp draws 254 watts at full output and is driven by electronic ballast. The
electronic ballast allows the lamps to be dimmed to conserve power based on a control signal from a
flow meter. The LPHO lamps will have a minimum life of 12,000 hours when operated in an
automatic mode and limited to a maximum of 4 on/off cycles per 24 hours. Table 4-6 summarizes
the size and design criteria for the UV system required to treat the WWTP discharge.
Table 4-6. UV Disinfection Design Summary
Description Value
Peak Hour Wet Weather Discharge 630 gpm
Minimum UV transmittance 65 percent
No. of UV channels 1
Design dose 35,000 µWs/cm2
Disinfection limit 30 e-coli per 100mL
Validation factors 0.98 end of lamp factor
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4.4.4 Cost Evaluation
A summary of capital and life-cycle estimated costs for both chlorination and UV disinfection is
presented in Table 4-7 for comparison.
The capital costs include the materials and equipment costs, construction costs, electrical,
instrumentation and control, soft costs, and contingency. As shown in the table, the UV option incurs
higher capital costs. The life cycle costs look at the impact of the capital costs along with the annual
operations and maintenance costs, including power, materials, chemicals, and labor costs over the
next 30 years. The life-cycle costs for chlorination option appear to be about 78 percent of the UV
option.
Table 4-7. Estimated Disinfection Costs
Description Chlorination UV System
Capital Cost $200,000 $800,000
Annual Operations and Maintenance $15,000 $6,000
Life-cycle Cost (30-Year Net Present Value) $746,000 $947,000
4.4.4.1 Non-Economic Evaluation
Table 4-8 presents a summary of advantages and disadvantages of using an ultraviolet light for
disinfection.
Table 4-8. Ultraviolet Disinfection – Advantages and Disadvantages
Advantages Disadvantages
Effective at inactivating most viruses, spores, and cysts Low dosage may not be effective on some pathogens and some organisms can repair and reverse the destructive
effects of UV
It’s a physical process, instead of chemical – it eliminated the need to transport, handle, store toxic or
corrosive chemicals
Turbidity and TSS in the wastewater can reduce UV disinfection effectiveness
No harmful residual compounds created that are toxic to humans or aquatic life Will likely require more call-outs by operators due to alarms caused by “dirty power”.
Shorter contact time (less than a minute) The relative intensity of equipment maintenance requirements, including staffing training and on-island avaliablity.
4.4.5 Disinfection Recommendation
A tablet chlorination system is the recommended disinfection option over the UV system for the
WWTP because it incurs lower capital and lifecycle costs. In addition, tablet chlorination will be
more-reliable than UV due to frequent “dirty power” conditions on the island. The County has elected
to install a UV system at the Pahala WWTP, to reduce the use of chemicals at the facility. An
uninterruptable power supply may be installed to address “dirty power” concerns.
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4.5 Effluent Management
For effluent management, a slow-rate land application system is proposed. The concept is to
intermittently apply wastewater to crops growing in permeable soils. As the applied water percolates
through the soil matrix or is taken up by the crop, it is treated by physical filtration and by biological
mechanisms. After an application period or wetting period, the surface can dry and oxygen can enter
the soil matrix, which aids aerobic biological treatment. The frequent wetting and drying also
maintains the infiltration rate through the soil surface and minimizes soil clogging. This method of
land application is an effective treatment process for BOD5, TSS, trace organics, phosphorus, metals
and pathogen removal. Furthermore, removal of nitrogen can be significant when system is
managed for that objective.
4.5.1 Design
The slow-rate system site consists of a net area of approximately 5.5 acres. The 5.5 acres will be
divided into 4 small groves of native trees, so that water application will be rotated to a different
grove each day. An additional small grove will be utilized as an emergency (overflow) or reserve
when surface or distribution system maintenance is conducted. By using one groove per day the
wet/dry cycle will be 1-day wetting and 3-days drying.
The groves will be planted with native Hawaiian trees. Trees grown within the land application area
will need to be water tolerant. Table 4-9 lists potential native tree species.
Table 4-9. Potential Land Application System Tree Species
Common Name Genus Species Salt
Tolerance Water Requirements Rubbish and
Maintenance Preferred Elevation
Milo Thespesia populnea Very Dry to Wet Moderate Low to Medium
Loulu Pritchardia hillebrandii Very Dry to Wet Low Low
Aalii Dodonaea viscosa Very Dry to Medium Low Low to High
Kou Cordia subcordata Very Dry to Wet Moderate Low
Golden Loulu Pritchardia arecina Moderate Dry to Wet Low Low to Medium
Wiliwili Erythrina sandwicensis Moderate Dry to Medium Moderate Low
The distribution system will consist of gated piping located on the surface. The piping will have slots
to allow the applied wastewater to uniformly be distributed over the grove surface. A perimeter
fence will be installed to limit access. Access roads will surround each grove. Figure 4-11 reflects
the proposed land application schematic.
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Figure 4-11. Land Application System Schematic
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4.6 Ancillary Systems
4.6.1 Water
Potable water is not currently available at the site. The nearest potable water system is located
uphill in town. Table 4-10 provides an initial assessment of the potential water demands at the
WWTP. The water demands are either for process or potable uses. As shown in the table, the
process water demands are significantly greater than the potable demands.
Table 4-10. Potential Water Demands
Description Flow Rate Type Priority
Screenings washer 20 gpm for 10 min/hour
4,800 gpd Process Mandatory with screen
Hose bibs 10 gpm for 20 min/day
200 gpd Process Desirable to maintain facility
Emergency eye wash / shower 20 gal per use Potable Mandatory
Restroom 20 gpd Potable Recommended
To supply water to the WWTP, it is recommended to construct approximately 2,000 linear feet of pipe
from the intersection of Huapala Street and Maile Street to the site and install a 1-inch water meter
with 1 ½-inch backflow preventer.
A plant water system will be supplied by the County water meter. The on-site water system will be
split into two branches, one for process water and one for potable water. The potable water will
service the restroom and emergency eye wash/shower. A second backflow preventer will separate
the process water uses from the potable connections.
4.6.2 Access Road
All weather access will be required to operate and maintain the WWTP. Access to the site will be
provided by connection to Maile Street. A paved driveway apron is proposed at Maile Street and an
all-weather driveway will extend into the site and provide access to and around the various WWTP
infrastructure. Additionally, a turn-around area large enough to accommodate a fire truck will be
provided.
Access road pavement options include aggregate base (AB) gravel, asphalt concrete (AC), or
concrete. AB is the lowest cost option, but requires the most maintenance. AC pavement is not
recommended for steep (greater than 12 percent) grades. Concrete is the highest cost option, but is
the most durable and requires the least maintenance.
The recommended driveway pavement section is 2-inches of AC over 6-inches of aggregate base
course. For portions of the driveway that exceed 12 percent slope, a concrete pavement section is
recommended.
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4.6.3 Stormwater Management
The overall goal of stormwater management is to mitigate the adverse impact of new construction on
the environment. Stormwater management can generally be separated into two areas:
1. Stormwater Quantity: management of the quantity to prevent increased flows and
volumes leaving the site on the downstream watercourses.
2. Stormwater Quality: management of the quality of stormwater runoff to prevent
contaminants such as silt, trash, hydrocarbons, heavy metals, and pesticides from
leaving the site through stormwater runoff.
4.6.4 Pre-development Stormwater Conditions
4.6.4.1 On-site
The majority of the proposed 42.5-acre site is currently utilized as macadamia nut orchards,
consisting of trees or unimproved agricultural roads. The parcel is bound on two sides by improved
county and state right-of-way and to the east by additional macadamia nut orchards.
The existing elevations range between 580 to 780 feet above mean sea level (MSL) and slopes in
the southerly direction at an average rate of 8 percent. The soils in this area are described as
Naalehu medial silty clay loam (NaC) by the Soils Conservation Service (SCS). These soils are
considered well drained with low runoff and slight erosion hazard.
On-site stormwater run-off generally sheet flows in a southerly direction to off-site swales along the
roadway frontages, Maile Street and Hawaiian Belt Road (also known as Mamalahoa Highway).
There is no known on-site drainage collection system, see Figure 4-12.
4.6.4.2 Off-site
Swales that run and collect along the roadway frontages of the property are conveyed through a box
culvert at the intersection of Maile Street and Hawaiian Belt Road and discharged makai. Similarly,
running along the north property line is an abandoned concrete flume, which was previously utilized
to discharge process water from the adjacent old sugar mill to agricultural land makai of Hawaiian
Belt Road. Figure 4-12 conceptualizes the existing drainage system.
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Figure 4-12. Existing Drainage System
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4.6.4.3 Flood Hazards
The subject property flood zone is designated Zone X, area of minimal flood hazard corresponding to
areas outside of the five-hundred-year flood plain, as indicated on the current September 29, 2017
Flood Insurance Rate Map (FIRM), Community Panel No. 1551661800F. Zone X designations are
not subject to the requirements of the Standards of Floodways, Chapter 27, Section 22 of the Hawaii
County Code. See Figure 4-13 for the Flood Insurance Rate Map.
On April 16, 2018, the State of Hawai‘i Department of Land and Natural Resources Engineering
Division stated the responsibility for conducting research as to the flood hazard designation for the
project site lies with the project proponent. Also on April 16, 2018, the County of Hawai‘i
Department of Public Works confirmed that the proposed treatment and disposal project site at Site
7 is designated as Zone X on the FIRM and is outside the 500-year floodplain.
The WWTP site slopes from approximately north to south (mauka to makai) such that, during rain
events, surface flows pass through the existing orchard to the southern (makai) end where the flows
eventually drain through the culvert located at the Maile Street-Māmalahoa Highway intersection to
the areas below (makai) the highway. Most of the land surface area below the existing macadamia
nut orchard contains little to no vegetation to absorb or slow these flows. The gradient of the site
and surrounding area results in this natural pattern of surface flows which also existed when the
area was planted in sugar cane and is not considered flooding.
Based on the roadway flooding concerns expressed by the community during the Pāhala public
meetings held in December 2017 and October 2018, the State of Hawai‘i Department of
Transportation (DOT) Hawai‘i District office was contacted to discuss drainage at the treatment and
disposal facility project site and the culvert at the Maile Street and Māmalahoa Highway
intersection. On February 20, 2019, the District office confirmed via telephone that the DOT owns
and maintains the culvert at the Maile Street intersection, and that they have no record of the
roadway being inundated by stormwater drainage during storm events.
Stormwater drainage flows generated from the existing orchard mauka of the treatment and
disposal facility project site will be directed around the perimeter of the site via diversion swales that
will convey flow back to the existing drainage pattern that flows to the existing culvert at Maile
Street. During heavy rain events, stormwater may temporarily back up behind the culvert. There
will be no changes to this culvert and the WWTP facilities will not be located within the area of the
culvert.
The on-site stormwater management system to collect runoff via grated inlets or swales, and flows
would be conveyed to on-site drainage detention systems, such as subsurface linear infiltration or
depressed detention basins. Landscape buffers with dirt berms would also be constructed around
most of the perimeter of the facility to act as secondary containment in the event of a large storm
event. The on-site stormwater management system would meet the requirements of Hawai‘i County
Code, Chapter 27, Section 20, which mandates drainage plans to accommodate runoff caused by
the facility for a 1-hour, 10-year storm event.
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Figure 4-13. Flood Insurance Rate Map
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4.6.4.4 Stormwater Quantity
The increase in peak flow and runoff volume is a function of the increase in impervious areas
associated with the proposed improvements.
All exposed (not enclosed) treatment processes will be sized to include free-board depth to
accommodate the 24-hour, 100-year storm event. Thus, no stormwater runoff from these areas is
anticipated.
A drainage system will be designed to address stormwater surface run-off caused by impervious
portions of the WWTP development. Per the Hawaii County Code, Chapter 27, Section 20, the site
drainage plan shall accommodate the run-off caused by the proposed development, within the site
boundaries, for a one-hour, ten-year storm event. The pre-development runoff (10-year, 1-hour
storm) is approximately 23 cubic feet per second (cfs). The post-development runoff is
approximated at 24.5 cfs, which is a net increase of 1.5 cfs.
To ensure that there is no adverse impact on adjacent or downstream properties due to post-
development flows, an on-site drainage system will collect runoff via grated inlets or swales. These
flows will be conveyed to on-site drainage detention systems, such as subsurface linear infiltration or
depressed detention basins, to detain flows and volumes to their pre-development condition.
Furthermore, landscape buffers with dirt berms will be constructed around most of the perimeter of
the property acting as secondary containment in the event of a large storm event.
A complete analysis of the pre and post development drainage condition will be completed during
the design phase. The site drainage plan will be prepared to comply with sections 27-20(a) and (b)
and section 27-24, and shall include a storm water disposal system to contain run-off caused by the
proposed development, within the site boundaries, up to the expected one-hour, ten year storm
event as shown in the department of public works “Storm Drainage Standards”.” A geotechnical
engineering assessment of berm stability will be conducted during the design process for any berms
constructed to act as secondary containment in the event of a large storm event.
To meet the requirements of HCC, Chapter 27, Section 20 (f), the project site “shall not alter the
general drainage pattern above or below the development”. Thus, no increase in flow amount will
be directed to either of the culverts at the highway as a result of the site development. A drainage
study will be prepared during the design process to evaluate the improvements necessary to comply
with HCC requirements.
The wastewater treatment processes will be designed to accommodate the peak flows during wet
weather events, including precipitation that falls on the area occupied by the aerated lagoon
treatment system. Section 2 outlines the anticipated peak wastewater flows from the community,
based on the applicable flow standard. The aerated lagoons will be lined with high density
polyethylene liners or concrete to prevent water seepage through the bottom and sides of the
lagoons. The aerated lagoons will be designed with operational freeboard that will be available to
contain and to equalize lagoon flows during peak wet weather events. In addition, the slow-rate land
application groves will be designed to completely contain both peak effluent flows and precipitation
from a 100-year, 24-hour storm event. This will be accomplished by constructing berms around the
land application tree groves. The tree groves will be designed in accordance with the EPA’s “Process
Design Manual, Land Treatment of Municipal Wastewater Effluents”. Effluent will be applied at a
hydraulic loading rate that is a small percentage of the percolation rate of the soil, ensuring
sufficient capacity for assimilation of peak effluent flow rates and precipitation from the design
storm event.
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4.6.4.5 Stormwater Quality
The quality of stormwater leaving the site is also a concern. Stormwater quality degrades with
development and increased impervious surfaces, because various pollutants are introduced into the
stormwater runoff.
The first half-inch of runoff during a storm is referred to as the Water Quality Volume (WQV) or the
“first-flush” volume. This portion of the runoff from a storm contains measurably more suspended
solids plus other contaminants per cubic foot than would be expected in runoff occurring later in the
storm.
To mitigate the quality of runoff, the drainage system will incorporate permanent Best Management
Practices (BMP’s). Recommended permanent BMP include scheduled good-housekeeping, which
will reduce litter and other constituents from being washed into the storm drain system, and
detention basins and underground infiltration facilities that prevent the release of sediment and
other pollutants to downstream waterways or adjacent properties. A full assessment of all available
BMP’s to optimize water quality will be provided during design of the project.
4.6.5 Electrical Systems
It will be necessary to bring electrical power to the WWTP site. It is anticipated that Hawaii Electric
Light Company (HELCO) will bring overhead power lines to the site and supply 480-volt, 3 phase
power to the WWTP via a pole-mounted transformer to a service panel with a meter.
The floating surface aerators will consume the majority of the electricity supplied to the site. An
electrical room will house the electrical gear, plant control equipment and the chlorination system.
Exterior lighting at the site will be limited to manually switched lights at the entrance to the electrical
building and at the headworks area.
A standby power system will be provided in the form of a pad-mounted diesel generator and above-
ground fuel tank with capacity to support three consecutive days of operation. In addition, the
electrical service panel will be equipped with a manual transfer switch and generator receptacle to
allow connection of a trailer-mounted generator in the event of emergency generator failure during
an extended power outage.
4.6.6 Telemetry Systems
A land-line telephone telemetry system with auto-dialer will be provided to provide Hilo-based
operation staff of alarm conditions and key operational parameters at the WWTP. Additionally, a cell
phone will be available for backup.
4.6.7 Operations Building
An operations building will be constructed to include the electrical room, chlorinator generator room,
restroom, and maintenance/storage room, as shown in Figure 4-14.
4.6.8 Site Fencing
The entire WWTP site, including the treatment systems and the land application system, will be
fenced (6-foot high chain link) and posted to prevent public access.
4.6.9 Alternative Energy
The WWTP does not include utilizing alternative energy systems such as photovoltaic solar as a total
replacement for connecting to the HELCO grid due to:
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• the need for consistent power supply;
• emergency backup power requirements;
• up front capital cost;
• full utilization of the 14.9-acre proposed site for the treatment and disposal facility;
• objective to minimize the amount of land area removed from agricultural production; and
• EPA-enforced project implementation schedule deadlines.
Partial augmentation of traditional power utilizing photovoltaic solar panel arrays on the headworks
and operations building rooftops will be further analyzed during the detailed design phase after
loads, demand patterns, and roof orientation are better understood. Additional alternative energy
systems can be added in the future if prioritized and funded by County Council, and the electrical
systems will be designed to accept additional alternative energy input. The capital cost for rooftop
photovoltaic solar is estimated to be approximately $13,000 per kW of peak capacity.
Methane gas is generated at wastewater treatment plants using a process called anaerobic
digestion. The proposed WWTP is too small for anaerobic digestion to be economical; the design
flow to the Pahala WWTP is 190,000 gallons per day, and anaerobic digestion is only economically
attractive for WWTPs that treat at least 5 to 10 million gallons per day. In addition, the anaerobic
digestion process requires primary clarifiers as part of the liquid treatment process, but primary
clarifiers tend to be odorous in tropical climates, due to the relatively high wastewater
temperatures. The proposed alternative relies on natural treatment systems that require relatively
low energy input.
Small-scale wind generation systems require a high level of maintenance attention due to the
mechanical systems required to convert wind energy into electricity, and is not appropriate for a
small, remote wastewater treatment facility.
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Figure 4-14. Operations Building Preliminary Floor Plan
5-1
Preliminary Design of
Improvements
The following is a summary of the preliminary design for the proposed Pahala WWTP.
5.1 Site Plan
The existing parcel is an active macadamia nut tree orchard. The prevailing grade is in the north to
south direction at 5 to 10 percent slope. Approximately 14.9 acres of the land will be cleared for the
construction of the proposed facility. Figure 5-1 presents a preliminary site plan for the WWTP.
5.2 Process Schematic
Figure 5-2 presents the recommended facilities process schematic.
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5-2
Figure 5-1. Preliminary Site Plan
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Figure 5-2. Recommended Facility Process Schematic
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5.3 Design Criteria
Table 5-1 provides preliminary design criteria.
Table 5-1. Preliminary Design Criteria
Description Value
Influent flows:
• Average dry weather 190,000 gpd
• Peak day wet weather 662,000 gpd
• Peak hour wet weather 630 gpm
Influent characteristics
• BOD5 300 mg/L
• TSS 300 mg/L
Odor control – granular activated carbon
• Airflow rate 500 cfm
• H2S Inlet concentration 1-10 ppm
• H2S removal efficiency 99%
• Media type High-capacity carbon
• Vessel diameter 3 feet
• Vessel height 6 feet
• Minimum carbon quantity 570 lbs
• Minimum bed depth 3 feet
• Fan motor 2 hp
• Nominal inlet size 8 inches
Mechanical screens
• Number of units 2
• Type In-channel cylindrical
• Screen opening size 0.25 inch (6 mm)
• Maximum flow rate capacity Greater than 625 gpm each
• Screening washing Integral
• Screening compaction Integral
• Screening wash water flow 20 gpm
• Screening wash water pressure 50 psi
Bypass screen
• Type Manually-cleaned bar rack
• Bar spacing 1 inch
• Rake Interlocking with bars
Screenings receptacle
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Table 5-1. Preliminary Design Criteria continued
• Type 55-gallon drum or bags
• Screenings volume per million gallons treated 5 ft3/Mgal
• Estimated screenings quantity 1 ft3/day
• Disposal frequency 1/week
Influent flow metering
• Type Parshall flume
• Maximum flow capacity Greater than 630 gpm
• Minimum straight upstream channel section 20 times the throat width
Influent flow sampling Refrigerated automatic composite sampler
Lagoon cells
• Number of cells 4
• Maximum lagoon temperature 25ºC
• Minimum lagoon temperature 20ºC
• Freeboard 3 feet
• Working water depth 15 feet
• Allowance for sludge 3 feet
• Total water depth 18 feet
• Side slope 3(H) : 1(V)
• Working volume of lagoon 1 to 3 0.80 Mgal
• Working volume of lagoon 4 1.60 Mgal
Aerators
• Type Floating mechanical surface aerators
• Cell 1 aerators 30 hp (2 at 15 hp)
• Cell 2 aerator 15 hp
• Cell 3 aerator 10 hp
• Cell 4 aerator 5 hp aspirator style, floating ball cover for algae control
Constructed Wetland
• Water temperature 25 degrees C
• Aerated lagoon effluent nitrate-N concentration 19 mg/l
• Aerated lagoon effluent ammonia-N concentration 1 mg/l
• Constructed wetland effluent total N concentration 15.3 mg/l
• Total constructed wetland surface area 0.25 acres
• Flow path length 50 feet
• Hydraulic application width 200 feet
• Media depth 24 inches
• Media type Medium gravel, D10 = ¾ inch
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Table 5-1. Preliminary Design Criteria continued
• Media porosity 38 percent
• Percolation prevention system 60 mil high density polyethylene (HDPE) liner
• Vegetation Native Hawaiian reeds and/or rushes, species to be determined
Disinfection system
• Type UV
• Form Calcium hypochlorite tablets
• Design chlorine dose 10 mg/L
• Chlorine contact time 15 minutes minimum
Effluent flow metering
• Type Magnetic
Effluent sampler
• Type Refrigerated automatic composite
Effluent quality
• BOD5 Less than 30 mg/L monthly average
Less than 60 mg/L peak
• TSS Less than 30 mg/L monthly average
Less than 60 mg/L peak
Effluent management system
• Type Slow-rate land application groves
• Number 4
• Minimum depth 5 feet
• Design percolation rate 0.0095 inches per minute
• Design application rate 8 percent of percolation rate
• Distribution system Gated pipe
• Stormwater containment 100-year, 24-hour storm event
• Vegetation Native Hawaiian trees
Stormwater site management 10-year, 1-hour storm
5.4 Environmental Benefits
A well-designed and managed land treatment system limits wastewater application to rates to
minimize adverse impact to groundwater quality. The deep percolate from the SR land treatment
system is expected to contain less than 1 mg/L of BOD5 and TSS. While the State of Hawaii has not
adopted formal groundwater quality standards, the drinking water standard for nitrate (10 mg/L as
N) in the annual average deep percolate below the land treatment system was used as a
performance target to design the land treatment site. Phosphorus adsorption is excellent in SR land
treatment systems, and 99 percent or greater phosphorus removal is anticipated. Table 5-2
compares the current loads to the environment via the LCCs and the loads to the environment after
the proposed project is implemented via the deep percolate from the land treatment system. Figure
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5-7
5-3 provides a graphical representation of the environmental benefits of the proposed project
compared to the status quo.
Table 5-2. Environmental Benefits of Proposed Project
Parameter Current Annual Load to
Environment via LCCs
Annual Load to Environment
via Proposed Land Treatment
System Deep Percolate
Reduction
BOD5 174,000 lbs./year 600 lbs./year >99%
TSS 174,000 lbs./year 600 lbs./year >99%
Nitrogen 23,000 lbs./year 4,100 lbs./year 83%
Phosphorus 4,000 lbs./year 40 lbs./year >99%
Figure 5-3. Environmental Benefits of Proposed Project
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5.5 Cost Estimates
An order of magnitude probable construction is summarized in Table 5-3. The estimate includes a
25 percent estimating contingency. The detailed cost estimate is included as Appendix A.
Table 5-3. Pahala WWTP Order of Magnitude Construction Cost Estimate
Description Estimated Construction Cost
Electrical and instrumentation $1,976,000
Headworks $906,000
Odor Control $412,000
Lagoons $2,222,000
Constructed Wetland $611,000
Land Application $925,000
On-site improvements $6,325,000
Off-site improvements $1,223,000
Total Estimated Construction Cost $14,600,000
5.6 Future Expansion
5.6.1 Full Buildout Flows
Full buildout wastewater flow projections were developed using the Draft Ka’u Community
Development Plan (March 2015) and the CCH’s current (2017) wastewater standards. Table 5-4
summarizes the projected full buildout flows for the community, and Figure 2-1 shows the WWTP full
buildout service area.
Table 5-4. Pahala WWTP Full Buildout Flow Projections
Description Value Peaking Factor
Average dry weather flow 360,000 gallons per day 1.0
Peak day wet weather flow 1,260,000 gallons per day 3.5
Peak hour wet weather flow 1,200 gallons per minute 4.8
5.6.2 Improvements
To accommodate the flow increase anticipated from the full buildout of the Pahala wastewater
collection system, the WWTP will require facility upgrades. The recommended upgrades include
headworks and odor control expansion within the 14.9-acre site.
Additionally, the lagoon system will require modifications. Lagoon 1 will be converted to a complete
mix aerated lagoon environment to accommodate wastewater treatment needs. In a complete mix
aerated lagoon, sufficient mixing energy is provided to maintain the lagoon solids in suspension
always. A completely mixed aerated lagoon system performs as an activated sludge process without
solids recycle. The higher mixing energy, as compared to a partial mix lagoon, creates greater
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opportunity for contact between the naturally-occurring micro-organisms in the lagoon and dissolved
organic matter. As a result, complete mix lagoons provide greater levels of treatment within a
smaller volume than partial mix lagoons. However, facilities must be provided downstream of
complete mixed lagoons to allow removal of settleable solids from the water column. To provide a
place for solids settling, lagoons 2 through 4 will continue to act as partial mix aerated lagoons
downstream of the complete mix lagoon 1. Lagoon 4 will require no aeration and will continue to be
covered to deprive algae of sunlight and allow suspended solids to settle out of the system effluent.
Utilizing this lagoon system approach, the Pahala WWTP will require modifications at full buildout
flows, but is not anticipated to expand beyond the initial build 14.9 acres.
6-1
Implementation
Table 6-1 provides the implementation schedule for the WWTP. The LCCs will be closed following
connection of the existing sewer system to the WWTP.
Table 6-1. Implementation Schedule
Description Milestone
Complete design of WWTP September 18, 2019
Complete construction of WWTP May 20, 2021
Connect existing collection system to WWTP June 30, 2021
7-1
Alternative Treatment Options
Evaluation
Several other treatment alternatives were considered for the Pahala WWTP, as summarized below.
7.1 Option Descriptions
7.1.1 Option 1: Aerated Lagoons/Constructed Wetland/Land Application
Option 1 consists of an aerated lagoon treatment system with a constructed wetland and
disinfection, followed by land application for effluent management, as described previously
throughout this report. Figure 7-1 is a schematic diagram for Option 1.
Figure 7-1. Option 1 Schematic Diagram
7.1.2 Option 2: R-1 Treatment/Land Application
Option 2 consists of constructing a membrane bioreactor (MBR) or an activated sludge treatment
process followed by cloth media filtration, followed by UV disinfection, to produce recycled water that
meets DOH R-1 recycled water criteria. R-1 recycled water is effluent that has undergone oxidation,
filtration, and disinfection. R-1 is considered the highest grade of recycled water and can be used for
irrigation of golf courses, parks, schools, and all types of agricultural crops. The R-1 treatment
system would be followed by land application as per Option 1. Figure 7-2 is a schematic diagram for
Option 2.
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Figure 7-2. Option 2 Schematic Diagram
7.1.3 Option 3: R-1 Treatment/Seasonal Water Recycling
Option 3 consists of a treatment system similar to Option 2 to produce R-1 recycled water. The
recycled water would be used to irrigate nearby macadamia nut orchards. Figure 7-3 provides a
schematic diagram of Option 3.
Figure 7-3. Option 3 Schematic Diagram
A water recycling analysis was prepared to assess the potential seasonal demand for recycled water
produced by the WWTP. Figure 7-4 is an irrigation demand assessment for the Pahala area based
on published climate data. The graph shows precipitation, estimated evapotranspiration, and the
irrigation demand for each month of the year. As shown in the figure, irrigation is typically needed
from April through September, reaching a peak demand in June. The graph shows that no irrigation
is typically needed between October and March, because precipitation exceeds evaporation during
those months.
Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 7
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Figure 7-4. Irrigation Demand Assessment
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The potential demand for recycled water produced by the Pahala WWTP was assessed, as shown in
Figure 7-5. The WWTP could potentially provide irrigation water for approximately 62 acres, based
on the peak month irrigation demand in June. During June, all the recycled water produced by the
WWTP would be used on the 62 acres. During all other months the supply of recycled water will
typically exceed the demand, and the excess water would be land applied on the WWTP property as
per the previous alternatives.
Figure 7-5. Option 3 Recycled Water Demand Assessment
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The Pahala climate makes it possible to only recycle only about 25 percent of the annual flow in this
scenario, due to the long wet season and relatively low evapotranspiration rate during the dry
season. This is in stark contrast to the Kailua-Kona area on the leeward side of the island, where the
climate will allow approximately 88 percent of the recycled water produced at the Kealakehe WWTP
Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 7
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throughout the year to be recycled. Figure 7-6 provides a comparison of the irrigation demand in
Pahala with the irrigation demand at Kealakehe.
Figure 7-6. Comparison of Irrigation Demands at Pahala and Kealakehe
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7.1.4 Option 4: R-1 Treatment and Storage for 100% Water Recycling
Option 4 adds a seasonal storage reservoir, as shown schematically in Figure 7-7.
Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 7
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Figure 7-7. Option 4 Schematic Diagram
Implementation of a seasonal storage reservoir would make it possible to recycle 100 percent of the
R-1 water produced by the Pahala WWTP in a typical year. The seasonal storage reservoir would
make it possible to save recycled water produced during the wet season for use during the dry
season. An annual water balance was prepared to assess the seasonal storage reservoir needs for
the Pahala WWTP. Figure 7-8 provides a summary of the evaluation, and shows recycled water
supply, use, and storage throughout a typical year. As shown in the graph, peak storage of
approximately 40 million gallons (Mgal) would occur during April, and by August the storage reservoir
would be dry and ready for another wet season. Under this scenario it would be possible to irrigate
approximately 253 acres of macadamia nut trees. The lined, 20-foot-deep storage reservoir would
have a water surface area of approximately 7 acres.
Storage of recycled water is not without its challenges. Recycled water contains nutrients that allow
algae to grow. The algae can cause odors if stagnant water conditions are allowed to develop.
Recycled water that is stored in open reservoirs must often be re-treated to improve the water quality
characteristics. Recycled water reservoirs can be equipped with mixers to prevent stagnant water
conditions, and/or be equipped with floating covers to block the sunlight that fosters algal growth.
Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 7
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Figure 7-8. Seasonal Storage Reservoir Analysis
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Implementation of a seasonal storage reservoir and recycling program would not eliminate the need
for a land application system at the WWTP, as described previously. HAR 11-62 requires a disposal
system for all recycled water system, to provide a means for disposal of water that does not meet R-
1 standards or disposal of excess water should the seasonal storage reservoir capacity be exceeded
during an exceptionally wet year.
7.1.5 Option 5: Maximum Practical Treatment
Option 5 consist of implementing advanced wastewater treatment processes that represent
maximum practical treatment. The option is illustrated schematically in Figure 7-9. The process
treatment train consists of a 5-stage Bardenpho activated sludge treatment process, followed by
chemical addition and denitrifying filters to reliably reduce total nitrogen to less than 4 mg/L and
total phosphorus to less than 0.1 mg/L. The treatment processes would be followed by a
disinfection process to create R-1 recycled water. The recycled water produced would be used to
irrigate macadamia nut trees as per Option 3. A seasonal storage reservoir could also be
implemented at additional cost. A land application system would be required as per the previous
Options.
Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 7
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Figure 7-9. Option 5 Schematic Diagram
7.2 Cost Comparisons
Planning-level cost estimates were prepared for the five options, as described below.
7.2.1 Capital Costs
Table 7-1 summarizes the capital costs associated with the options described above. Additional
detail can be found in Appendix A. The capital costs shown in the table do not include costs
associated with collection system improvements or closure of the existing LCCs.
Table 7-1. Summary of Capital Cost Estimates
Option Name Estimated Capital Cost
1 Aerated lagoons/constructed wetland/land application $14.6 million
2 R-1 treatment/land application $18.4 million
3 R-1 treatment/seasonal water recycling $20.2 million
4 R-1 treatment and storage for 100% water recycling $30.4 million
5 Maximum practical treatment $26.0 million
Comparison of options 1 and 2 shows that providing R-1 treatment instead of the aerated lagoon
and wetland natural treatment system will increase the capital cost by approximately $3.8 million.
Option 3 shows that addition of water recycling to reuse approximately 25 percent of the annual flow
would add an additional $1.8 million in capital costs. Option 4 shows that constructing a seasonal
storage reservoir to recycle 100 percent of the flow would add an additional $10 million in capital
costs. Comparison of options 3 and 5 shows that providing maximum practical treatment instead of
normal R-1 treatment would add $5.8 million in capital costs.
7.2.2 Operation and Maintenance Costs
Operation and maintenance (O&M) costs include labor, electricity, chemicals, spare parts, sludge
management, and other costs required to operate and maintain the facility. Table 7-2 provides a
Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 7
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summary of the O&M cost estimates developed for the options. Additional details can be found in
Appendix A.
Table 7-2. Summary of O&M Cost Estimates
Option Name Estimated Annual O&M Cost
1 Aerated lagoons/constructed wetland/land application $236,000
2 R-1 treatment/land application $1,052,000
3 R-1 treatment/seasonal water recycling $1,055,000
4 R-1 treatment and storage for 100% water recycling $1,063,000
5 Maximum practical treatment $1,421,000
As shown in the table, option 1 incurs significantly lower O&M costs than the other options. The
significant cost differential is due to the simple aerated lagoon natural treatment system that
requires less labor, electricity, chemical, and maintenance that the other options.
7.2.3 Recycled Water Sale Proceeds
Options 3, 4, and 5 will produce a marketable product in the form of R-1 recycled water that could be
sold to users for irrigation purposes. The value of recycled water is a function of the value of the
water that it replaces. In general, recycled water is sold to users at a fraction of the price of the
water that is being replaced to provide a financial incentive to use the product. The typical recycled
water price is 25 percent to 90 percent of the water it replaces.
The Pahala WWTP will be located at elevation 750 feet MSL. The cost to pump groundwater from
the basal lens to the ground surface at the WWTP is approximately $1,078 per million gallons. Table
7-3 provides a summary of a recycled water sales assessment of each option, assuming the recycled
water is sold for 90 percent of the cost of the irrigation water it would replace. Additional detail is
provided in Appendix A.
Table 7-3. Summary of Annual Recycled Water Sale Proceeds
Option Name Annual Volume Recycled
(Mgal)
Maximum Annual
Sales Proceeds
1 Aerated lagoons/constructed wetland/land application 0 $0
2 R-1 treatment/land application 0 $0
3 R-1 treatment/seasonal water recycling 17 $17,000
4 R-1 treatment and storage for 100% water recycling 70 $68,000
5 Maximum practical treatment 17 $17,000
7.2.4 Life-Cycle Costs
Life-cycle costs represent the total costs to the community to construct and operate the wastewater
treatment system over a 30-year period. The life-cycle cost evaluation includes capital and O&M
costs, and recycled water sales proceeds as described above. In addition, equipment replacement
allowances are included after 20-years of operation. The life-cycle cost evaluation includes an
Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 7
7-9
inflationary factor to account for long-term changes in the value of money. The life-cycle costs are
expressed as the Net Present Value (NPV). The NPV represents the amount of money that the
County would need to set aside now in an interest-bearing account to cover all of the costs over the
defined life-cycle. Table 7-4 provide a summary of the life-cycle cost evaluation. Additional detail
can be found in Appendix A.
Table 7-4. Summary of Life-Cycle Cost Estimates
Option Name Estimated Life-Cycle Cost
1 Aerated lagoons/constructed wetland/land application $21.2 million
2 R-1 treatment/land application $43.0 million
3 R-1 treatment/seasonal water recycling $44.5 million
4 R-1 treatment and storage for 100% water recycling $54.0 million
5 Maximum practical treatment $59.0 million
As shown in the table, option 1 incurs the lowest life-cycle costs, and the other options would all
incur over double to nearly triple the cost over the 30-year life-cycle. The life-cycle cost estimates are
shown graphically in Figure 7-10. The operating costs shown in the figure include benefits (i.e., cost
reductions) from recycled water sales where applicable.
Figure 7-10. Life-Cycle Costs of Options
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Capital Costs Operating Costs
As shown in the graph, the operating cost differential between option 1 and the other options is the
leading contributor to the lower life-cycle cost of option 1. The major operating cost differences are
discussed below.
7.3 Non-Economic Discussion
The options are discussed on a non-economic basis below.
Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 7
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7.3.1 Labor Requirements
The Pahala WWTP will be operated by the COH DEM, Wastewater Division that is based in Hilo. The
Hilo-based WWTP operators will regularly visit to facility to check the system status, make
operational adjustments, and draw samples for required laboratory testing. In addition,
maintenance personnel will visit the WWTP as needed to conduct equipment and electrical system
repairs.
A major difference between option 1 and the other options is the frequency of routine operator visits
required, and the number of personnel routinely required. Option 1 will require a single operator to
normally visit the site once per week. The other options will require daily operator visits to conduct
sampling that is required for R-1 compliance. In addition, options 2 through 5 consist of mechanical
treatment technology that required more operator attention than option 1. Table 7-5 compares the
operational labor differences for the options, as expressed as full-time equivalents (FTEs).
Table 7-5. Comparison of Operational Labor Requirements
Option Name Estimated Operational Labor
Requirement (FTEs)
1 Aerated lagoons/constructed wetland/land application 0.3
2 R-1 treatment/land application 3.7
3 R-1 treatment/seasonal water recycling 3.7
4 R-1 treatment and storage for 100% water recycling 3.7
5 Maximum practical treatment 5.6
7.3.2 Operational Complexity
HAR 11-61 establishes operator certification requirements for WWTPs. The DOH requires that
certified operators operate municipal WWTPs. The larger and/or more complex the wastewater
treatment process, the higher grade of operator required at the facility. Options 1 through 5 were
evaluated for operator certification requirements based on the criteria established in HAR 11-61.
Table 7-6 summarizes the results of the evaluation. As shown in the table, option 1 would require a
Grade I operator, while the other options would require a Grade IV operator (the highest grade). The
higher requirements for options 2 through 5 are due to the complexity of the treatment processes
compared to option 1. In general, the County has difficulty attracting and retaining Grade IV
operators.
Table 7-6. Comparison of Operator Certification Requirements per HAR 11-61
Option Name Operator Certification Level Requirement
1 Aerated lagoons/constructed wetland/land application I
2 R-1 treatment/land application IV
3 R-1 treatment/seasonal water recycling IV
4 R-1 treatment and storage for 100% water recycling IV
5 Maximum practical treatment IV
Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 7
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7.3.3 Energy Consumption
Figure 7-11 provides a comparison of the electrical energy requirements of the five options. As
shown in the graph, option 1 will require significantly less electrical energy to operate, due to the use
of natural treatment systems (aerated lagoons) instead of mechanical treatment processes that
require more aeration and process pumping.
Figure 7-11. Comparison of Electrical Energy Requirements
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7.3.4 Sludge Management
Sludge management for Option 1 is significantly different than the other options. The partial-mix
aerated lagoon treatment system allows wastewater solids to accumulate at the bottom of the
lagoon, forming a sludge blanket that slowly anaerobically digests. Sludge removal is infrequent,
typically on the order once every 15 to 20 years. The resulting solids are well-digested and
inoffensive due to the long retention time in the lagoons.
Options 2 through 5 would require an aerobic digester to stabilize and store waste solids from the
activated sludge treatment process. The solids would need to be dewatered and trucked to a landfill
on a weekly basis.
7.4 Living Machine®
Living Machine® technology was suggested during community outreach meetings. Living Machine®
is a proprietary technology by Worrell Water Technologies that incorporates aerated tanks planted
with vegetation to provide an attractive wastewater treatment process. In colder climates the
aerated tanks are housed in a greenhouse for protection. In addition, subsurface flow wetlands with
continuous and/or batch flow can be included in the process to provide desired treatment.
The Living Machine® technology has been implemented in “green” buildings like the San Francisco
Public Utilities Commission building, the Port of Portland Headquarters, and others. Review of the
company’s website did not reveal any municipal projects completed on the scale of what would be
needed for Pahala. Therefore, the technology is considered to be not feasible.
Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 7
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It should be noted that the proposed non-proprietary treatment system (aerated lagoons and
subsurface flow wetland) uses essentially the same natural treatment processes as the Living
Machine®, but on a municipal scale.
7.5 Septic Tank Alternatives
A previous assessment recommended installation of a community septic tank and repurposing one
of the existing LCCs to serve as a seepage pit (SSFM, July 2007), in accordance with Alternative 1
proposed to the community by the County in 2004 (County of Hawaii, November 5, 2004). This and
other options that have been raised during the community outreach process that incorporate septic
tank technology are discussed below.
7.5.1 Community Septic Tank
The effectiveness of a septic tank is directly related to the amount of hydraulic detention time
provided by the tank volume. The previous study (SSFM, July 2007) suggested a 24-hour detention
time would be adequate. Applying the current flow projections for the project indicate a 190,000-
gallon tank would be appropriate if this criterion is used. However, for large community septic tanks
it has been found that longer detention times are needed to optimize treatment performance, avoid
the need for frequent septage pumping, and to account for peak flow rates that are developed by
community wastewater collection systems. Applying appropriate design criteria (Crites and
Tchobanoglous, 1998), to the project results in the need for an 800,000-gallon tank, which would
require pumping on a 3-year interval. The area required for an appropriately-sized community septic
tank would be approximately ¼ acre.
The use of a community septic tank would require the DOH to issue a variance to HAR 11-62, which
requires WWTPs with design capacities greater than 100,000 gallons per day to produce effluent
containing less than 30 mg/L of both BOD5 and TSS – septic tanks are not able to produce effluent
of this quality. A secondary treatment process is needed to comply with the effluent quality
requirements contained in the DOH regulations. The County would need to reapply for the variance
every 5-years, and if not renewed then secondary treatment would need to be provided.
Additionally, odors from a community septic tank present a significant concern. A septic tank is an
anaerobic treatment process that produces hydrogen sulfide, reduced sulfur compounds, and other
odorous gases. Odors emanating from septic tanks at individual residences are typically dispersed
to the atmosphere throughout the community via the household plumbing roof vents. A community
septic tank would concentrate the community’s emissions to a single point source that would require
foul air collection and treatment to avoid nuisance odor conditions. A dual-stage scrubber capable of
treating approximately 3,600 cubic feet per minute of foul air would be required to avoid nuisance
odor conditions. The dual-stage scrubber would consist of a biotrickling filter, followed by a granular
activated scrubber.
7.5.2 Converting LCC to Seepage Pit
A previous study (SSFM, July 2007) suggested that the existing LCC located on the County-owned
parcel TMK 9-6-002:024 could be converted to a seepage pit that would be regulated by DOH as an
injection well. HAR 11-23-07 allows injection wells located mauka of the UIC line that were in
existence prior to July 6, 1984 to continue to operate. However, the flow to the wells cannot
increase, nor can a new well be constructed. Therefore, the earlier plan to convert the existing LCC
to a seepage pit is not feasible for the following reasons:
• Closing LCC No. 2 that is located on private property would not be allowed, as it would
increase the flow to LCC No. 1 (converted to a seepage pit that is regulated as an injection
well) that is located on County property.
Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 7
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• The capacity, structure, and condition of the existing LCC No. 1 is not known. The LCC could
either be a lava tube or a large conventional cesspool. A geotechnical investigation
conducted on the site to depths of 30 to 35 feet did not reveal the presence of lava tubes
(Masa Fujioka & Associates, January 9, 2007), therefore it is likely a large conventional
cesspool. The County attempted to determine the structure and condition of the LCC via
closed circuit TV inspection, but could not ascertain either due to technological limitations. It
is not known if the LCC could accommodate the flow from the existing service area if LCC No.
2 is closed.
• HAR 11-62-25 requires new and proposed effluent disposal systems to have a backup
disposal system capable of handling the peak flow. A second seepage pit cannot be
constructed to comply with the regulatory requirement because the site is located mauka of
the UIC line. If the existing seepage pit were to fail then a replacement cannot be
constructed.
• The Kau Community Development Plan requires the County to provide for eventual
construction of sewers throughout the community. Providing sewers for the entire
community will increase wastewater flows considerably, as presented in Section 5.
Increasing flow to the existing LCC (converted to a seepage pit) would not be allowed.
Therefore, the use of the existing LCC as a disposal system could prevent the County from
providing the community’s desired future wastewater needs.
For these reasons, converting the existing LCC to a seepage pit is considered to be not feasible.
7.5.3 Leachfield Disposal
Leachfields are effluent disposal systems consisting of buried gravel-filled absorption trenches.
Significant treatment occurs as septic tank effluent percolates through the soil surrounding the
leachfield trenches. Leachfields are an integral part of residential septic systems, and DOH has
established trench design criteria applicable to both residential and municipal-scale leachfields. In
particular, HAR 11-62-34 requires trenches to be sized based on bottom area only. Application of
the DOH criteria to the project yields a need for at least 30 acres of land to satisfy DOH hydraulic
loading rate and redundancy requirements. Achieving even distribution of effluent over a leachfield
of this size would be challenging at best. Therefore, leachfield disposal for the project is considered
to be not feasible.
7.5.4 Conversion to Individual Wastewater Systems
The concept of a community wastewater system could be abandoned and all houses be required to
construct individual wastewater systems comprised of a septic tank and leachfield. However, many
of the lots in the community are small (less than 10,000 square feet) and significantly improved,
making the feasibility of constructing individual wastewater systems on every lot uncertain. HAR 11-
62-34 allows construction of seepage pits where there is insufficient land area to install absorption
trenches (i.e., a leachfield), but prohibits construction in soils having percolation rates slower than
10 minutes per inch or where rapid percolation through such soils may result in contamination of
water-bearing formations. The soils in the community are classified as Puueo-Naalehu complex, 3 to
10 percent slopes in the National Resource Conservation Service soil survey. This soil type consists
of approximately 18 inches of extremely cobbly medial silt loam over cobbles and bedrock. This soil
profile is too thin for conventional soil absorption trenches, so residents with sufficient space would
be required to import fill soil to create elevated mound systems in accordance with HAR 11-62-34 to
achieve adequate soil depth. Residents without sufficient space could potentially install seepage
pits if suitable subsurface geology could be located. However, previous subsurface investigations in
the community (Masa Fujioka & Associates, January 9, 2007, and Geolabs-Hawaii, September 23,
Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 7
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1998) revealed extremely permeable clinker layers and numerous lava tubes, both of which would
not meet HAR 11-62-34 requirements for seepage pits. For these reasons, conversion to individual
wastewater systems is considered to be not feasible.
7.5.5 Gray Water Systems/Composting Toilets
The DOH has published guidelines for the reuse of gray water (DOH, June 22, 2009). The DOH
defines black water as wastewater discharged from toilets and urinals and kitchen sinks. Gray
water is defined as wastewater discharged from showers and bathtubs, lavatories, wastewater that
has not contacted toilet waste, sinks not used for food preparation.
Composting toilets are a type of dry toilet that treats human excreta by a biological process called
composting. The process leads to the decomposition of organic matter and turns the human
excreta into a compost-like material but does not destroy all pathogens. Composting toilets do not
require a connection to a septic tank or sewer system (Wikipedia).
The combination of a gray water system and composting toilet cannot replace an individual
wastewater system or a sewer connection, because black water from the kitchen sink in a residence
requires either an individual wastewater system or sewer connection.
7.6 Package Plant
Package plants are commercially-available prefabricated wastewater treatment plants. Package
plants are commonly used for small WWTPs with capacity requirements less than 250,000 gallons
per day. Package plants are generally based on the extended aeration activated sludge process.
Use of a package plant in lieu of aerated lagoons at Pahala could potentially save some capital cost
but would require daily visits by WWTP operators to monitor and adjust the process, and to waste
sludge. In addition, weekly or bi-weekly sludge dewatering and disposal would be required. The
results of an economic analysis of a package plant alternative for Pahala are:
• Capital cost: $12.6 million
• Annual O&M cost: $1.1 million
• Life-cycle cost: $37 million.
Comparison of these values to the results shown in Tables 7-1, 7-2, and 7-4 show that a package
plant at Pahala would incur significantly higher life-cycle costs compared to the recommended
aerated lagoon approach.
8-1
Alternative Site Evaluation
Nine sites were evaluated as potential locations for the Pahala WWTP. Each site was assessed for
twenty-one criteria, in four broad categories: environmental, social and cultural; location and site;
land use and availability; and collection system and service area.
8.1 Methodology
The site evaluation was performed according to the following process:
1. Potential sites for the Pahala WWTP were initially identified by the Department of
Environmental Management. Additional sites were identified based on feedback from the
Pahala community obtained during Community Outreach meetings that took place in
December 2017.
2. Four general categories and twenty-one criteria were established and defined for the
analysis.
3. Six “fatal flaw” conditions were identified. Sites with a fatal flaw were eliminated from
further consideration.
4. Relative weighting factors were established for each category and criteria.
5. Sites were mapped using GIS. Data such as soil type, location of subsurface and surface
water, topography, zoning and prevailing wind direction were determined.
6. Each site was evaluated and scored for the twenty-one criteria.
7. A weighted ranking was determined for each site, based on the weighting factors established
in Step 4.
8. A preferred site was identified, based on the weighted high score.
8.2 Site Locations
Ownership, location, and proximity to the existing LCCs for all siting alternatives considered is
illustrated in Figure 8-1.
Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 8
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Figure 8-1. Pahala Site Alternatives
Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 8
8-3
8.3 Criteria
The criteria used for the analysis are presented for each of four categories in Tables 8-1, 8-2, 8-3
and 8-4. A score was assigned to each criterion based on definitions included in the tables. A score
of five represents a preferred or positive condition, and a score of one a less preferred or negative
condition. A score of zero indicates a fatal flaw; six fatal flaw conditions were identified during the
analysis are identified in the corresponding table.
Table 8-1 outlines the environmental, social, and cultural criteria considered in the analysis.
Table 8-1. Environmental, Social and Cultural Criteria
Criteria Scoring and Definitions
5 4 3 2 1 0 = Fatal Flaw
Presence of or proximity to
archaeological/cultural sites
No known or
suspected sites
Confirmed or
suspected sites and mitigatable
No information
available
Suspected sites
and mitigation ability unknown
Confirmed sites
and mitigation ability unknown
Confirmed sites
and unmitigatable
Proximity of treatment
units to existing occupied buildings
More than 1000
ft. from any occupied building
Between 50 and
1000 ft. from non-school building
Between 50 and
1000 ft. of school
Less than 50 ft
from any occupied building
Prevailing wind direction Site is downwind
of most of the community
Site is central Site is upwind of
most of the community
Biology Endangered or
threatened species not present
Presence of
endangered or threatened species unknown
Endangered or
threatened species known to be present
Endangered or
threatened species known to be present and unmitigatable
Visual impact Natural visual mitigation (hill, berm,
vegetation, remoteness) exists
Visible location, mitigatable with trees or other
engineered buffers
Visible location, unmitigatable
Contamination from prior land use
No suspected
industry-related contamination issues
Presence of
contamination unknown
Suspected or
confirmed contamination issues
Previously disturbed or developed Yes Partial No previous development or disturbance
The circumstance where a cultural or historical site is known to exist within the treatment facility
footprint and mitigation to relocate, protect, or preserve that site is not possible, was identified as a
fatal flaw condition.
From an environmental perspective, the presence of endangered or threatened species was
considered negative. A site previously disturbed or developed was viewed as positive, unless
contamination from a previous land use was suspected.
Considerations specific to social impact include proximity to occupied buildings (including
residences, school, commercial establishments and others), prevailing wind direction, and visual
impact.
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Table 8-2 outlines the location and site characteristics considered in the analysis.
Table 8-2. Location and Site Characteristics
Criteria Scoring and Definitions
5 4 3 2 1 0 = Fatal Flaw
Parcel size More than 14.9 acres Less than 14.9 acres
Soils type Good soil and in sufficient amounts in area of parcel useable for disposal
Good soil but over limited area and disposal modification required
Marginal soil in area of parcel useable for disposal
No soil in area of parcel useable for disposal
Topography Gentle slopes (less than 8%) Moderate slopes (8% - 18%) or localized high/low points
Steep slopes (18% - 20%) Extreme slopes (greater than 20%)
Proximity to water well Outside of both 1000 ft. radius and upgradient
influence zone of any well
Outside of 1000 ft. but suspected within
upgradient influence zone of non-potable well
Within 1000 ft. or within upgradient
influence zone of non-potable well
Within 1000 ft. or within upgradient influence zone of potable well
Presence of lava tubes None Possible or
unknown
Known
Proximity to surface water, intermittent stream or
coast line
Treatment and disposal more
than 500 ft. away
Treatment and disposal
between 50 to 500 ft.
Treatment and disposal less
than 50 ft. away
Flood control / drainage No risk of flooding Flood risk unknown Prone to flooding or within flood
zone
Vehicle access Vehicle access currently exists Existing easement, but
new road or significant road upgrades required in or via
county/private right if way
Existing easement, but
new road or significant road upgrades required in or via
state right-of-way
No current vehicle access or
easement, access legally restricted, or significant
obstruction to access
Power and potable water
availability
Utilities currently
available at property line and within 400 ft. of site, no new easement required, no
known significant obstructions (i.e. - culverts,
streams, cultural sites)
Utilities
available within 400 yds. of property or unknown
Potable water
and/or power not currently available within 400 yds. of property and/or significant
obstruction to utility construction
Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 8
8-5
Three fatal flaw conditions were identified for the location and site characteristics category in Table
8-2:
• Sites less than 14.9 acres in size, which is the least amount of land needed for treatment,
disposal, and future growth.
• Average slopes greater than 20 percent, which significantly increase the cost of construction
and limit design options.
• Location within a 1000-foot radius surrounding a potable water well, which is prohibited by
HAR 11-62 for the protection of drinking water in the State of Hawaii.
Table 8-3 outlines the collection system and service area characteristics considered in the analysis.
Table 8-3. Collection System and Service Area Criteria
Criteria Scoring and Definitions
5 4 3 2 1
Distance from LCC collection area Parcel is adjacent to existing LCC or less than 0.25 miles away
Parcel is 0.25-0.5 mile away from existing LCC
Parcel is 0.5-1.0 miles away from existing LCC
Parcel is 1.0 – 1.5 miles away from existing LCC
Parcel is more than 1.5 miles away from existing LCC
Gravity flow possible or pumping required Gravity flow possible Pumping required for wastewater transmission from
collection area to site
Number of properties newly
accessible
Commercial areas
become accessible
Additional
individual residential properties become accessible outside of LCC service area
No additional
properties become accessible
A site location requiring large transmission distances of more than two miles are less preferable due
to both initial capital cost and future operations and maintenance requirements. Similarly, sites
where wastewater can flow via gravity from the collection area are preferable to those requiring a
pump station.
Newly accessible refers to properties within the service area that are not currently connected to the
LCC, but will become accessible to the County-owned sewer system when the collection lines are
relocated into the roadways fronting the property. Hawaii County Code requires connection of these
properties once the new collection system is constructed, and their individual wastewater systems
(cesspools or septic tanks) properly removed from service. All individual cesspools in the State of
Hawaii must be converted or closed by the year 2050.
Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 8
8-6
Table 8-4 outlines the land use and availability characteristics considered in the analysis.
Table 8-4. Land Use and Availability Criteria
Criteria Scoring and Definitions
5 4 3 2 1
Current zoning and land use WWTP currently permitted in zoning without Special Permit
WWTP possible onsite Special Permit required
WWTP not recommended on site
Land availability Owner willing and able to sell or land currently
government (state, county) owned
Subdivision required or friendly condemnation
required
Difficult or lengthy approval process expected or owner
willingness to sell unknown
Owner unwilling to sell or unfriendly condemnation of
land required (private corporate owner)
Owner unwilling to sell or unfriendly condemnation
required (private family owner)
Although public facilities are permitted in any zoning in the County of Hawaii, construction of a
wastewater treatment facility requires a Special Permit within some zones. No fatal flaws were
identified for the land use and availability category.
Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 8
8-7
8.4 Criteria Weighting Factors
To consider the relative importance to the categories and criteria, each was assigned a weighting
factor for the analysis. Weighting allows for appropriate consideration of all factors - both the
technical and non-technical - associated with siting. Relative weighting is summarized in Table 8-5.
Table 8-5. Relative Weighting Factors
Category Category Weight Criteria Criteria Weight
Environmental, social and cultural 35% Presence of and/or proximity to archaeological/cultural sites 25%
Proximity of treatment units to existing occupied buildings 25%
Prevailing wind direction 25%
Biology 10%
Visual impact 5%
Contamination from prior land use 5%
Previously disturbed or developed 5%
100%
Location and site characteristics 35% Parcel size 25%
Soils type 25%
Topography 15%
Proximity to water well 10%
Presence of lava tubes 8%
Proximity to surface water, intermittent stream or coast line 6%
Flood control / drainage 5%
Existing vehicle access 3%
Power and potable water availability 3%
100%
Collection system and service area 20% Distance from LCC collection area 50%
Gravity flow possible or pumping required 30%
Number of properties newly accessible 20%
100%
Land use and availability 10% Current ownership 55%
Current zoning and land use 45%
100%
Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 8
8-8
8.5 Raw Scores
For the nine sites identified in Figure 8-1, raw scores were assigned for each of the twenty-one
criteria according to the definitions in Section 8.3. The results are presented in Table 8-6.
Table 8-6. Alternatives Analysis – Raw Scores
Category Criteria Site Raw Score
1 2 3 4 5 6 7 8 9
Environmental, social and cultural
Presence of and/or proximity to archaeological/cultural sites 5 1 2 3 3 3 4 3 3
Proximity of treatment units to existing occupied buildings 3 3 5 5 5 5 5 5 5
Prevailing wind direction 5 5 5 5 5 5 5 5 5
Biology 3 3 3 3 3 3 3 3 3
Visual impact 3 3 3 5 5 5 3 3 3
Contamination from prior land use 3 1 3 1 3 3 3 3 3
Previously disturbed or developed 5 5 5 3 3 3 5 5 5
Location and site characteristics
Parcel size a 0 5 0 5 5 5 5 5 5
Soils type 5 1 1 3 5 1 5 5 5
Topography 3 5 3 5 3 5 3 3 5
Proximity to water well b 0 5 5 3 5 5 5 5 5
Presence of lava tubes 1 1 3 3 3 3 3 3 3
Proximity to surface water, intermittent stream or coast line 5 5 5 5 3 5 5 1 5
Flood control / drainage 3 3 3 3 3 1 3 3 3
Existing vehicle access 5 5 2 2 2 5 5 5 2
Power and potable water availability 3 3 3 1 1 1 3 3 1
Collection system and service area
Distance from LCC collection area 5 5 4 3 3 2 5 4 3
Gravity flow possible or pumping required 5 5 5 5 1 1 5 5 5
Number of properties newly accessible 3 3 3 3 3 3 3 3 3
Land use and availability Current zoning and land use 3 3 3 3 3 3 3 3 3
Current ownership 5 5 3 3 5 5 4 4 4
Raw score totals (maximum possible = 105) FF 75 FF 72 72 72 85 79 79
a Fatal flaw condition for Sites 1 and 3.
b Fatal flaw condition for Site 1.
As indicated in Table 8-6, fatal flaw conditions were identified for Site 1 (due to both parcel size and
proximity to a drinking water well) and Site 3 (due to parcel size). These two sites were removed
from further analysis.
Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 8
8-9
8.6 Weighted Analysis
The weighted analysis is presented in Table 8-7.
Table 8-7. Alternatives Analysis – Weighted Scoring
Category Criteria Site Weighted Score
1 2 3 4 5 6 7 8 9
Environmental, social and cultural
Presence of and/or proximity to archaeological/cultural sites 0.25 0.75 0.75 0.75 1.00 0.75 0.75
Proximity of treatment units to existing occupied buildings 0.75 1.25 1.25 1.25 1.25 1.25 1.25
Prevailing wind direction 1.25 1.25 1.25 1.25 1.25 1.25 1.25
Biology 0.30 0.30 0.30 0.30 0.30 0.30 0.30
Visual impact 0.15 0.25 0.25 0.25 0.15 0.15 0.15
Contamination from prior land use 0.05 0.05 0.15 0.15 0.15 0.15 0.15
Previously disturbed or developed 0.25 0.15 0.15 0.15 0.25 0.25 0.25
Location and site characteristics
Parcel size a 1.25 1.25 1.25 1.25 1.25 1.25 1.25
Soils type 0.25 0.75 1.25 0.25 1.25 1.25 1.25
Topography 0.75 0.75 0.45 0.75 0.45 0.45 0.75
Proximity to water well b 0.50 0.30 0.50 0.50 0.50 0.50 0.50
Presence of lava tubes 0.08 0.24 0.24 0.24 0.24 0.24 0.24
Proximity to surface water, intermittent stream or coast line 0.30 0.30 0.18 0.30 0.30 0.18 0.30
Flood control / drainage 0.15 0.15 0.15 0.05 0.15 0.15 0.15
Existing vehicle access 0.15 0.06 0.06 0.15 0.15 0.15 0.06
Power and potable water availability 0.09 0.03 0.03 0.03 0.09 0.09 0.03
Collection system and service area
Distance from LCC collection area 2.50 1.50 1.50 1.00 2.50 2.00 1.50
Gravity flow possible or pumping required 1.50 1.50 0.30 0.30 1.50 1.50 1.50
Number of properties newly accessible 0.60 0.60 0.60 0.60 0.60 0.60 0.60
Land use and availability
Current zoning and land use 1.35 1.35 1.35 1.35 1.35 1.35 1.35
Current ownership 2.75 1.65 2.75 2.75 2.20 2.20 2.20
Overall weighted totals (maximum possible = 5) FF 3.61 FF 3.76 3.76 3.46 4.33 4.06 4.10
a Fatal flaw condition for Sites 1 and 3.
b Fatal flaw condition for Site 1.
Pahala Wastewater Treatment Plant Preliminary Engineering Report Section 8
8-10
8.7 Results
The results of the analysis are presented in Table 8-8. Two sites were identified as having fatal flaws
and the remaining seven were ranked in accordance with the overall weighted score.
Table 8-8. Alternative Site Ranking
Rank Site
1 7
2 9
3 8
4 5
5 4
6 2
7 6
FF 1
FF 3
The top three sites for the Pahala WWTP are:
1. Site 7 (TMK 9-6-002:18)
2. Site 9 (TMK 9-6-002:49)
3. Site 8 (TMK 9-6-002:21)
Site 7 is preferred to the second and third ranked sites for the following reasons:
• A preliminary Archaeological Inventory Survey has been performed for Site 7, indicating no
unmitigable cultural sites on the property.
• Site 8 is bisected by an intermittent stream bed, and a steep gulch borders the property to
the west.
• Site 7 is closer to the existing collection area than both Site 8 and Site 9.
• Power and potable water are more readily available to Site 7. Site 9 will require the utilities
to cross the highway.
8.8 Conclusion
Based on the analysis, Site 7 (TMK 9-6-002:18) was selected as the preferred location for the
Pahala WWTP.
9-1
References
CH2MHILL. Kau High School and Pahala Elementary School Connection to County Sewer. July 2017.
County of Hawaii. Letter to Community Homeowners, signed by Mayor Harry Kim. November 5, 2004.
Crites, Ron, and George Tchobanoglous. Small and Decentralized Wastewater Management Systems. WCB McGraw-Hill, 1998.
Crites, Ronald W., E. Joe Middlebrooks, Robert K. Bastian, and Sherwood C. Reed. “Natural Wastewater Treatment
Systems, Second Edition”. CRC Press, 2014.
Crites, Ronald W., E. Joe Middlebrooks, Sherwood C. Reed. Natural Wastewater Treatment Systems. CRC Taylor & Francis, 2006.
Crites, Ronald W., Sherwood C. Reed, and Robert K. Bastian. “Land Treatment Systems for Municipal and Industrial
Wastes”. McGraw-Hill, 2000.
Department of Planning, County of Hawaii. Kau Community Development Plan. October 2017.
Department of Wastewater Management, City and County of Honolulu, State of Hawaii. Design Standards of the Department of Wastewater Management, Volume 1 and 2. July 2017.
Great Lakes – Upper Mississippi River Board of State and Provincial Public Health and Environmental Managers.
Recommended Standards for Wastewater Facilities. 1997.
Hawaii Administrative Rules (HAR), Title 11, Department of Health Administrative Rules.
Masa Fujioka & Associates. Letter Report, Probing for Large Cavities (Lava Tubes), Naalehu and Pahala Large
Capacity Cesspool Sewerage System. January 9, 2007.
M&E Pacific, Inc. Kau Sewer System Evaluation, Kau, Island of Hawaii, Hawaii. December 2004.
Reed, Sherwood C., Ronald W. Crites, E. Joe Middlebrooks. Natural Systems for Waste Management and Treatment. McGraw-Hill, Inc. 1995.
Rich, Linvil G. High Performance Aerated Lagoon Systems. American Academy of Environmental Engineers, 1999.
SSFM International, Inc. Final Preliminary Engineering Report for Naalehu and Pahala Large Capacity Cesspool
Conversion Projects, July 2007.
USEPA. “Process Design Manual, Land Treatment of Municipal Wastewater Effluents”. EPA/625/R-06/016. September 2006.
Water Environment Federation. Wastewater Disinfection, Manual of Practice FD-10. Water Environment Federation,
1996.
Water Pollution Control Federation. Aeration, Manual of Practice FD-13. 1988.
White, George Clifford, Handbook of Chlorination and Alternative Disinfectants, John Wiley & Sons Inc., New York,
1999.
Pahala Wastewater Treatment Plant Preliminary Engineering Report
A-1
Cost Estimates
County of Hawaii Department of Environmental Management
Pahala WWTP
Preliminary Design - Order of Magnitude Construction Cost
Electrical and instrumentation 1,976,000$
Headworks 906,000$
Odor Control 412,000$
Lagoons 2,222,000$
Wetland 611,000$
Land Application 925,000$
On-site improvements 6,325,000$
Off-site improvements 1,223,000$
Total Estimated Construction Cost 14,600,000$
Description Quantity Units Unit Cost Extension
Clear and grub 18.0 AC $5,995 $107,910
BMP's 18.0 AC $13,080 $235,440
Archaeological Monitoring 18 AC $2,507 $45,126
Earthwork 52,000 CY $25 $1,300,000
Sewerline extension 700 LF $218 $152,600
Operations building 1,500 SF $500 $750,000
Generator and tank 1 LS $250,000 $250,000
Fencing 3,200 LF $164 $523,200
Paving 38,000 SY $55 $2,071,000
Off-site waterline 2,500 LF $327 $817,500
On-site waterline 900 LF $164 $147,150
On-site fireline 750 LF $218 $163,500
Off-site overhead electrical 1 LS $50,000 $50,000
Trees (landscaping & Irrigation)10 EA $2,500 $25,000
Headworks 1 EA $501,339 $501,339
Odor control unit 1 EA $329,797 $329,797
Lagoons 1 LS $1,816,902 $1,816,902
Constructed Wetland 1 LS $489,000 $489,000
Chlorine contact tank 1 LS $150,000 $150,000
Chlorine feed system 1 LS $26,577 $26,577
Land Application piping 2,700 LF $125 $337,500
Land Application trees/ground cover 5.5 AC $5,000 $27,500
Effluent flow meter and sampler 1 LS $154,780 $154,780
$10,472,000
15%$1,570,800
1.0%$104,720
$12,148,000
20%$2,430,000
$14,600,000.00TOTAL ORDER OF MAGNITUDE CONSTRUCTION COST
Subtotal
On-site electrical
Mobilization/Demoblization
Total
Contingency
A-2
A-3
County of Hawaii Department of Environmental Management
Pahala WWTP
Preliminary Options Assessment - Capital Costs
Wetlands
Description Quantity Units Unit Cost Extension
linear 13,100 SF $4 $52,400
gravel 1,000 CY $50 $50,000
piping 500 LF $100 $50,000
Effluent Structure 1 EA $50,000 $50,000
Standpipe 1 EA $25,000 $25,000
plantings 13,100 sf $20 $262,000
$489,000 Subtotal
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A-4
Common Capital Inputs
Current ENRCCI:10870
Area markup factor:30%
Contingency factor:20%
Project soft costs factor:25%
Lagoon-Wetland Treatment
Description Quantity Units Unit Cost Extension
Clear and grub 8 AC $15,000 $120,000
BMPs 8 AC $13,000 $104,000
Earthwork 9,500 CY $25 $237,500
Sewer extension 700 LF $160 $112,000
Headworks 1 EA $500,000 $500,000
Lagoons 1 LS $1,800,000 $1,800,000
Wetlands 1 LS $350,000 $350,000
Chlorine contact tank 1 LS $100,000 $100,000
Chlorine feed system 1 LS $30,000 $30,000
Operations building 1,500 SF $500 $750,000
Generator and tank 1 LS $250,000 $250,000
Fencing 1,500 LF $100 $150,000
Paving 15,000 SY $55 $825,000
Water line extension 1,500 LF $160 $240,000
Yard piping 1 LS $200,000 $200,000
Miscellaneous site work 1 LS 100,000 $100,000
HELCO power 1 LS 50,000 $50,000
Hawaiian Telcom 1 LS 20,000 $20,000
Archeological monitoring 8 AC 2,500 $20,000
Visual buffer trees and irrigation 10 EA 2,500 $25,000
Subtotal $5,983,500
Electrical and instrumentation 20% $1,196,700
Total construction $7,180,200
Contingency $1,436,040
Total construction $8,616,240
Project soft costs $2,154,060
Total project cost:$10.770 million
Land Application
Description Quantity Units Unit Cost Extension
Clear and grub 6 AC $15,000 $82,500
BMPs 6 AC $13,000 $71,500
Earthwork 33,500 CY $25 $837,500
Fencing 1,700 LF $100 $170,000
Paving 23,000 SY $30 $690,000
Yard piping 3,500 LF $160 $560,000
Planting 6 AC 10,000 $60,000
Effluent flow meter and sampler 1 LS 50,000 $50,000
Archeological monitoring 6 AC 2,500 $15,000
Subtotal $2,536,500
Electrical and instrumentation 0%$0
Total construction $2,536,500
Contingency $507,300
Total construction $3,043,800
Project soft costs $760,950
Total project cost:$3.805 million
County of Hawaii Department of Environmental Management
Pahala WWTP
Preliminary Options Assessment - Capital Costs
A-5
R-1 Treatment
Capacity:0.19 mgd
Mainland cost at current ENRCCI:$39.44 /gpd from R-1 WWRF capital regression. y=24.003*(x^-0.299)
Local construction cost:$51.27 /gpd
Construction estimate:$9.7 million
Contingency:$1.9 million
Total construction cost:$11.7 million
Project soft costs:$2.9 million
Total project cost:$14.6 million
Limit of Treatment Technology
ENRCCI of estimate:8952
10 mgd WWTP cost:$13.80 /gpd
10 mgd WWTP cost at current ENRCCI:$16.76 /gpd
Local 10 mgd WWTP cost:$21.78 /gpd
Small flow escalation:$71.54 /gpd y=43.47x^-0.3 Per WERF analysis. BNR + advanced nutrient removal
Construction estimate:$13.6 million
Contingency:$2.7 million
Total construction cost:$16.3 million
Project soft costs:$4.1 million
Total project cost:$20.4 million
Seasonal Storage Reservoir
Volume:124 ac-ft
Mainland construction cost:$25,000 /ac-ft
Subtotal:$3.1 million
Local construction cost:$4.0 million
Contingency:$0.8 million
Total construction cost:$4.8 million
Project soft costs:$1.2 million
Total project cost:$6.1 million
Diurnal R-1 Tank - Seasonal Program
Volume:0.19 mgal 1 peak day
Local construction cost:$3.00 /gallon
Subtotal:$0.6 million
Contingency:$0.1 million
Total construction cost:$0.7 million
Project soft costs:$0.1 million
Total project cost:$0.8 million
Diurnal R-1 Tank - Reservoir Program
Volume:0.77 mgal 1 peak day
Local construction cost:$3.00 /gallon
Subtotal:$2.3 million
Contingency:$0.5 million
Total construction cost:$2.8 million
Project soft costs:$0.69 million
Total project cost:$3.5 million
A-6
R-1 Delivery Pumps - Seasonal Program
Peak day flow 0.19 mgal
Delivery time:8 hours
Pumping capacity:396 gpm
Mainland construction cost @ ENRCCI 4500:$100,000
Current mainland construction cost:$242,000
Local construction cost:$315,000
Contingency:$63,000
Total construction cost:$378,000
Project soft costs:$94,500
Total project cost:$0.5 million
R-1 Delivery Pumps - Reservoir Storage
Peak day flow 0.77 mgal
Delivery time:8 hours
Pumping capacity:1604 gpm
Mainland construction cost @ ENRCCI 4500:$200,000
Current mainland construction cost:$483,000
Local construction cost:$628,000
Contingency:$125,600
Total construction cost:$753,600
Project soft costs:$188,400
Total project cost:$1.0 million
R-1 Pipelines - Seasonal Program
Peak delivery rate:396 gpm
Pipeline diameter:6 inches
Hawaii construction cost:$25 /in-ft
Estimated length:2000 feet
Local construction cost:$300,000
Contingency:$60,000
Total construction cost:$360,000
Project soft costs:$90,000
Total project cost:$0.5 million
R-1 Pipelines - Reservoir Storage
Peak delivery rate:1604 gpm
Pipeline diameter:10 inches
Hawaii construction cost:$25 /in-ft
Estimated length:4000 feet
Local construction cost:$1,000,000
Contingency:$200,000
Total construction cost:$1,200,000
Project soft costs:$300,000
Total project cost:$1.5 million
A-7
Common O&M Inputs
Labor cost:$100 /hr (loaded)
FTE effective labor:1,560 hours/year
Chlorine tab cost:$4 /lb
Alum cost:$2 /lb
Electricity cost:$0.35 /kWh
Maintenance cost:2%/year of equipment capital
Sludge management cost:$1,500 /dry ton, dewatering, hauling, tip fee
Average flow:0.19 mgd
Lagoon Treatment/Wetlands/Disinfection
Labor
Normal requirement:1 visit/week
Operators/visit:1
Time per visit:8 hours/visit
Weekly labor hours:8 hours/week
Annual labor hours:416 hours/year
FTEs:0.3 FTEs
Annual labor cost:$41,600 /yr
Electricity
Load Equiv hp Percent kWhr/mo $/month
Aerators 50 100%26,845 $9,396
Screens 2 10%107 $38
Chlorine pumps 0.5 30%81 $28
Effluent pumps 2 100%1,074 $376
Totals $9,837
Annual power cost:$118,049
Annual power consumption:337283 kWh/yr
Chemicals
Chlorine dose:5 mg/L
Daily use:8 lbs/d
Annual use:2892 lbs/d
Annual cost:$11,568 /yr
Maintenance
Equipment cost:$2,692,575 (assume 25% of capital cost)
Annual maintenance:$53,852 /yr
Sludge Management
Production rate:0.1 dry tons/mgal
Annual production:6.935 /dry tons
Sludge management cost:$10,403 /year (deferred for 20 years)
R-1 Treatment
Labor
Normal requirement:7 visits/week
Operators/visit:2
Time per visit:8 hours/visit
Weekly labor hours:112 hours/week
Annual labor hours:5824 hours/year
FTEs:3.7 FTEs
Annual labor cost:$582,400
O&M Costs
County of Hawaii Department of Environmental Management
Pahala WWTP
Preliminary Options Assessment
A-8
Electricity
Daily power use:2,700 kWh/d
Annual power use:985,500 kWh/yr
Annual power cost:$344,925 /yr
Chemicals
Annual chemical cost:$10,000
Maintenance
Equipment cost:$3,652,973 (assume 25% of capital cost)
Annual maintenance:$73,059 /yr
Sludge Management
Sludge production:0.4 dry tons/mgal
Annual production:28 /dry tons
Sludge management cost:$41,610 /year
Limit of Treatment Technology
Labor
Normal requirement:7 visits/week
Operators/visit:3
Time per visit:8 hours/visit
Weekly labor hours:168 hours/week
Annual labor hours:8736 hours/year
FTEs:5.6 FTEs
Annual labor cost:$873,600
Electricity
Daily power use:2,700 kWh/d
Annual power use:985,500 kWh/yr
Annual power cost:$344,925 /yr
Chemicals
Alum dose 30 mg/L
Alum use:48 lbs/d
Alum cost:$34,703 /yr
Maintenance
Equipment cost:$5,097,397 (assume 25% of capital cost)
Annual maintenance:$101,948 /yr
Sludge Management
Sludge production:0.6 dry tons/mgal
Annual production:42 /dry tons
Sludge management cost:$62,415 /year
Seasonal Water Recycling (25%)
Load Equiv hp Percent kWhr/mo $/month
R-1 delivery pumps 5 25%671 $235
Totals $235
Annual power cost:$2,819
Annual power consumption:8054 kWh/yr
Annual Water Recycling (100%)
Load Equiv hp Percent kWhr/mo $/month
R-1 delivery pumps 5 100%2,685 $940
Totals $940
Annual power cost:$11,275
Annual power consumption:32214 kWh/yr
A-9
Avoided Cost of Pumping Irrigation Water
Assume pumping from basal lens
Elevation at WWTP:750 feet MSL
Flow rate:1000 gpm
2.2 cfs
Pump efficiency:85%
Motor efficiency:90%
Power cost:$0.35 /kWh
BHP:223 hp
Motor draw:185 kW
Unit volume:1 mgal
Time to pump unit vol: 16.7 hours
Power to pump unit vol: 3080 kWh
Cost to pump unit vol: $1,078
Recycled Water Pricing
High price:90%of avoided cost
Low price:50%of avoided cost
Recycled Water Sales
High price:$970 /mgal
Low price:$539 /mgal
Seasonal Recycling Sales
Annual reuse volume:17 mgal
High price sales:$16,661 /year
Low price sales:$9,256 /year
100% Recycling Sales
Annual reuse volume:70 mgal
High price sales:$67,987 /year
Low price sales:$37,770 /year
County of Hawaii Department of Environmental Management
Pahala WWTP
R-1 Sales Assessment
A-10
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No.Treatment Disposal Recycling
1 Aerated lagoons/disinfection Land application None
2 MBR (R-1)Land application None
3 MBR (R-1)Land application Seasonal (25% of total annual flow)
4 MBR (R-1)Land application Annual storage reservoir (100% of flow)
5 Limit of treatment technology Land application Seasonal (25% of total annual flow)
Criteria per HAR 11-61 1 2 3 4 5
Population served 1 1 1 1 1
Design average flow 1 1 1 1 1
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Primary treatment 0 0 0 0 0
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Advanced waste treatment 0 12 12 12 22
Additional treatment processes 7 7 7 7 7
Solids handling 0 19 19 19 19
Disinfection 5 10 10 10 10
Laboratory control bacteriological 0 0 0 0 0
Laboratory control chemical/physical 0 0 0 0 0
Total points 29 77 81 81 96
WWTP Classification per 11-61 I IV IV IV IV
Option
County of Hawaii Department of Environmental Management
Pahala WWTP
Preliminary Options Assessment
Operator Requirement Evaluation
A-12
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Pahala Wastewater Treatment Plant Preliminary Engineering Report
B-1
Collection System Plan
Memorandum Pahala Collection System Description June 20, 2018 Page 2
2. PROJECT PHASING
The project will be implemented in two phases to expedite the LCC closure. The collection system
phasing is indicated on Figure 2 and 3.
Phase 1 consists of the portions of the collection system required to divert wastewater from the LCCs
to the proposed WWTP. To accomplish this as quickly as possible, the existing collection system will
be intercepted before entering the LCCs and diverted into the new Phase 1 collection system. There
will be a portion of the sewer within an existing roadway (Pikake St. extension) on private property
owned by Edmund Olsen. The County will obtain an easement for the approximately 350 linear feet
of sewer within this private road. The LCC closures will be part of the Phase 1 work.
Phase 2 will consist of the necessary sewers and pumps needed to de-commission the aging plantation
collection system and construct a municipal sewer system that meets current County standards. The
plantation system crosses through private properties and under some residences, making the system
difficult to access for maintenance. This phase will place the new sewers mostly within the County
right-of-way for ease of access and connect the individual properties impacted by the LCC closures to
these sewers. There will be an 1,100 linear feet portion of the sewer that follows the existing
plantation sewer route within an industrial area between Ilima and Maile Streets. The property at
TMK 9-6-005:036 is owned by Edmund Olsen and leased to M L Macadamia Orchards. The County
will obtain an easement within this area to maintain the sewer.
3. TOPOGRAPHY AND SOILS
Pahala slopes down at about 6-percent from the northwest to the southeast, from an elevation of 1000
ft above mean sea level (MSL) to 800 ft MSL over a distance of 3,500 feet. A topographic map of the
area is provided in Figure 4. Available information on soil condition indicates shallow soils in the
residential areas over basalt. Soils as shallow as 12” are reported in some areas. The soil cover
appears to get deeper in the downhill direction.
Several roads in Pahala roughly follow contour lines to maintain level or appropriately sloped grades
for vehicles. This is the case for Hinano Street and Pikake Street. This results in houses on the
downhill side of the roads to be several feet below the road surface while uphill houses are several
feet above the road surface. The laterals coming from downhill dwellings would result in a deep
gravity sewer in these areas. If it is not feasible to construct deep sewers in these streets due to
unavoidable subsurface conditions or unreasonably deep pipes and manholes, an alternative such as
individual pump stations or different sewering method may be needed. A more detailed discussion of
the areas requiring pumps is presented in the next section.
Memorandum Pahala Collection System Description June 20, 2018 Page 3
4. PUMP STATIONS
The design of the collection system will minimize the use of pump stations as much as possible. This
will serve to enhance reliability and minimize operation and maintenance costs. There is one property
currently connected to the sewer system that will require a pump station. The Methodist preschool
located at TMK 9-6-015:033 is located on the downhill side of Huapala Street, approximately 20 feet
below the elevation of the street. It would not be practical to lower the sewer to this extent to service
this property.
There are also four properties on the downhill side of Hinano Street that are connected to the sewer
system that may require pumps. The intent of the design is to lower the sewer on Hinano Street to
service these properties by gravity; however, the subsurface conditions will have to be verified before
a final determination can be made.
There are also several newly accessible properties on Pikake Street that require pumps if the sewer is
not constructed deep. Based on what has been reported of subsurface conditions at the Kau High
School, it is suspected that the sewer on Pikake Street would not be able to be set low enough to serve
these properties; therefore, the assumption is most of the newly accessible properties east of Pikake
Street will require pumps.
5. PIPE SIZING
Sewer pipe sizing is based on the flow estimates provided by B&C and a best guess of how the entire
community will be eventually serviced. It is assumed that the sewer on Maile Street will eventually
convey the flow from the entire community. It is also anticipated that the sewer on Pikake Street will
eventually have other sewers feeding into them from surrounding areas. Similarly, for the sewers to
be constructed in Phase 2, there will be surrounding areas eventually feeding into the sewers on
Puahala/Kamani Streets. It is assumed future sewers would not be feeding into Huapala Street. It is
assumed the areas northeast of Huapala Street can be served by the sewers system to the east;
therefore, the sewer is not up-sized for future flows. A summary of the estimated pipe sizes and
lengths is presented in Table 1.
Memorandum Pahala Collection System Description June 20, 2018 Page 4
Table 1: Approximate Pipe Size and Lengths
Location Start End Size Length
Phase 1
Waterline Pikake St Pikake WWTP 6 2200
SL A Maile St (deep to normal) Huapala WWTP 16 1730
SL C1 Pikake St Ph 1 Ohia Maile 14 780
Phase 2
SL B‐1 Ilima St Huapala Ilima 8 335
SL B‐2 Huapala St Hinano Pikake 8 410
SL C2 Pikake St Pakalana Ohia 14 1569
SL D Puahala St & Kamani St Pakalana Pikake 12 1150
SL E Hinano St (deep) Hapu Huapala 8 700
SL F Hala St End Hinano 8 250
SL G Huapala St Pakalana Ilima 8 1650
SL H Ilima St End Huapala 8 1750
SL I Easement thru Olson Land Ilima Maile 12 875
Pipe material will be AWWA C900 PVC for corrosion resistance. Although this application is for
gravity service, the thick wall C900 pressure pipe is preferred for durability in service and during
installation.
6. COST
The 0% cost estimates for Phase 1 and Phase 2 are based on recent bid tabs. Costs from a recent
project were much higher than originally anticipated. Phase 1 using recent bid cost is approximately
$4 million. Phase 2 using the same basis is $9 million. These costs will be refined further as the
design is develop.
")
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LEGEND
Existing Condition to Large Capacity Cesspool (LCC)
Initial Build Condition to WWTP
Proposed Pahala WWTP Site
"Existing Large Capacity Cesspool )
Pahala Future County Sewer System
Ka'u High & Pahala Elementary School
Ka' u
Hospital
Proposed Pahala WWTP Site ±
2,000 1,000
Feet
0
Existing Large Capacity
Cesspool (LCC 1)
Existing Large Capacity
Cesspool (LCC 2)
TMK 9-6-017:038 will not
connect to system
Sewer w/in Easements
Properties Req. Pump
Properties That Can Be
Connected by Deep Sewer
or Pump
Sewer w/in Temp. Easements to Close
LCCs Before Collection System Completed
NOTE: Deep sewers may not be acceptable pending
results of geotechnical investigation and cultural studies
LEGEND
JOB NO: 150440 PAHALA WWTP SERVICE AREA
SCALE: AS SHOWN PAHALA WASTEWATER TREATMENT PLANT FIGURE2-1
Easement
Intercept existing sewer
(temporary easement)
Intercept existing sewers
Figure 2
Collection System Phase 1
Phase 1 Sewers (Purple)
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396021029
396021001 396016036
396021030 !(
396017013
396017014
396017015
396017029
396017016
396017028
396017027 396017024 396017026
396017025
396014071
396016046 396016033 396021031 !396016038 396017017 ( 396016032 396017018 396017022 396014067 396016034 396016003 396017999 396014066 !( 396016037 396016045
396017019 396014072 396014065
396016028 396016029396016030 396016031 396016001 396017020 !(
396014053
396014064 396016044 !(
!( 396014063 396016035
396014062
396014054
396016999 OH 396016002
396014061 396016043 !( 396016004
!(
396014055 396014060 396016027 396016018 396016017
!( 396014051 396014056
!( 396014059
!( !( 396014058
396014050 396014057 396015030
396015029 396016042 396015028 396016019
!( 396014049
!( 396014048
!(
396014047 396015031
396015027
396016016
396023042 396023044
!(
!(
396015026 !( 396015022 396015023 !(
396016026
396015025 396016015 396016005
!( !( 396015013 396015014 396014046
396014070 !( 396014045
396015012
396014017 !( 396015011
396015015 !( 396015016 396016013 !( LCC 2 !( !( 396015024 !396015021 ( Z |396016020
396016041 !( 396016025
396023041
396016014 396016006 396023040
396015017 !(
!( 396014018 396014044 !( 396015010 396015018
396014069
396014016 MAS!( 396014019
!( 396014020
396014043 !( 396014042
396015019
396016024 396023039 !396016039 396016007 396015020 ( 396016040 !(
396015009 !( !( 396015001 !( 396016012 396016023 396016008
396016022 396023045
!( 396023038 396023032 396023031
396014015 !(
396014041 !( 396014021 !!(( 396015008 396015006 396015002 396014040
396014014 !( 396014022 !( 396015003 396023037
396014013 !(
396014039 396014023 !( !( 396014024 396014038 !( !(
396016009 396023030
396015004 !(
396014012 !( 396014025 396014037 !( 396015007 396023036 396023027
396014011 396014026 !( !( 396014036 !( 396015005 !( 396016010 !( 396023029
396014010
396014009
!( !( 396014027
396014008
!( !( 396014028
396014035 !( 396016011 396014034 !! 396015999 396015033 396023026 396023007
!( !( 396014007
396014029 396014033 396023028
!( !( 396023025 396014030
396014006
396014005
!( !( 396014031 396015032 396005044
396014004 !( !( 396005049 396014003 !( 396014999 !! 396002056
!( !( 396014032 !! 396023024
396023033
396023010
396005009 396014002 !( 396023023 !( 396014001
396023011
396023012396023013 !! 396023022
396015034
396023014
( !396023015396023016396023021 396023017
396023035
396005036 396023020 396023019 396023018 !!
!!
396002025
396023034
396015035
!!
396002016
396005054 Legend
|lehu-Pahala LCCs Z Naa
!! Naalehu-Pahala Sewer Manholes
Naalehu-Pahala Sewer Lines
Elec Permits Pahala "Cancelled" (1)
Elec Permits Pahala "Complete" (4)
Plumbing Permits Pahala "Cancelled" (1)
Plumbing Permits Pahala "Complete" (93)
Plumbing Permits Pahala "No Record" (4)
Parcels Services Status
( !Connected (1)
!Assumed Connec ion )
( t (100
D Not Connected (0)
PERMIT STATUS µ Electrical (Transfer Switch & Pump) and Plumbing
Feet
0 100 200 400 600 800 Pahala Oct. 05, 2016
!!
396002999 396002024
|Z LCC 1 396002047
396002001
396023999
396002002
396002048
396002043
396005052
396005051 396002999
396005026
396002044
396002018
396002021
396002028
396002015
396017046
396022050
396022051
396022052
396022053
396023043
396022002
396022004
396022055
396022056
396023001
396023002
396023003
396023004
396023005
396023006
396005046
396023999
396017023
396023008
396023009
396017021
Easements
Deep sewers
Figure 3
Collection System Phase 2
Phase 2 Sewers (Green)
H
A
P
U
S
T
HA
L
A
S
T
LE
H
U
A
S
T
WOOD
VALLEYRD
HOLEI
S
T
LII T
HAU
S
T
PAAUAUPL
KAUMAHAN
A
S
T
KOKIO
S
T
LI
I
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S
T
IA ST
PIK
A
K
E
S
T
PUA
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S
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A
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KEAHI
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KOALIST
PUMELI
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S
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I
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396022049
396021004
396021003
396014052
396005017
396012002 396012999 396012028
396005059 396005061 396012001
396005057
396005053
396005003
396005060
396012010 396005045
396018050 396018048396018049 396018051
396018052 396018046396018047
396018045
396019001 396018053
396018054
396018039 396012012 396019002 396018041 396018040396005001 396018043 396018055
396018044 396018042 396018038 396019003 396018037
396019007 396018056 396018057 396018058 396018036 396019008 396019013 396018030 396018009 396019009 396019006 396019004 396018031 396018032 396018035 396018059 396019014 396019012
396019011396019010 396019005 396019015 396019017 396019016 396018011 396022042 396018060 396018034
396018999 396018033 396018012 396022041 396018010 396022043
396019018 396019999 396018013 396018027 396018026 396020015 396019019 396020016 396018029 396022040 396020063 396020061 396020058 396018014 396019020 396020064 396020060 396018025 396020062 396019021 396020065 396020059 396022044 396020014 396018015 396022039
396020066 396020057 396020017 !( 396018028 396018024 396022023 396019022 396022038 396022058 396018016 396022045 396021016 396020046 396018023 396020013 !( 396021015 396020047 396020048
396020049 396020050 396018004
396021014
396020018 396020051 396020053396020054
396020052 !( 396020055396020056 396020012 396018003 396018022
396018017 396022037 396022024 396022057
396018018 396022036
396021013 396020045
396021012 396021017
( !396020019 396020011 396022035 !( 396018002 396018019
396022025 396022022 396022046
396022026 396022021 396022999 396022047
396021011
396021032
396021010
396021018 396020044 396020999 396020020 !(
396021019
396020040396020039 396020043 396020042396020041 396020038 396020036 396020037 396020034 396020021 !(
396020010 !396018021 ( 396018001
396022034 396022048 396022027 396022020 396022013
396018020 396022033 396022028
396021020 396020035 396020009 !( 396022019 396022014
396021021 396020022 396020033 !(
396021009
396020008 !(
396022032 396022029 396022015 396022012
396022018
396022030 396022016 396022011
396021008 396021999 !( 396020023 396021022 396017041
396020032 396020007 396022017 !( 396017003 396017038 396022031 396017040 396022010
396021007 396021023 396020031
396021006 396021024
396021025 396020030
396020024 396020006 396017037 !( 396022009
396017039 396017042
396020025 !( 396022008 396022005 396022003
396021005 396020026 396020004 ( !!(
396020005 !( 396017043 396017033 396022006
396021026 396017002 396017034 396022007
396005039 !( 396020027 396020003 !( 396017044 396022054
396017035
396021027 396017036 396020002 396017031 !(
396021028 396020028 396017030 396020001 !396017001 ( 396017006 396017007 396017008
396021002 396005008 396017009 396017010396017011
396017032 396017045
396017012
396022001
396021029
396021001 396016036
396021030 !(
396017013
396017014
396017015
396017029
396017016
396017028
396017027 396017024 396017026
396017025
396014071
396016046 396016033 396021031 !396016038 396017017 ( 396016032 396017018 396017022 396014067 396016034 396016003 396017999 396014066 !( 396016037 396016045
396017019 396014072 396014065
396016028 396016029396016030 396016031 396016001 396017020 !(
396014053
396014064 396016044 !(
!( 396014063 396016035
396014062
396014054
396016999 OH 396016002
396014061 396016043 !( 396016004
!(
396014055 396014060 396016027 396016018 396016017
!( 396014051 396014056
!( 396014059
!( !( 396014058
396014050 396014057 396015030
396015029 396016042 396015028 396016019
!( 396014049
!( 396014048
!(
396014047 396015031
396015027
396016016
396023042 396023044
!(
!(
396015026 !( 396015022 396015023 !(
396016026
396015025 396016015 396016005
!( !( 396015013 396015014 396014046
396014070 !( 396014045
396015012
396014017 !( 396015011
396015015 !( 396015016 396016013 !( LCC 2 !( !( 396015024 396015021 !( Z |396016020
396016041 !( 396016025
396023041
396016014 396016006 396023040
396015017 !(
!( 396014018 396014044 !( 396015010 396015018
396014069
396014016 MAS!( 396014019
!( 396014020
396014043 !( 396014042
396015019
396016024 396023039 !396016039 396016007 396015020 ( 396016040 !(
396015009 !( !( 396015001 !( 396016012 396016023 396016008
396016022 396023045
!( 396023038 396023032 396023031
396014015 !(
396014041 !( 396014021 (( !!396015008 396015006 396015002 396014040
396014014 !( 396014022 !( 396015003 396023037
396014013 !(
396014039 396014023 !( !( 396014024 396014038 !( !(
396016009 396023030
396015004 !(
396014012 !( 396014025 396014037 !( 396015007 396023036 396023027
396014011 396014026 !( !( 396014036 !( 396015005 !( 396016010 !( 396023029
396014010
396014009
!( !( 396014027
396014008
!( !( 396014028
396014035 !( 396016011 396014034 !! 396015999 396015033 396023026 396023007
!( !( 396014007
396014029 396014033 396023028
!( !( 396023025 396014030
396014006
396014005
!( !( 396014031 396015032 396005044
396014004 !( !( 396005049 396014003 !( 396014999 !! 396002056
!( !( 396014032 !! 396023024
396023033
396023010
396005009 396014002 !( 396023023 !( 396014001
396023011
396023012396023013 !! 396023022
396015034
396023014
( !396023015396023016396023021 396023017
396023035
396005036 396023020 396023019 396023018 !!
!!
396002025
396023034
396015035
!!
396002016
396005054 Legend
|lehu-Pahala LCCs Z Naa
!! Naalehu-Pahala Sewer Manholes
Naalehu-Pahala Sewer Lines
Elec Permits Pahala "Cancelled" (1)
Elec Permits Pahala "Complete" (4)
Plumbing Permits Pahala "Cancelled" (1)
Plumbing Permits Pahala "Complete" (93)
Plumbing Permits Pahala "No Record" (4)
Parcels Services Status
( !Connected (1)
!Assumed Connec ion )
( t (100
D Not Connected (0)
PERMIT STATUS µ Electrical (Transfer Switch & Pump) and Plumbing
Feet
0 100 200 400 600 800 Pahala Oct. 05, 2016
!!
396002999 396002024
|Z LCC 1 396002047
396002001
396023999
396002002
396002048
396002043
396005052
396005051 396002999
396005026
396002044
396002018
396002021
396002028
396002015
396017046
396022050
396022051
396022052
396022053
396023043
396022002
396022004
396022055
396022056
396023001
396023002
396023003
396023004
396023005
396023006
396005046
396023999
396017023
396023008
396023009
396017021
Approx Scale: 1” = 1500 feet
Figure 4
Topographic Map
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C-1
Wastewater Flow Calculations
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Final EA, Pāhala LCC Replacement Project Pāhala, Ka‘ū District, Hawai‘i
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Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
Appendix C
August 2018 Biological Survey Report
February 2020
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
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AECOS No. 1545
Biological survey for the Pāhala Community
Large Capacity Cesspool Closure Project on lot
TMK: 9‐6‐002:018, Ka‘ū District, Hawaiʻi Island
Prepared by:
AECOS, Inc. 45-939 Kamehameha Hwy, Suite 104 Kāne‘ohe, Hawai‘i 96744-3221 August 16, 2018
AECOS Inc. [File: 1545.docx] Page | 1
Biological survey for the Pāhala Community
Large Capacity Cesspool Closure Project on lot
TMK: 9‐6‐002:018, Ka‘ū District, Hawaiʻi Island
August 16, 2018 Draft AECOS No. 1545
Eric Guinther and Reginald David
AECOS, Inc.
45‐939 Kamehameha Hwy, Suite 104
Kāne’ohe , Hawai’i 96744
Phone: (808) 234‐7770 Fax: (808) 234‐7775 Email: guinther@aecos.com
Introduction
The Hawai‘i County Department of Environmental Management, Wastewater Division is proposing to construct a wastewater treatment and disposal system (“Project”) to treat sewage collected in Pāhala, Ka‘ū District. The treatment and disposal system will be located on a property identified as TMK: 9-6-002:018, north of the intersection of Hawaii Belt Road (Māmalahoa Highway) and Maile Street. This report describes methods used and results of a biological survey conducted in the Project area in August 2018. The primary purpose of the survey was to determine whether any species currently proposed or listed as threatened or endangered under either federal or state endangered species statutes occur on, or could utilize resources within, the Project area. Project and Site Descriptions
The WWTP site encompasses the lower, approximately 15 ac (6 ha) of the subject parcel (TMK: 9-6-002:018). Presently the entire parcel is a macadamia nut (Macadamia integrifolia) orchard, but with the margins and two narrow windbreak tree lines dominated by other species of trees and herbaceous plants dividing the orchard into northwest-southeast trending units. In addition to the WWTP site, a proposed transmission pipe would be constructed to the northwest through the orchard up to Maile Street. From Maile Street a collection system is planned for many of the streets within Pāhala town (see Figure 1).
Biological Surveys PĀHALA WWTP (TMK: 9-6-002: 018)
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Figure 1. Project and survey areas marked in red, Pāhala.
Biological Surveys PĀHALA WWTP (TMK: 9-6-002: 018)
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Macadamia nut trees form a closed crown of dense leaf growth (see cover photo), creating deep shade within most parts of the grove. The dominant understory in these deeply shaded areas is germinating mac nut trees. Methods Botanical Survey The botanical survey was undertaken on August 13, 2018 and entailed a wandering pedestrian transect that traversed the subject property, including the area extending north to Maile Road proposed for installation of a collector main. A “windshield” survey was conducted along all the streets proposed for the collection system beyond the surveyed parcel. Plant species were identified as they were encountered and notations made in a field notebook, which was used to develop qualitative abundance values for each species as the survey progressed. On a strictly area basis, only macadamia nut trees, Guinea grass (Megathyrsus maximus), and perhaps a couple of other species would have a ranking above uncommon. So, abundance values in this report are relative to areas that support species other than the macadamia nut trees, such as the road verges and other areas surrounding the orchard, unmaintained areas within the orchard, including narrow windbreak lanes that divide the orchard plots into units. The survey period encompassed the early dry season, but most of the vegetation was in a relatively healthy state (the orchard is irrigated as needed). However, early in the dry season found most trees and shrubs absent fruit or flower. This slight limitation did not compromise the discovery of native species of plants. Plant names used herein follow Manual of the Flowering Plants of Hawai‘i (Wagner, Herbst, & Sohmer, 1990; Wagner & Herbst, 1999) for native and naturalized flowering plants, Hawai‘i’s Ferns and Fern Allies (Palmer, 2003) for ferns, and A Tropical Garden Flora (Staples & Herbst, 2005) for ornamental and crop plants. More recent name changes for naturalized plant species follow Imada (2012). Avian Survey Six avian count stations were sited roughly equidistant from each other, four within the WWTP area and two along the collection pipe route upslope to Maile Street. Stations were sited approximately 150 m (490 ft) apart from each other. A single eight-minute avian point count was made at each of the count stations. Field observations were made with the aid of Leica 8 X 42 binoculars and by
Biological Surveys PĀHALA WWTP (TMK: 9-6-002: 018)
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listening for vocalizations. The avian counts were conducted in the early morning hours. Time not spent counting at point-count stations was used to search the site for species and habitats not observed during the point counts. Weather conditions were excellent with winds of between 1 and 5 kph and no precipitation. The avian phylogenetic order and nomenclature used in this report follows the
AOU Check‐List of North American Birds (American Ornithologists’ Union, 1998), and the 42nd through the 59th supplements to the Check-List (American Ornithologists’ Union, 1998, 2000; Banks et al., 2002, 2003, 2004, 2005, 2006, 2007, 2008; Chesser et al., 2009, 2010, 2011, 2012, 2013, 2014, 2015, 2016, 2017, 2018).
Mammalian Survey
With the exception of the endangered Hawaiian hoary bat (Lasiurus cinereus
semotus) or ‘ōpe‘ape‘a, all terrestrial mammals currently found on the Island of Hawai’i are alien species, and most are ubiquitous. The survey of mammals was limited to visual and auditory detection, coupled with visual observation of scat, tracks, and other animal sign. A running tally was kept of all terrestrial mammalian species detected within the project area. Results Vegetation Vegetation within the areas surveyed comprises a macadamia nut orchard of mature trees, unmaintained areas dominated outside the orchard by Guinea grass, lanes of windbreak trees oriented between orchard units, and (mostly) mowed road verge areas. Within the orchard are scattered small plots of ruderal herbaceous plants, in most cases dominated by nodeweed (Synedrella
nodiflora), but if generally only lightly shaded, a number of other herbaceous species. The windbreak lanes consist of two rows of trees: silk oak (Grevelia
robusta) and paperbark (Melaleuca quinquenervia) and are used in orchard maintenance to stack cut branches and logs. These lanes support many of the herbaceous plants recorded from the orchard. The proposed sewerage collection system will be installed along already paved roadways within Pāhala. The survey in these areas revealed the vegetation to be entirely maintained yards of ornamental plants.
Biological Surveys PĀHALA WWTP (TMK: 9-6-002: 018)
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Flora A listing of the plant species recorded during the August 2018 survey is provided as Table 1. In all, the listing has 52 species of vascular plants: 2 ferns, one gymnosperm, and 49 species of angiosperms (flowering plants). Only two species (4%) are regarded as native to the Hawaiian Islands and both are indigenous (native, but also distributed elsewhere in the Pacific). Found in low numbers are the ubiquitous, ruderal ‘uhaloa (Waltheria indica) and the common blue- or purple-flowered morning glory vine: koali ‘awa (Ipomoea indica). Being widely distributed indigenous species, neither is listed as threatened or endangered or of any special concern. Table 1. Plant species identified during the August 13, 2018 survey of TMK: 9-6-002:018, Pāhala, Ka‘ū District, Hawai‘i. Species listed by family Common name Status Abundance Notes FERNS NEPHROLEPIDACEAE Nephrolepis multiflora (Roxb.) F.M. Jarrett ex C.V. Morton sword fern Nat R PTERIDACEAE Pityrogramma calomelanos (L.) Link
silver fern Nat R <1> GYMNOSPERMS ARAUCARIACEAE Araucaria columnaris (G. Forst.) J.D. Hook. Cook pine Nat O <1> FLOWERING PLANTS DICOTYLEDONS AMERANTHACEAE Amaranthus spinosus L. spiny amaranth Nat R APOCYNACEAE Carissa macrocarpa (Ecklon) A. de Cand. natal plum Orn R Nerium oleander L. olreander Orn R ARALIACEAE Schefflera actinophylla (Endl.) Harms umbrella tree Nat U ASTERACEAE (COMPOSITAE) Ageratum conyzoides L. maile hohono Nat R <1>
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Table 1 (continued). Species listed by family Common name Status Abundance NotesASTERACEAE (cont.) Bidens pilosa L. ki; beggartick Nat U <2> Calyptocarpus vialis Less. --- Nat O <1> Conyza bonariensis (L.) Cronq. hairy horseweed Nat C <2> Crassocephalum crepidioides (Benth.) S. Moore --- Nat R Cyanthillium cinereum L. little ironweed Nat U <1> Lactuca serriola L. prickly lettuce Nat U <1> Indet. ruderal weed Nat R <3> Synedrella nodiflora (L.) Gaertn. nodeweed Nat AA <2> BASELLACEAE Anredera cordifolia (Ten.) Steenis Madeira vine Nat R <3> BRASSICACEAE Lepidium virginicum L. --- Nat R <2> CAPPARACEAE Cleome gynandra L. wild spider flower Nat O <1> CONVOLVULACEAE Ipomoea indica (J. Burm.) Merr. koali ‘awa Ind R Ipomoea obscura (L.) Ker-Gawl. --- Nat O Merremia tuberosa (L.) J. Rendle wood rose Nat R CUCURBITACEAE Momordica charantia L. wild bitter melon Nat O EUPHORBIACEAE Euphorbia heterophylla L. kaliko Nat U <1> Euphorbia hirta L. garden spurge Nat O <2> Ricinus communis L. castor bean Nat C <2> FABACEAE Acacia confusa Merr. Formosan koa Nat R Leucaena leucocephala (Lam.) deWit koa haole Nat R <2> Macroptilium atropurpureum (DC.) Urb. ‐‐‐ Nat U <1> Neonotonia wightii (Wight & Arnott) Lackey
glycine vine Nat AA <2> LAMIACEAE Leonotis nepetifolia (L.) R. Br. lion’s ear Nat O <2> MALVACEAE Abutilon grandifolium (Willd.) Sweet hairy abutilon Nat R Malvastrum coromandelianum (L.) Garcke false mallow Nat O <2> Sida rhombifolia L. Cuba jute Nat C <2>
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Table 1 (continued). Species listed by family Common name Status Abundance NotesMALVACEAE (cont.) Sida spinosa L. prickly sida Nat R Waltheria indica L. ‘uhaloa Ind U MORACEAE Ficus microcarpa L. f. Chinese banyan Nat R <2> MYRTACEAE Melaleuca quinquenervia (Cav.) S.T. Blake paperbark Nat C Syzygium cumini (L.) Skeels Java plum Nat U <2> PHYTOLACCACEAE Rivina humilis L. coral berry Nat U PROTEACEAE Grevillea robusta A. Cunn. ex R. Br. silk oak Nat C <2> Macadamia integrifolia Maiden & Berche macadamia nut Nat AA RUBIACEAE Spermacoce assurgens Ruiz & Pav. buttonweed Nat C <1> MONOCOTYLEDONS COMMELINACEAE Commelina benghalensis L. hairy honohono Nat R <1> CYPERACEAE Cyperus gracilis R. Br. McCoy grass Nat U POACEAE Axonopus compressus (Swartz) P. Beauv.
brd.-lvd. carpet grass Nat C <1> Cenchrus purpureus (Schumach.) Morrone elephant grass Nat U Chloris barbata (L.) Sw. swollen fingergrass Nat R Digiteria sp. --- Nat R Eleusine indica (L.) Gaertn. wiregrass Nat A <2> Megathyrsus maximus Jacq. Guinea grass Nat AA <2> Setaria verticillata (L.) P. Beauv. bristly foxtail Nat R Legend to Table 1: Status = distributional status Ind = indigenous; native to Hawai‘i, but not unique to the Hawaiian Islands. Nat = naturalized, exotic, plant introduced to the Hawaiian Islands since the arrival of Cook Expedition in 1778 and well-established outside of cultivation. Orn = ornamental; crop or landscape plant not established outside of cultivation. Abundance = occurrence ratings for plants on property in July 2013. R – Rare - only one or two plants seen.
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Table 1 – Legend (continued). U - Uncommon - several to a dozen plants observed. O - Occasional - found regularly, but not abundant anywhere. C - Common - considered an important part of the vegetation and observed numerous times. A - Abundant - found in large numbers; may be locally dominant. AA - Abundant - very abundant and dominant; defining vegetation type. Notes: <1> Characteristic or found only in the road verge immediately adjacent to the site. <2> Species also reported from close by in David & Guinther (2013). <3> Plant lacking flowers or fruit at time of survey; identification uncertain.
Avian Survey A total of 175 individual birds of 13 species, representing nine separate families, was recorded during station counts (Table 2). 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. A closed canopy keeps areas beneath the trees in perpetual twilight. Four species, Northern Cardinal (Cardinalis cardinalis), Japanese White-eye (Zosterops japonicus), Yellow-fronted Canary (Ceithagra mozambica), and Red-billed Leiothrix (Leiothrix lutea), accounted for 52% of all birds recorded during station counts. The most frequently recorded species was Northern Cardinal, which accounted for 16% of the total number of individual birds recorded during station point counts. All of the species recorded during the course of this survey are established alien species. Table 2. Avian species detected during point-counts for the Pāhala Community WWTP Project
Common Name Scientific Name ST RA
PHASIANIDAE ‐ Pheasants & Partridges
Meleagridinae ‐Turkeys
Wild Turkey Meleagris gallopavo A 2.00
COLUMBIFORMES
COLUMBIDAE ‐ Pigeons & Doves
Spotted Dove Streptopelia chinensis A 3.17
Zebra Dove Geopelia striata A 2.00
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Table 2 (continued). Common Name Scientific Name ST RA
PASSERIFORMES
ZOSTEROPIDAE ‐White‐eyes
Japanese White‐eye Zosterops japonicus A 3.67
TIMALIIDAE ‐ Babblers
Chinese Hwamei Garrulax canorus A 2.00
Red‐billed Leiothrix Leiothrix lutea A 3.33
STURNIDAE ‐ Starlings
Common Myna Acridotheres tristis A 0.17
FRINGILLIDAE ‐ Fringilline and Carduline Finches & Allies
Carduelinae ‐ Carduline Finches and Hawaiian
Honeycreepers
House Finch Haemorhous mexicanus A 1.33
Yellow‐fronted Canary Ceithagra mozambica A 1.50
CARDINALIDAE ‐ Cardinals & Allies
Northern Cardinal Cardinalis cardinalis A 4.67
THRAUPIDAE ‐ Tanagers
Thraupinae ‐ Core Tanagers
Yellow‐billed Cardinal Paroaria capitata A 1.50
Saffron Finch Sicalis flaveola A 1.67
ESTRILDIDAE ‐ Estrildid Finches
Scaly‐breasted Munia Lonchura punctulata A 0.17
Key to Table 2
ST Status. A Alien – Introduced to the Hawaiian Islands by humans.
RA Relative Abundance – Number of birds detected divided by the number of count stations (6). Mammalian Survey Rather remarkably, we recorded no mammalian species within the survey area. Indeed, there was no indication that pigs (Sus scrofa) utilize the Project area. Discussion Botanical Resources Although some unmaintained or infrequently maintained areas exist on the subject parcel, the entire Project is proposed for land that is highly modified and the flora present subject to alterations, including mowing. Thus, there is no expectation for the site to support remnants of a native forest flora and minimal
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opportunity for native plants to become established, the ‘uhaloa and koali ‘awa being exceptions due to their ability to grow in highly disturbed environments. A previous biological survey (David and Guinther, 2013) conducted on 5 ac (2 ha) of land close by to the east yielded only 25 species of plants, the most abundant being white shrimp plant (Justicia betonica), glycine vine, and Guinea grass. Because that area had been highly disturbed, then not disturbed for a long time, species such as the shrimp plant and particularly Guinea grass had become well-established to the exclusion of other species. Sixteen species (24% of the combined species list) were common to both surveys. Obviously, the macadamia nut orchard is a valuable botanical resource, but a commercial one and not an environmentally sensitive one. The same can be said for the Cook pines (Araucaria columnaris) that line Maile Street along the southwestern side of the parcel. These old trees are an important community landscape element to be retained in place by the Project. Avian Resources The findings of the avian survey are consistent with the location of the site, and the monoculture of macadamia nut trees present on it. No native avian species were recorded during the course of this survey. Although not detected during this survey, endemic Hawaiian Petrel (Pterodroma sandwichensis) and Newell’s Shearwater (Puffinus newelli) have been recorded over-flying the general Project area between April and the end of November each year. The petrel is listed as endangered, and the shearwater as threatened under both federal and State of Hawai‘i endangered species statutes. The primary cause of mortality in both Hawaiian Petrel and Newell’s Shearwater is thought to be predation by alien mammalian species at the nesting colonies (USFWS, 1983; Simons and Hodges, 1998; Ainley et al., 2001). Collision with man-made structures is considered to be second-most significant cause of mortality of these seabirds in Hawai‘i. Nocturnally flying seabirds, especially fledglings on their way to sea in the summer and fall, can become disoriented by exterior lighting. When disoriented, seabirds can collide with man-made structures and, if not killed outright, dazed or injured birds become prey to feral mammals (Hadley, 1961; Telfer, 1979; Sincock, 1981; Reed et al., 1985; Telfer et al., 1987; Cooper and Day, 1998; Podolsky et al., 1998; Ainley et al., 2001; Hue et al., 2001; Day et al., 2003). Neither nesting colonies nor appropriate nesting habitat for either of these listed seabird species occur within or close to the current Project site.
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Mammalian Resources No Hawaiian hoary bats were detected during the course of this survey. It is possible that bats use resources within orchard part of the Project. Although, no rodents were recorded during the course of this survey, it is likely that one or more of the four alien Muridae established on Hawai’i IslandEuropean house mouse (Mus musculus domesticus), roof rat (Rattus rattus), brown rat (Rattus norvegicus), and black rat (Rattus exulans hawaiiensis)use various resources found within the general Project area on a seasonal basis, especially in the macadamia nut orchard. These human commensal species are drawn to areas of human habitation and activity and all are deleterious to native ecosystems and their dependent native fauna. Jurisdictional Waters The subject parcel slopes down to the southwest corner. A street culvert at that location carries runoff in the area under Māmalahoa Highway (Hawaii Belt Road). The National Wetlands Inventory (NWI) Wetlands Mapper (USFW, nd (a)) shows no features occurring on the parcel and no streams are shown on USGS topographic maps (USGS, 1923). Streams in the Pāhala area of the Island do not flow all the way to the sea, but terminate on Keone‘ele‘ele Flat to the southwest. Critical Habitat Federally delineated Critical Habitat is not present in Pāhala area (USFWS, 2012). Thus, the Project will not impinge on federally designated Critical Habitat. No equivalent designation exists under state law Potential Impacts to Protected Species No species of plants or animals currently proposed for listing or listed under either the federal or State of Hawai‘i endangered species statutes (DLNR 1998, 2015; USFWS, nd (b)) were recorded by this survey. Three faunal species not observed, may occur in the general vicinity and are discussed here. Seabirds The principal potential impact that the construction of the project poses to protected seabirds is the increased threat that birds will be downed after becoming disoriented by lights associated with the proposed action during the
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nesting season. The two activities that could pose a threat to these nocturnally flying seabirds are: a) if during construction, it is deemed expedient or necessary to conduct night-time construction activities during the seabird fledging season (which runs from September 15 through December 15); or b) exterior lighting is installed as part of the WWTP facilities. Impacts can be minimized if all external lighting is made dark sky compliant (HDLNR-DOFAW, 2016). Hawaiian hoary bat The potential impact that Project construction poses to the endangered Hawaiian hoary bat would be from clearing and grubbing of the macadamia nut orchard. Trimming or removal of trees within the construction areas may temporarily displace bats using this vegetation for roosting. Hawaiian bats use multiple roosts within their home territories, so the disturbance resulting from removal of trees is likely to be minimal. However, during pupping season, female bats carrying pups may be less able to rapidly vacate a roost site when the tree is felled. Additionally, adult female bats sometimes leave their pups in the roost tree while they themselves forage, and very small pups may be unable to flee a tree that is being felled. Adverse effects from such disturbance 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. References Ainley, D. G, R. Podolsky, L. Deforest, G. Spencer, and N. Nur. 2001. The Status and Population Trends of the Newell’s Shearwater on Kaua’i: Insights from Modeling, in: Scott, J. M, S. Conant, and C. Van Riper III (editors)
Evolution, Ecology, Conservation, and Management of Hawaiian Birds: A
Vanishing Avifauna. Studies in Avian Biology No. 22. Cooper’s Ornithological Society, Allen Press, Lawrence, Kansas. Pp. 108-123. American Ornithologist’s Union. 1998. Check‐list of North American Birds. 7th edition. AOU. Washington, D.C. 829 pp. _______. 2000. Forty-second supplement to the American Ornithologist’s Union
Check‐list of North American Birds. The Auk, 117: 847-858. Banks, R. C., C. Cicero, J. L. Dunn, A. W. Kratter, P. C. Rasmussen, J. V. Remsen, Jr., J. D. Rising, and D. F. Stotz. 2002. Forty-third supplement to the American
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Ornithologist's Union Check-list of North American Birds. The Auk, 119: 897-906. Banks, R. C., C. Cicero, J. L. Dunn, A. W. Kratter, P. C. Rasmussen, J. V. Remsen, Jr., J. D. Rising, and D. F. Stotz. 2003. Forty-fourth supplement to the American Ornithologist's Union Check-list of North American Birds. The
Auk, 120: 923-931. ______, ______, ______, ______, ______, ______, ______, and ______. 2004. Forty-fifth supplement to the American Ornithologist's Union Check-list of North American Birds. The Auk, 121: 985-995. ______, ______, ______, ______, ______, ______, ______, and ______. 2005. Forty-sixth supplement to the American Ornithologist's Union Check-list of North American Birds. The Auk, 122: 1026-1031. ______, ______, ______, ______, ______, ______, ______, and ______. 2006. Forty-seventh supplement to the American Ornithologist's Union Check-list of North American Birds. The Auk, 123: 926-936. _______, R. T. Chesser, C. Cicero, J. L. Dunn, A. W. Kratter, I. J. Lovette, P. C. Rasmussen, J. V. Remsen, Jr., J. D. Rising, and D. F. Stotz. 2007 Forty-eighth supplement to the American Ornithologist Union Check-list of North American Birds. The Auk, 124: 1109-1115. _______. _______. _______, _______, _______, ________, _______, _______, _______, _______, and K. Winker. 2008 Forty-ninth supplement to the American Ornithologist Union Check-list of North American Birds. The Auk, 125: 758-768. Chesser, R. T., R. C. Banks, F. K. Barker, C. Cicero, J. L. Dunn, A. W. Kratter, I. J. Lovette, P. C. Rasmussen, J. V. Remsen, Jr., J. D. Rising, D. F. Stotz, and K. Winker. 2009. Fiftieth supplement to the American Ornithologist Union, Check-list of North American Birds. The Auk, 126: 1-10. ______, _______, _______, _______, _______, _______, _______, _______, _______, _______, _______, and _______. 2010. Fifty-first supplement to the American Ornithologist Union, Check-list of North American Birds. The Auk 127: 726-744. ______, _______, _______, _______, _______, _______, _______, _______, _______, _______, _______, and _______. 2011. Fifty-second supplement to the American Ornithologist Union, Check-list of North American Birds. The Auk, 128: 600-613.
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Chesser, R. T., R. C. Banks, F. K. Barker, C. Cicero, J. L. Dunn, A. W. Kratter, I. J. Lovette, P. C. Rasmussen, J. V. Remsen, Jr., J. D. Rising, D. F. Stotz, and K. Winker. 2012. Fifty-third supplement to the American Ornithologist Union, Check-list of North American Birds. The Auk, 129: 573-588. ______, _______, _______, _______, _______, _______, _______, _______, _______, _______, _______, and _______.. 2013. Fifty-fourth supplement to the American Ornithologist Union, Check-list of North American Birds. The Auk, 130: 558-71. ______, _______, _______, _______, _______, _______, _______, _______, _______, _______, _______, and _______. 2014. Fifty-fifth supplement to the American Ornithologist Union Check-list of North American Birds. The Auk, Ornithological
Advances, 131: CSi-CSxv. ______, _______, _______, _______, _______, _______, _______, A. G. Navarro-Sigüenza, P. C. Rasmussen, J. V. Remsen, Jr., J. D. Rising, D. F. Stotz, and K. Winker. 2015. Fifty-sixth supplement to the American Ornithologist Union Check-list of North American Birds. The Auk, Ornithological Advances, 132: 748-764. ______, _______, _______, _______, _______, _______, _______, _______, _______, _______, _______, _______, and ______. 2016. Fifty-seventh supplement to the American Ornithologist Union Check-list of North American Birds. The Auk,
Ornithological Advances, 133: 544-560. _______, K. J. Burns, C. Cicero, J. L. Dunn, A. W. Kratter, I. J. Lovette, P. C. Rasmussen, J. V. Remsen, Jr., J. D. Rising, D. F. Stotz, and K. Winker. 2017. Fifty-eighth supplement to the American Ornithologist Society Check-list of North American Birds. The Auk, Ornithological Advances, 134: 751-773. ______, _______, _______, _______, _______, _______, _______, _______, _______, _______, B. M. Winger, and K. Winker. 2018. Fifty-ninth supplement to the American Ornithologist Society‘s Check-list of North American Birds. The Auk,
Ornithological Advances, 135: 798-813. Cooper, B. A. and R. H. Day. 1998. Summer behavior and mortality of Dark-rumped Petrels and Newell’s Shearwaters at power lines on Kauai.
Colonial Waterbirds, 21(1): 11-19. _______ and R. H. Day. 1998. Summer Behavior and Mortality of Dark-rumped Petrels and Newells’ Shearwaters at Power Lines on Kauai. Colonial
Waterbirds, 21(1): 11-19.
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Day, R. H., B. A. Cooper, and T. C. Telfer. 2003. Decline of Townsend’s (Newell’s Shearwaters (Puffinus auricularis newelli) on Kauai, Hawaii. The Auk, 120: 669-679. David, R. E. 2018. Unpublished field notes – Hawai‘i 1980 – 2018. _______, and E. B. Guinther. 2013. Biological surveys conducted for the Pāhala Wastewater Treatment Plant Project, Ka‘ū District, Island of Hawai‘i. Prep for Fukunaga and Assoc. Inc. Rana Biological Consulting, Inc., 17 pp. Hawai‘i Department of Land and Natural Resources (HDLNR). 1998. Chapter 107. Threatened and Endangered Plants. Department of Land and Natural Resources. State of Hawaiʻi. Administrative Rule under Title 13. Subtitle 5, Part 1, dated March 23, 1998. _______. 2015. Chapter 124. Indigenous Wildlife, Endangered, Injurious Wildlife, Introduced Wild Birds, and Introduced Wildlife. Department of Land and Natural Resources. State of Hawaii. Administrative Rule under Title 13. Subtitle 5, Part 2, dated February 17, 2015. Exhibits dated November 1, 2014. Hawai‘i Department of Land and Natural Resources, Division of Forestry and Wildlife (HDLNR-DOFAW). 2016. Wildlife Lighting. PDF available at URL: http://dlnr.hawaii.gov/wildlife/files/2016/03/DOC439.pdf; last accessed on January 17, 2018. Hadley, T. H. 1961. Shearwater calamity on Kauai. Elepaio, 21: 60. Hue, D., C. Glidden, J. Lippert, L. Schnell, J. MacIvor and J. Meisler. 2001. Habitat Use and Limiting Factors in a Population of Hawaiian Dark-rumped Petrels on Mauna Loa, Hawai‘i. Pp. 234-242, in: : Scott, J. M, S. Conant, and C. Van Riper III (editors) Evolution, Ecology, Conservation, and
Management of Hawaiian Birds: A Vanishing Avifauna. Studies in Avian Biology No. 22. Cooper’s Ornithological Society, Allen Press, Lawrence, Kansas. Imada, C. T. 2012. Hawaiian Native and Naturalized Vascular Plants Checklist (December 2012 update). Bishop Museum Tech. Rept. 60. 380 pp. Palmer, D. D. 2003. Hawai`i’s Ferns and Fern Allies. University of Hawaii Press, Honolulu. 324 pp.
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Podolsky, R., D. G. Ainley, G. Spencer, L. de Forest, and N. Nur. 1998. Mortality of Newell’s Shearwaters Caused by Collisions with Urban Structures on Kaua‘i. Colonial Waterbirds, 21: 20-34. Reed, J. R., J. L Sincock, and J. P. Hailman 1985. Light Attraction in Endangered Procellariform Birds: Reduction by Shielding Upward Radiation. The Auk, 102: 377-383. Simons, T. R., and C. N. Hodges. 1998. Dark-rumped Petrel (Pterodroma
phaeopygia). In: A. Poole and F. Gill (editors). The Birds of North America, No. 345. The Academy of Natural Sciences, Philadelphia, PA. and the American Ornithologists Union, Washington, D.C. Sincock, J. L. 1981. Saving the Newellʻs Shearwater. Pp. 76-78 in: Proc. of the Hawaii Forestry and Wildllife Conference, 2-4 October 1980. Department of Land and Natural Resources, State of Hawaii, Honolulu. Staples, G. W. and D. R. Herbst. 2005. A Tropical Garden Flora. Plants Cultivated
in the Hawaiian Islands and other Tropical Places. Bishop Museum, Honolulu. 908 pp. Telfer, T. C. 1979. Successful Newell’s Shearwater Salvage on Kauai. ‘Elepaio, 39:71 _______, J. L. Sincock, G. V. Byrd, and J. R. Reed. 1987. Attraction of Hawaiian seabirds to lights: conservation efforts and effects of moon phase.
Wildlife Soc. Bull., 15: 406-413. U.S. Fish & Wildlife Service (USFWS). 1983. Hawaiian Dark-Rumped Petrel & Newell’s Manx Shearwater Recovery Plan. USFWS, Portland, Oregon. February 1983. _______. no date (a). National Wetlands Inventory website. U.S. Department of the Interior, Fish and Wildlife Service, Washington, D.C. Available online at URL: http://www.fws.gov/wetlands/ Data/Mapper.html; last accessed on July 1, 2018. ______. no date (b). USFWS Endangered Species. Available online at URL:
https://www.fws.gov/endangered/; Last visited on June 3, 2018 and Environmental Conservation Online System (ECOS), online at URL:
https://ecos.fws.gov/ecp/species‐reports; last visited on June 21, 2018.
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U.S. Geological Survey (USGS). 1923. 15-minute Series, Topographic Map, Pāhala Quadrangle. Wagner, W. L., D. R. Herbst and S. H. Sohmer. 1990. Manual of the Flowering
Plants of Hawai‘i: Volume I and II. Bishop Museum Special Publication 83. University of Hawai‘i Press. 1853 pp. ________ and ________. 1999. Supplement to the Manual of the flowering plants of
Hawai‘i, pp. 1855-1918. In: Wagner, W. L., D. R. Herbst, and S. H. Sohmer, Manual of the flowering plants of Hawai‘i. Revised edition. 2 vols. University of Hawaii Press and B.P. Bishop Museum.
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
Appendix C-1
Endangered Species Act Section 7 Consultation
February 2020
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
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February 2020
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December 21, 2018 Eldridge Naboa, Fish and Wildlife Biologist U.S. Department of the Interior U.S. Fish and Wildlife Service 300 Ala Moana Boulevard Room 3-122, Box 50088 Honolulu, HI 96850
Subject: Pāhala Large Capacity Cesspool (LCC) Replacement Project; Pāhala, Ka‘ū
District, Hawai‘i (01EPIF00‐2018‐TA‐0275) – Request for Concurrence Dear Mr. Naboa: On behalf of the United States Environmental Protection Agency (EPA) and the County of Hawai‘i (County), and as the designated non-Federal representative for consultations under Section 7 of the Endangered Species Act, we respectfully request concurrence from the U.S. Fish and Wildlife Service (FWS) that the above-referenced project is not likely to adversely affect federally-listed threatened and endangered species or critical habitat. This consultation addresses the project’s potential impacts to the following eight species that were identified in correspondence with FWS dated April 23, 2018 as having the potential to occur in the vicinity of the project area: Hawaiian hoary bat (Lasiurus cinereus semotus), Hawaiian Hawk (Buteo solitarius), Nēnē (Branta
sandvicensis), Hawaiian Petrel (Pterodroma sandwichensis), Band-rumped Storm-Petrel (Oceanodroma castro), Newell’s Shearwater (Puffinus newelli), Hawaiian Stilt (Himantopus
mexicanus knudseni), and Hawaiian Coot (Fulica alai). The proposed project is located in Pāhala, Ka‘ū District, Hawai‘i. Funding for this project is provided by a Special Appropriation Grant from EPA and a loan from the State of Hawai‘i Clean Water State Revolving Fund (SRF). The project involves replacing two large-capacity cesspools (LCCs) with a new County-owned wastewater collection system to be constructed primarily within the existing public right-of-way (ROW); a treatment and disposal system that will occupy a 14.9-acre site that is currently a privately-owned macadamia nut plantation; and closure of the two LCCs. See enclosed map of project location for reference (Site 7 on the attached Figure 1).
Project Description/Action Area The proposed project is located in the community of Pāhala, a former sugar farming and processing operation, in the Ka‘ū District, Island of Hawaiʻi. In 1999, pursuant to the Safe Drinking Water Act, EPA promulgated regulations (40 CFR 144.14) requiring the elimination or closure of all LCCs by April 2005. In 2010, the C. Brewer company transferred the ownership and operation of the LCCs to the County, which is bringing these wastewater systems into compliance with the Safe Drinking Water Act.
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The proposed project will consist of constructing a new wastewater collection system primarily within the public ROW and a treatment and disposal system located on a 14.9-acre parcel that is currently privately owned (TMK: 9-6-002: 018), but will be acquired by the County (Figure 1). The wastewater collection system will consist of approximately 12,150 linear feet of 8 to 16-inch gravity-flow piping located within eight public streets. The treatment and disposal facility will be a land-based system consisting of a headworks with screens to remove debris and an odor control unit; a series of three 0.4-acre aerated lagoons and a fourth, 0.8-acre aerated lagoon; an operations building with adjacent disinfection system; a subsurface flow constructed wetland; and four slow-rate (SR) land treatment basins, which will be surrounded by berms on all sides (Figure 2). SR land treatment involves irrigation of land and vegetation with treated wastewater effluent. Significant additional treatment occurs as the water percolates through the soil. The facility’s treatment capacity will be approximately 190,000 gallons per day. The property will be cleared of trees and will be enclosed by a 6-foot-high chain link security fence (Figure 2). No more than two Cook pines (Araucaria columnaris) along Maile Street will be removed to accommodate the new driveway to the treatment and disposal facility. Once the new system is in place, the County will close and abandon the existing LCCs. This system includes some lines located in the backyards of residential lots and some within public streets; therefore, abandoning the lines in place will minimize impacts related to their excavation and removal. The cut ends of the abandoned laterals to the collection system will be plugged with concrete to prevent unauthorized use of the old system and to avoid the need to maintain an unused underground hydraulic conduit. The two LCCs will also be abandoned and closed; the specific closure methods have not yet been determined but will be consistent with the requirements set forth in Hawai‘i Administrative Rules §11-23-19.
Consultation History with FWS Representatives of EPA and the County have conferred with FWS regarding this project. In the process of preparing the Draft Environmental Assessment (EA), the County’s representative (Wilson Okamoto Corporation) submitted a written request for comments to FWS in a letter dated March 15, 2018. In a letter dated April 23, 2018, FWS identified the eight federally-listed species having the potential to occur in the vicinity of the project area, as well as FWS’s recommended impact avoidance and minimization measures for each species. The project team subsequently provided a written summary of the botanical and biological field studies that were undertaken as part of the Draft EA in a letter to FWS dated August 20, 2018. Copies of the three corresponding letters are enclosed. The project team also held a conference call with FWS on October 17, 2018 and has incorporated feedback from the phone call into our assessment of potential impacts and planned avoidance and mitigation measures.
Summary of August 2018 Biological Field Survey Botanical and biological field surveys were conducted in August 2018 within the proposed project area, including the streets and adjacent areas of the proposed wastewater collection system and the 14.9-acre wastewater treatment and disposal facility site. The field surveys confirmed that the collection system will be installed along roadways within Pāhala that are already paved, and that vegetation that will be impacted consists of ornamental plants in private yards. Surveys of the wastewater treatment and disposal facility site documented 52 species of vascular plants; however, only two species are considered native to the Hawaiian Islands and both are widely-distributed indigenous species that are not listed as threatened, endangered, or of special
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concern. An avian survey of the project site recorded 13 bird species, all of which are established alien species. While not documented during the field survey of the project area, the field survey contractor noted in their survey report that the Hawaiian Petrel and Newell’s Shearwater have been observed flying over the general project area between April and the end of November each year. No species of plants or animals currently proposed for listing or listed under either the federal or State of Hawai‘i endangered species statutes were recorded by the survey.
Federally‐designated Critical Habitat ERG reviewed the FWS Environmental Conservation Online System (ECOS) and contacted FWS by email in November 2018 to determine whether any proposed or final critical habitat of federally listed threatened or endangered species has been designated in the vicinity of the project area. Per ECOS, critical habitat is designated at several locations throughout the County; however, no proposed or final critical habitat has been designated at or in the immediate vicinity of the project area. This finding was confirmed by FWS in email correspondence dated November 29, 2018. The project area is located approximately 3.1 miles northwest of the nearest critical habitat along the island’s shoreline, which has been designated for the federally and state-endangered Hawaiian monk seal (Monachus schauinslandi). Based on the distance, the 600- to 900 feet elevation of the project area, and the nature of project activities, impacts to this or other critical habitats in the County are not anticipated.
Anticipated Impacts to Federally‐listed Species and Proposed Avoidance Measures
Hawaiian Hoary Bat Potential impacts to Hawaiian hoary bat from construction and operation of the project include injury or mortality of young bats if woody vegetation is cleared during the pupping season and entanglement in barbed wire fencing. All clearing activities of trees taller than 15 feet will be scheduled to take place outside the pupping season of the Hawaiian hoary bat, which lasts from June 1 to September 15. Additionally, to avoid adverse impacts to Hawaiian hoary bats no barbed wire will be used on the security fence or elsewhere on the project site.
Hawaiian Hawk Potential impacts to Hawaiian Hawk from construction and operation of the project include destruction of a nest by cutting a tree in which a nest is located, either during or outside of the breeding season. Noise-related disturbance resulting from construction activities (including tree clearing and facility construction) in the vicinity of a nest during the breeding season is a second potential impact. Noise-related disturbance in close proximity to a nest has the potential to result in nest failure due to adult nest abandonment and increased exposure of chicks and juveniles to inclement weather or predators. The 14.9-acre parcel proposed for the treatment and disposal facility is currently a monotypic macadamia nut plantation. The existing macadamia nut plantation likely does not provide suitable nesting habitat for Hawaiian Hawks; therefore, tree clearing within this area (whether during or outside the breeding season) is not expected to directly harm or destroy Hawaiian Hawk nests. Additionally, the Cook pines along Maile Street are not expected to provide suitable nesting habitat
4 of 5 December 21, 2018
for Hawaiian Hawks, due in part to their location alongside a road. Removal of the one or two Cook pines as necessary to accommodate the new driveway is not expected to directly harm or destroy Hawaiian Hawk nests. Regardless of the time of year, no trimming or cutting of trees that contain a Hawaiian Hawk nest will be performed. If feasible, to avoid noise-related disturbance during the Hawaiian Hawk breeding season (which lasts from March 1 to September 30), all tree clearing activities will be scheduled to occur outside the breeding season. If, however, tree clearing will occur during the breeding season, the County will seek technical assistance from FWS regarding appropriate survey methods to determine whether nesting Hawaiian Hawks are present near the area to be cleared. Depending on the timing of the survey, methods may include visual nest searches and/or callback surveys by a qualified biological monitor. If surveys document the presence of an active Hawaiian Hawk nest during the breeding season within 1,600 feet of the area to be cleared, the County will postpone tree clearing activities until after the breeding season or until authorized in writing by FWS that activities may proceed. Additionally, if site preparation, construction, or other substantial noise-generating activities (following the completion of tree clearing) will occur during the Hawaiian Hawk breeding season, the County will seek technical assistance from FWS regarding whether any surveys of the surrounding area are necessary. If surveys document the presence of an active Hawaiian Hawk nest during the breeding season within 1,600 feet of the footprint of site preparation and construction activities, the County will seek technical assistance from FWS to ensure that any noise-generating activities do not have the potential to result in nest abandonment.
Waterbirds Potential impacts to Nēnē, Hawaiian Stilt, and Hawaiian Coot are primarily related to the creation of suboptimal habitat at the treatment and disposal facility. Specifically, the constructed lagoons may represent an attractive nuisance due to the potential for spread of botulism, and the presence of waterbirds and their nests at the facility may attract non-native mammalian predators to the area. Several measures are proposed to discourage and monitor waterbird use of the facility and exclude predators from the area. Design elements of the proposed facility expected to discourage waterbird use of the area include the following: the total proposed acreage of new lagoon surface (approximately 2 acres) is relatively small, as compared to approximately 20 acres of lagoons at the Kealakehe Wastewater Treatment Plant in Kailua-Kona, Hawai‘i; the subsurface-flow-constructed-wetland will not have areas of open water, which would attract waterbird prey; asphalt rather than gravel will be used to provide access around the lagoons; the lagoons will be lined with a high-density polyethylene (HDPE) liner, rather than with substrate that would support vegetation growth; shade balls will be used in the largest lagoon (Lagoon 4) to discourage algal growth, and are also expected to discourage use of the lagoon by waterbirds; and the lagoons will be bordered by groves rather than bare land. In addition, the security fence around the perimeter of the treatment and disposal facility is expected to exclude larger non-native mammalian predators including dogs and wild pigs. For the first year following completion of construction, the County will provide for a biological monitor to assess waterbird use of the facility on a weekly basis. Weekly post-construction monitoring will include checking for predators, sick or dead waterbirds, and the presence of threatened and endangered species. Following the completion of construction, the County will coordinate with FWS to determine the specific approach for communicating the monitoring results.
Seabirds
Potential impacts to Hawaiian Petrel, Band-rumped Storm-Petrel, and Newell's Shearwater from the construction and operation of the project include potential adverse effects resulting from nighttime lighting at the facility. Outdoor, nighttime lighting during construction and operation of the facility could result in seabird disorientation, fallout, and injury or mortality.
To avoid adverse impacts to seabirds during the construction period, the construction contract will include a blanket statement prohibiting construction activities after dark. To avoid impacts to seabirds during the operation of the facility, the proposed facility includes use of a down-shielded light exterior fixture mounted below the roof overhang. The light fixture near the headworks will also be down-shielded. The exterior lights will be used at night only in the event of an emergency that requires an immediate response. All fixtures will meet requirements for outdoor lighting as set forth in Hawai'i Code Chapter 14 (General Welfare).
Summary
The FWS has identified eight federally-listed threatened and endangered species which have the potential to occur in the vicinity of the project area. The impact avoidance and minimization measures described above have been specifically developed for the project in consultation with FWS. EPA has reviewed and concurred with the analysis conducted and proposed measures. Therefore, on behalf of EPA and the County, we respectfully request concurrence from the FWS that the project is not likely to adversely affect the eight federally-listed threatened and endangered species which have the potential to occur in the vicinity of the project area.
We greatly appreciate your input during this consultation. If you have any questions, please feel free to contact me at (703) 615-4371 or by email at patrick.goodwin@erg.com.
Sincerely,
Patrick Goodwin Environmental Scientist
Enclosures
5 of 5 December 21, 2018
Figure 1 – Project Location Map
Figure 1. Project Location Map (Site 7)
Figure 2. Preliminary Site Plan for New Wastewater Treatment and
Disposal Facility at Site 7
Figure 2. Preliminary Site Plan for New Wastewater Treatment and Disposal Facility at Site 7
Pre-consultation Letter to FWS, March 15, 2018
WILSON OKAMOTO CORP ORATIO N
INNOVATORS• PLANNERS• ENGINEERS
10349-01 March 15, 2018
Ms. Mary Abrams, Field Supervisor U.S. Department of the Interior Fish and Wildlife Service 300 Ala Moana Boulevard Room 3-122, Box 50088 Honolulu, HI 96850
Subject: Draft Environmental Assessment, Pre-Assessment Consultation; Pahala Community Large Capacity Cesspool Replacement Pa'au'au, Ka'u, Hawai'i Request for Comment
Dear Ms. Abrams:
Wilson Okamoto Corporation is preparing a Draft Environmental Assessment (EA) for the County ofHawai'i Department of Environmental Management Piihala Community Large Capacity Cesspool Replacement, Pii'au'au, Ka'u, Hawai'i project. The Piihala Community Large Capacity Cesspool Replacement project will be funded by a U.S. Environmental Protection Agency (EPA) Special Appropriation Grant and by the State of Hawaii Clean Water State Revolving Fund (SRF) loan program. A project summary sheet and location map are enclosed for your information.
As part of the Draft EA pre-assessment consultation process, we are soliciting comments you may have on the proposed Piihala Community Large Capacity Cesspool Replacement project. Please submit your comments to:
Wilson Okamoto Corporation 1907 South Beretania Street, Suite 400 Honolulu, Hawaii 96826 Attn: Earl Matsukawa, AICP
We would appreciate your comments by April 16, 2018. If you have any questions, please call me at 808.946.2277 or fax to 808.946.2253.
Enclosures cc: D.Beck, DEM (w/o encl.)K. Rao, EPA (w/o encl.)C.Lekven, PE, BC (w/o encl.)
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
PROJECT SUMMARY
Pahala Community Large Capacity Cesspool Closure
Pa'au'au, Ka'u, Island of Hawai'i
1.Introduction
Tax Map Key: 9-6-002:018
The community of Pahala is located about 52 miles southeast of Hilo, in the Ka'u District, Island of
Hawai'i. Pahala is located west (mauka) of Mamalahoa Highway (State Route 11) about 3.8 miles
from the shoreline with most of the community lying between 980 feet mean sea level (msl) on the
western end and approximately BOO feet msl on the eastern end. See Figure 1. The Pahala
community had its start in 1876 with establishment of the Hawaiian Agricultural Company to develop
the sugar industry in Hawai'i. For the next 120 years or so, Pahala was a major sugar producing area.
However, by the early 1990s there was a major downturn in the sugar market. Thus, beginning in
1994, the sugar mill in the town was shut down and dismantled. By 1996, the Ka'u Sugar Company,
the successor to the Hawaiian Agricultural Company, closed and, subsequently, the sugar cane fields
were cleared and the lands now grow macadamia nut and coffee trees. The population in Pahala was
approximately 1,405 persons in 2016, the most current estimate.
Founded in 1826, C. Brewer was both the oldest company in Hawai'i and a major developer of the
sugar industry in Paha la. For about the last 60 years, approximately 50 percent of the residential
units in Pahala have been serviced by a wastewater collection and disposal system constructed,
operated and maintained by C. Brewer. The collection system consisted of sewer lines, some of
which were located in the streets and others routed in the backyards of private parcels. The disposal
system consisted of two large capacity cesspools (LCCs) within the community.
In 1998, the US Environmental Protection Agency (EPA) issued regulations (40 CFR 144.14) requiring
the elimination or closure of all large capacity cesspools used for wastewater disposal by April 5,
2005. In 2003, C. Brewer requested assistance from the County to close their LCCs. Subsequently,
the County held a community meeting to present sewer system replacement alternatives. Voting took
place by mail to choose the preferred sewer improvement alternative, resulting in 87 percent of
returned ballots in favor of installing a new sewer collection, treatment and disposal system to be
operated and maintained by the County.
In 2006, in anticipation of its dissolution, C. Brewer requested the County construct and maintain a
new community sewer system. The County subsequently agreed by way of a County Council
Resolution, to enter into a formal agreement to assume ownership of the C. Brewer constructed
collection system and the two LCCs by April 30, 2010 and to construct and maintain a new community
sewer system. As part of the County's agreement, C. Brewer agreed to install laterals to certain of the
residential properties.
In 2007, the County proposed a new collection system and a wastewater treatment system, consisting
of large capacity septic tanks and converting the existing LCCs into seepage pits for disposal of the
treated effluent. In 2008, the combination of the LCCs being in poor and failing condition and the poor
results from soil percolation tests influenced the County to consider acquiring a larger land area to
construct a secondary treatment system. Such a system could allow a higher level of wastewater
treatment and disposal, as well as accommodate existing Pahala properties not currently served by
the LCC system in addition to expanding the system to accommodate possible community growth.
2.Project Description
The County of Hawai'i. Department of Environmental Management (DEM) is proposing to construct
wastewater system improvements to replace the current system servicing Pahala, now owned by the
County. The wastewater system improvements would allow the County to comply with EPA
PROJECT SUMMARY
Pahala Community Large Capacity Cesspool Closure
Pa'au'au, Ka'u, Island of Hawal'i
Tax Map Key: 9-6-002:018
regulations requiring closure of the LCCs and to construct a system meeting current State of Hawai'i
Department of Health (DOH) and DEM design guidelines for the collection, treatment and disposal of
the treated effluent. The Pahala Community Large Capacity Cesspool Closure project improvements
would consist of a new wastewater collection system located within the public right-of-way and a
treatment and disposal system located on a currently privately-owned parcel (TMK: 9-6-002: 018)
which will be acquired by the County. The Pahala Community Large Capacity Cesspool Closure
project would be funded by an EPA Special Appropriation Grant and by the State of Hawai'i Clean
Water State Revolving Fund (SRF) loan program.
The wastewater collection system would be located within 7 public streets; Maile Street; 'llima Street;
Huapala Street; HTnano Street; Hala Street; all located in the southern portion of the community and
Puahala Street; and PTkake Street located on the eastern end. These streets serve the residential
areas and have two travel lanes with unpaved shoulders and no improved sidewalks. The collection
system would consist of approximately 11,000 linear feet of gravity flow piping ranging from 8 to 12
inches in diameter. The collection system is not anticipated to include pump stations, nor will the
system collect stormwater runoff. The number of manholes in the system will be determined during
the detail design phase. The County's sewer standards show the trenches for sewer lines would
require at least 4 feet of cover from the top of the pipe to grade and 12 inches of cushion material on
both sides of the line and 6 inches below the line. Therefore, the typical sewer trenches will be 3 feet
wide and at least 6 feet deep.
The treatment and disposal system would be a land-based system located southeast of the developed
community and would be designed to treat flows of approximately 190,000 gallons per day. The EPA
defines land treatment as "the application of appropriately pre-treated municipal and industrial
wastewater to the land at a controlled rate in a designed and engineered setting. The purpose of
the activity is to obtain beneficial use of these materials, to improve environmental quality, and to
achieve treatment goals in a cost-effective and environmentally sound manner".
The proposed treatment and disposal system would occupy about 14 acres and consist of a
headworks with screens to remove debris and an odor control unit, four lined aerated lagoons of
about 0.3 acres each, an operations building with adjacent disinfection system to remove pathogens,
a subsurface flow constructed polishing wetland to remove nitrogen and four slow rate (SR) land
treatment basins which will be surrounded by berms on all four sides. SR land treatment involves
irrigation of land and vegetation with the treated effluent. Significant additional treatment is
provided as the water percolates through the soil. The vegetation uptakes the nutrients in the
effluent as fertilizer, and transpires a portion of the applied water. A security fence will be
constructed along the perimeter of the site.
3.Anticipated Impacts
Project impacts would be primarily related to construction of the trenches for placement of the
collection system lines and construction of the land-based treatment and disposal system. These
activities would create dust and noise while work occurs in the streets and in the area of the land
treatment and disposal system, which will include removal of existing macadamia nut trees within the
14 acre project site. As the collection system is constructed, the streets will be restored for vehicle
travel. Upon completion of the treatment and disposal facilities, the project will operate without the
need for DEM employees to be on-site. Weekly monitoring visits will be sufficient to insure routine
proper operation, and a telemetry system will alert DEM employees of abnormal conditions to allow
timely response when they occur.
Island of Hawaii
Legend
Collection System
Disposal and Treatment Site
FIGURE 1
PROJECT LOCATION MAP
PAHALA COMMUNITY LARGE CAPACITY CESSPOOL CLOSURE PROJECTCOUNTY OF HAWAII DEPARTMENT OF ENVIRONMENTAL MANAGMENT
1 inch = 2,000 feet.
¯
0 2,000 4,0001,000 Feet
0 500250Meters
Ma
m
a
l
a
h
o
a
H
i
g
h
w
a
y
ProjectLocation
CollectionSystem
Disposal andTreatment Site
Hilo
Pahala
Kailua-Kona
Honokaa
Waiaka Source:State OP &ESR I
Pre-consultation Comments from FWS, April 23, 2018
United States Department of the Interior
FISH AND WILDLIFE SERVICE Pacific Islands Fish and Wildlife Office 300 Ala Moana Boulevard Honolulu, Hawaii 96850
In Reply Refer To:
01EPIF00-2018-TA-0275 April 23, 2018
Mr. Earl Matsukawa, AICP Project Manager Wilson Okamoto Corporation 1907 South Beretania Street, Suite 400
Honolulu, HI 96826
Subject: Comments for the Draft Environmental Assessment for the County of Hawaii Department of Environmental Management Pahala Community Large Capacity Cesspool Replacement, Paauau, Kau, Island and County of Hawaii
Dear Mr. Matsukawa: The U.S. Fish and Wildlife Service (Service) received your correspondence on April 9, 2018, requesting technical assistance in the preparation for the Draft Environmental Assessment for the
County of Hawaii Department of Environmental Management Pahala Community Large Capacity Cesspool (LCC) Replacement in Paauau, Kau, (TMK: 9-6-002: 018). The Service offers the following comments to assist you in your planning process so that impacts to trust resources can be avoided through site preparation, construction, and operation. Our comments are provided under the authorities of the Endangered Species Act of 1973 (ESA), as amended (16
U.S.C 1531 et seq.). The County of Hawaii Department of Environmental Management (DEM) is proposing to construct wastewater system improvements to replace the current system servicing Pahala, now owned by the County. The wastewater system improvements would allow the County to comply
with Environmental Protection Agency (EPA) regulations requiring closure of the LCC’s and to construct a system meeting current State of Hawaii Department of Health and DEM design guidelines for the collection, treatment, and disposal of the treated effluent. The Pahala Community LCC closure project improvements would consists of a new wastewater collection system located within the public right-of-way and a treatment and disposal system located on a
currently privately-owned parcel which would be acquired by the County. The Pahala LCC closure project would be funded by the EPA Special Appropriation Grant and by the State of Hawaii Clean Water State Revolving Fund loan program. Based on information you provided and pertinent information in our files, including data
compiled by the Hawaii Biodiversity and Mapping Project, eight (8) listed species that have the potential to either be in or fly through the vicinity of the project area: The federally endangered Hawaiian hoary bat (Lasiurus cinereus semotus), Hawaiian hawk (Buteo solitarius), Nene
Mr. Earl Matsukawa 2
Branta (=Nesochen) sandvicensis)), Hawaiian petrel (Pterodroma sandwichensis), Band-rumped storm-petrel (Oceanodroma castro), the threatened Newell’s shearwater (Puffinus auricularis newelli), Hawaiian stilt (Himantopus mexicanus knudseni), and the Hawaiian coot, (Fulica alai).
Avoidance and Minimization Measures
Hawaiian hoary bat 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 three 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
incorporating 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. Hawaiian hawk The Hawaiian hawk is known to occur across a broad range of forest habitats throughout the
Island of Hawaii. Loud, irregular and unpredictable activities, such as using heavy equipment or building a structure, near an endangered Hawaiian hawk nest may cause nest failure. Harassment of Hawaiian hawk nesting sites can alter feeding and breeding patterns or result in nest or chick abandonment. Nest disturbance can also increase exposure of chicks and juveniles
to inclement weather or predators.
To avoid and minimize impacts to Hawaiian hawks we recommend you consider incorporating the following applicable measures into your project description:
• If work must be conducted during the March 1 through September 30 Hawaiian hawk breeding season, have a biologist familiar with the species conduct a nest search of the project footprint and surrounding areas immediately prior to the start of construction activities. o Pre-disturbance surveys for Hawaiian hawks are only valid for 14 days. If
disturbance for the specific location does not occur within 14 days of the survey, conduct another survey.
• No clearing of vegetation or construction activities within 1,600 feet of any active Hawaiian hawk nest during the breeding season until the young have fledged.
• Regardless of the time of year, no trimming or cutting trees containing a hawk nest, as nests may be re-used during consecutive breeding seasons. Nene Nene are found on the islands of Hawaii, Maui, Molokai, and Kauai predominately, with a small
population on Oahu. They are observed in a variety of habitats, but prefer open areas, such as
Mr. Earl Matsukawa 3
pastures, golf courses, wetlands, natural grasslands and shrublands, and lava flows. Threats to the species include introduced mammalian and avian predators, wind facilities, and vehicle strikes. To avoid and minimize potential project impacts to Nene we recommend incorporating the
following applicable measures into your project description:
• Do not approach, feed, or disturb Nene.
• If Nene are observed loafing or foraging within the project area during the Nene breeding
season (September through April), have a biologist familiar with the nesting behavior of Nene survey for nests in and around the project area prior to the resumption of any work. Repeat surveys after any subsequent delay of work of three or more days (during which the birds may attempt to nest).
o Cease all work immediately and contact the Service for further guidance if a
nest is discovered within a radius of 150 feet of proposed work, or a previously undiscovered nest is found within said radius after work begins.
• In areas where Nene are known to be present, post and implement reduced speed limits, and inform project personnel and contractors about the presence of endangered species
on-site. Hawaiian petrel, Band-rumped storm-petrel, and Newell’s shearwater 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 avoid and minimize potential project impacts to seabirds we recommend you incorporate the following applicable measures into your project description:
• Fully shield all outdoor lights so the bulb can only be seen from below bulb height and only use when necessary.
• 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. Hawaiian stilt and Hawaiian coot 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.
Based on the project details provided, our information suggests that your project may result in standing water or the creation of open water, thus attracting Hawaiian waterbirds to the site. In particular, the Hawaiian stilt is known to nest in sub-optimal locations (e.g. any ponding water),
Mr. Earl Matsukawa 4
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 implement reduced speed limits, and inform project personnel and contractors about the presence of endangered species on-site.
• If water resources are located within or adjacent to the project site, incorporate applicable
best management practices regarding 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 have fledged. Do not conduct potentially disruptive activities or habitat alteration within this buffer. 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 fledge to ensure that Hawaiian
waterbirds and nests are not adversely impacted. Invasive Species To avoid and minimize the risk of the road construction introducing harmful invasive pests including coqui, ants, and weeds into the project sites, we recommend the following measures be
implemented by project contractors:
• Vehicles, machinery, and equipment must be thoroughly pressure washed and visibly free of mud, dirt, plant debris, frogs and frog eggs, insects and other debris. A hot water wash is preferred. Areas of particular concern include bumpers, grills, hood compartments,
areas under the battery, wheel wells, undercarriage, cabs, and truck beds.
• The interior and exterior of vehicles, machinery, and equipment must be free of rubbish and food. The interiors of vehicles and the cabs of machinery must be vacuumed clean. Floor mats will be sanitized with a solution of >70% isopropyl alcohol or a freshly mixed
10% bleach solution.
• All work vehicles, machinery, and equipment may be subject to inspection.
• Any vehicles, machinery, and equipment that do not pass inspection will be turned away.
• Staging areas must be kept free of invasive pests.
Minimize Spread of Rapid Ohia Death Rapid Ohia Death (ROD), a newly identified disease, has killed large numbers of mature ohia trees (Metrosideros polymorpha) in forests and residential areas of Hawaii Island. The disease is
Mr. Earl Matsukawa 5
caused by a vascular wilt fungus (Ceratocystis fimbriata). Crowns of an affected tree turn yellowish or brown within days to weeks and dead leaves typically remain on branches for some time. All ages of ohia trees can be affected and can have symptoms of browning of branches or leaves. As of early 2017 the disease has been confirmed in all districts except North and South
Kohala. Additional information on ROD can be found at:
http://www2.ctahr.hawaii.edu/forestry/downloads/ROD-trifold-03.2016.pdf and http://www2.ctahr.hawaii.edu/forestry/disease/ohia_wilt.html.
The following avoidance and minimization measures should be followed for projects working in
ohia forests or at sites with ohia trees on Hawaii Island: 1) A survey of the proposed project site should be conducted within two weeks prior to any tree cutting to determine if there are any infected ohia trees. If infected ohia are suspected
at the site, the following agencies should be contacted for further guidance.
a. Service – please contact the name at the bottom of this letter. b. Dr. J.B. Friday, University of Hawaii Cooperative Extension Service, 808-969-8254 or jbfriday@hawaii.edu c. Dr. Flint Hughes, USDA Forest Service, 808-854-2617, fhughes@fs.fed.us
d. Dr. Lisa Keith, USDA Agriculture Research Service,
808-959-4357, Lisa.Keith@ars.usda.gov 2) Both prior to cutting ohia and after the project is complete: a. Tools used for cutting infected ohia trees should be cleaned with a 70 percent
rubbing alcohol solution. A freshly prepared 10 percent solution of chlorine
bleach and water can be used as long as tools are oiled afterwards, as chlorine bleach will corrode metal tools. Chainsaw blades should be brushed clean, sprayed with cleaning solution, and run briefly to lubricate the chain. b. Vehicles used off-road in infected forest areas should be thoroughly cleaned. The
tires and undercarriage of the vehicle should be cleaned with detergent if they
have travelled from an area with ROD or travelled off-road. Use a pressure washer with soap to clean all soil off of the tires and vehicle undercarriage. c. Shoes and clothing used in infected forests should also be cleaned. Shoes should be decontaminated by dipping the soles in 70 percent rubbing alcohol to kill the
ROD fungus. Other gear can be sprayed with the same cleaning solutions.
Clothing can be washed in hot water and detergent. d. Wood of affected ohia trees should not be transported to other areas of Hawaii Island or interisland. All cut wood should be left on-site to avoid spreading the disease. The pathogen may remain viable for over a year in dead wood. The
Hawaii Department of Agriculture has passed a quarantine rule that prohibits
interisland movement, except by permit, of all ohia plant or plant parts. If this project should receive federal funding, federal permit, or any federal authorization, it will require a Section 7 consultation with the Service. The Service only conducts Section 7
consultations with the federal action agency or their designated representative.
Mr. Earl Matsukawa 6
Thank you for participating with us in the protection of our endangered species. If you have any further questions or concerns regarding this consultation, please contact Eldridge Naboa, Fish and Wildlife Biologist, 808-284-0037, e-mail: eldridge_naboa@fws.gov. When referring to this project, please include this reference number: 01EPIF00-2018-TA-0275.
Sincerely,
Jodi Charrier Acting Island Team Leader Maui Nui and Hawaii Island
Non‐Federal Representative Designation Letter to FWS, June 7, 2018
~D S%UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
~:,,.,REGIONIX
~_____75 Hawthorne Street\~/San Francisco,CA 941 05-3901LPRO~
JUN 072010
Jodi Charrier
Acting Island Team Leader
Maui Nui and Hawaii Island
Pacific Islands Fish and Wildlife Office
300 Ala Moana Boulevard
Honolulu,Hawaii 96850
SUBJECT:Designation of Non-Federal Representative under Section 7 of the
Endangered Species Act (Reference:O1EPIFOO-2018-TA-0275)
Dear Ms.Charrier:
The U.S.Environmental Protection Agency Region 9 (EPA)awarded a Special Appropriation
Act Project (SAAP)grant to the County of Hawaii for the Pahala Community Large Capacity
Cesspool (LCC)Replacement Project.This project triggers the application of the National
Environmental Policy Act (NEPA)and numerous Federal cross-cutting authorities including the
Endangered Species Act (ESA).
Pursuant to 50 C.F.R.§402.08,a Federal agency may designate a non-Federal representative to
conduct informal consultation or prepare a biological assessment by giving notice to the Director
of such designation.In accordance with 50 C.F.R. §402.08,EPA hereby designates Eastern
Research Group,Inc.(ERG)to act on EPA’s behalf when initiating the ESA consultation process
and prepare a biological assessment if needed in connection with the Pahala Community LCC
Replacement Project.Effective immediately,ERG may consult with the Fish and Wildlife
Service (FWS)to initiate the informal consultation process under Section 7 of the ESA,with
responsibilities described herein.
EPA requires,through grant provisions for federally-assisted SAAP projects, that grant
recipients implement such measures as are ultimately determined necessary or appropriate during
the ESA Section 7 consultation process to avoid adverse effects to listed species or adverse
modification of designated or proposed critical habitat.However,EPA will continue to be
ultimately responsible for compliance with the Section 7 requirements of the ESA and will
remain responsible for participating in the consultation process if:
•there is disagreement between relevant parties regarding the scope of the area of potential
effects,identification of endangered species or habitats, or evaluation of effects;or,
Printed on 100%Postconsumer Recycled Paper Process Chlorine Free.
••there is an objection from consulting parties or the public regarding findings or
determinations oi the implementation of agreed provisions
If you have any questions,please contact Kate Rao,Drinking Water Protection Section,at (415)
972-3533 or via email at rao.ka~e~.oy.
~erely,
Mike Montgomery
Assistant Director,Water Division
cc:
William Kurcharski,County of Hawaii
Dora Beck,County of Hawaii
2
Biological Survey Report, August 16, 2018
AECOS No. 1545
Biological survey for the Pāhala Community
Large Capacity Cesspool Closure Project on lot
TMK: 9‐6‐002:018, Ka‘ū District, Hawaiʻi Island
Prepared by:
AECOS, Inc. 45-939 Kamehameha Hwy, Suite 104 Kāne‘ohe, Hawai‘i 96744-3221 August 16, 2018
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Biological survey for the Pāhala Community
Large Capacity Cesspool Closure Project on lot
TMK: 9‐6‐002:018, Ka‘ū District, Hawaiʻi Island
August 16, 2018 Draft AECOS No. 1545
Eric Guinther and Reginald David
AECOS, Inc.
45‐939 Kamehameha Hwy, Suite 104
Kāne’ohe , Hawai’i 96744
Phone: (808) 234‐7770 Fax: (808) 234‐7775 Email: guinther@aecos.com
Introduction
The Hawai‘i County Department of Environmental Management, Wastewater Division is proposing to construct a wastewater treatment and disposal system (“Project”) to treat sewage collected in Pāhala, Ka‘ū District. The treatment and disposal system will be located on a property identified as TMK: 9-6-002:018, north of the intersection of Hawaii Belt Road (Māmalahoa Highway) and Maile Street. This report describes methods used and results of a biological survey conducted in the Project area in August 2018. The primary purpose of the survey was to determine whether any species currently proposed or listed as threatened or endangered under either federal or state endangered species statutes occur on, or could utilize resources within, the Project area. Project and Site Descriptions
The WWTP site encompasses the lower, approximately 15 ac (6 ha) of the subject parcel (TMK: 9-6-002:018). Presently the entire parcel is a macadamia nut (Macadamia integrifolia) orchard, but with the margins and two narrow windbreak tree lines dominated by other species of trees and herbaceous plants dividing the orchard into northwest-southeast trending units. In addition to the WWTP site, a proposed transmission pipe would be constructed to the northwest through the orchard up to Maile Street. From Maile Street a collection system is planned for many of the streets within Pāhala town (see Figure 1).
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Figure 1. Project and survey areas marked in red, Pāhala.
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Macadamia nut trees form a closed crown of dense leaf growth (see cover photo), creating deep shade within most parts of the grove. The dominant understory in these deeply shaded areas is germinating mac nut trees. Methods Botanical Survey The botanical survey was undertaken on August 13, 2018 and entailed a wandering pedestrian transect that traversed the subject property, including the area extending north to Maile Road proposed for installation of a collector main. A “windshield” survey was conducted along all the streets proposed for the collection system beyond the surveyed parcel. Plant species were identified as they were encountered and notations made in a field notebook, which was used to develop qualitative abundance values for each species as the survey progressed. On a strictly area basis, only macadamia nut trees, Guinea grass (Megathyrsus maximus), and perhaps a couple of other species would have a ranking above uncommon. So, abundance values in this report are relative to areas that support species other than the macadamia nut trees, such as the road verges and other areas surrounding the orchard, unmaintained areas within the orchard, including narrow windbreak lanes that divide the orchard plots into units. The survey period encompassed the early dry season, but most of the vegetation was in a relatively healthy state (the orchard is irrigated as needed). However, early in the dry season found most trees and shrubs absent fruit or flower. This slight limitation did not compromise the discovery of native species of plants. Plant names used herein follow Manual of the Flowering Plants of Hawai‘i (Wagner, Herbst, & Sohmer, 1990; Wagner & Herbst, 1999) for native and naturalized flowering plants, Hawai‘i’s Ferns and Fern Allies (Palmer, 2003) for ferns, and A Tropical Garden Flora (Staples & Herbst, 2005) for ornamental and crop plants. More recent name changes for naturalized plant species follow Imada (2012). Avian Survey Six avian count stations were sited roughly equidistant from each other, four within the WWTP area and two along the collection pipe route upslope to Maile Street. Stations were sited approximately 150 m (490 ft) apart from each other. A single eight-minute avian point count was made at each of the count stations. Field observations were made with the aid of Leica 8 X 42 binoculars and by
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listening for vocalizations. The avian counts were conducted in the early morning hours. Time not spent counting at point-count stations was used to search the site for species and habitats not observed during the point counts. Weather conditions were excellent with winds of between 1 and 5 kph and no precipitation. The avian phylogenetic order and nomenclature used in this report follows the
AOU Check‐List of North American Birds (American Ornithologists’ Union, 1998), and the 42nd through the 59th supplements to the Check-List (American Ornithologists’ Union, 1998, 2000; Banks et al., 2002, 2003, 2004, 2005, 2006, 2007, 2008; Chesser et al., 2009, 2010, 2011, 2012, 2013, 2014, 2015, 2016, 2017, 2018).
Mammalian Survey
With the exception of the endangered Hawaiian hoary bat (Lasiurus cinereus
semotus) or ‘ōpe‘ape‘a, all terrestrial mammals currently found on the Island of Hawai’i are alien species, and most are ubiquitous. The survey of mammals was limited to visual and auditory detection, coupled with visual observation of scat, tracks, and other animal sign. A running tally was kept of all terrestrial mammalian species detected within the project area. Results Vegetation Vegetation within the areas surveyed comprises a macadamia nut orchard of mature trees, unmaintained areas dominated outside the orchard by Guinea grass, lanes of windbreak trees oriented between orchard units, and (mostly) mowed road verge areas. Within the orchard are scattered small plots of ruderal herbaceous plants, in most cases dominated by nodeweed (Synedrella
nodiflora), but if generally only lightly shaded, a number of other herbaceous species. The windbreak lanes consist of two rows of trees: silk oak (Grevelia
robusta) and paperbark (Melaleuca quinquenervia) and are used in orchard maintenance to stack cut branches and logs. These lanes support many of the herbaceous plants recorded from the orchard. The proposed sewerage collection system will be installed along already paved roadways within Pāhala. The survey in these areas revealed the vegetation to be entirely maintained yards of ornamental plants.
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Flora A listing of the plant species recorded during the August 2018 survey is provided as Table 1. In all, the listing has 52 species of vascular plants: 2 ferns, one gymnosperm, and 49 species of angiosperms (flowering plants). Only two species (4%) are regarded as native to the Hawaiian Islands and both are indigenous (native, but also distributed elsewhere in the Pacific). Found in low numbers are the ubiquitous, ruderal ‘uhaloa (Waltheria indica) and the common blue- or purple-flowered morning glory vine: koali ‘awa (Ipomoea indica). Being widely distributed indigenous species, neither is listed as threatened or endangered or of any special concern. Table 1. Plant species identified during the August 13, 2018 survey of TMK: 9-6-002:018, Pāhala, Ka‘ū District, Hawai‘i. Species listed by family Common name Status Abundance Notes FERNS NEPHROLEPIDACEAE Nephrolepis multiflora (Roxb.) F.M. Jarrett ex C.V. Morton sword fern Nat R PTERIDACEAE Pityrogramma calomelanos (L.) Link
silver fern Nat R <1> GYMNOSPERMS ARAUCARIACEAE Araucaria columnaris (G. Forst.) J.D. Hook. Cook pine Nat O <1> FLOWERING PLANTS DICOTYLEDONS AMERANTHACEAE Amaranthus spinosus L. spiny amaranth Nat R APOCYNACEAE Carissa macrocarpa (Ecklon) A. de Cand. natal plum Orn R Nerium oleander L. olreander Orn R ARALIACEAE Schefflera actinophylla (Endl.) Harms umbrella tree Nat U ASTERACEAE (COMPOSITAE) Ageratum conyzoides L. maile hohono Nat R <1>
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Table 1 (continued). Species listed by family Common name Status Abundance NotesASTERACEAE (cont.) Bidens pilosa L. ki; beggartick Nat U <2> Calyptocarpus vialis Less. --- Nat O <1> Conyza bonariensis (L.) Cronq. hairy horseweed Nat C <2> Crassocephalum crepidioides (Benth.) S. Moore --- Nat R Cyanthillium cinereum L. little ironweed Nat U <1> Lactuca serriola L. prickly lettuce Nat U <1> Indet. ruderal weed Nat R <3> Synedrella nodiflora (L.) Gaertn. nodeweed Nat AA <2> BASELLACEAE Anredera cordifolia (Ten.) Steenis Madeira vine Nat R <3> BRASSICACEAE Lepidium virginicum L. --- Nat R <2> CAPPARACEAE Cleome gynandra L. wild spider flower Nat O <1> CONVOLVULACEAE Ipomoea indica (J. Burm.) Merr. koali ‘awa Ind R Ipomoea obscura (L.) Ker-Gawl. --- Nat O Merremia tuberosa (L.) J. Rendle wood rose Nat R CUCURBITACEAE Momordica charantia L. wild bitter melon Nat O EUPHORBIACEAE Euphorbia heterophylla L. kaliko Nat U <1> Euphorbia hirta L. garden spurge Nat O <2> Ricinus communis L. castor bean Nat C <2> FABACEAE Acacia confusa Merr. Formosan koa Nat R Leucaena leucocephala (Lam.) deWit koa haole Nat R <2> Macroptilium atropurpureum (DC.) Urb. ‐‐‐ Nat U <1> Neonotonia wightii (Wight & Arnott) Lackey
glycine vine Nat AA <2> LAMIACEAE Leonotis nepetifolia (L.) R. Br. lion’s ear Nat O <2> MALVACEAE Abutilon grandifolium (Willd.) Sweet hairy abutilon Nat R Malvastrum coromandelianum (L.) Garcke false mallow Nat O <2> Sida rhombifolia L. Cuba jute Nat C <2>
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Table 1 (continued). Species listed by family Common name Status Abundance NotesMALVACEAE (cont.) Sida spinosa L. prickly sida Nat R Waltheria indica L. ‘uhaloa Ind U MORACEAE Ficus microcarpa L. f. Chinese banyan Nat R <2> MYRTACEAE Melaleuca quinquenervia (Cav.) S.T. Blake paperbark Nat C Syzygium cumini (L.) Skeels Java plum Nat U <2> PHYTOLACCACEAE Rivina humilis L. coral berry Nat U PROTEACEAE Grevillea robusta A. Cunn. ex R. Br. silk oak Nat C <2> Macadamia integrifolia Maiden & Berche macadamia nut Nat AA RUBIACEAE Spermacoce assurgens Ruiz & Pav. buttonweed Nat C <1> MONOCOTYLEDONS COMMELINACEAE Commelina benghalensis L. hairy honohono Nat R <1> CYPERACEAE Cyperus gracilis R. Br. McCoy grass Nat U POACEAE Axonopus compressus (Swartz) P. Beauv.
brd.-lvd. carpet grass Nat C <1> Cenchrus purpureus (Schumach.) Morrone elephant grass Nat U Chloris barbata (L.) Sw. swollen fingergrass Nat R Digiteria sp. --- Nat R Eleusine indica (L.) Gaertn. wiregrass Nat A <2> Megathyrsus maximus Jacq. Guinea grass Nat AA <2> Setaria verticillata (L.) P. Beauv. bristly foxtail Nat R Legend to Table 1: Status = distributional status Ind = indigenous; native to Hawai‘i, but not unique to the Hawaiian Islands. Nat = naturalized, exotic, plant introduced to the Hawaiian Islands since the arrival of Cook Expedition in 1778 and well-established outside of cultivation. Orn = ornamental; crop or landscape plant not established outside of cultivation. Abundance = occurrence ratings for plants on property in July 2013. R – Rare - only one or two plants seen.
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Table 1 – Legend (continued). U - Uncommon - several to a dozen plants observed. O - Occasional - found regularly, but not abundant anywhere. C - Common - considered an important part of the vegetation and observed numerous times. A - Abundant - found in large numbers; may be locally dominant. AA - Abundant - very abundant and dominant; defining vegetation type. Notes: <1> Characteristic or found only in the road verge immediately adjacent to the site. <2> Species also reported from close by in David & Guinther (2013). <3> Plant lacking flowers or fruit at time of survey; identification uncertain.
Avian Survey A total of 175 individual birds of 13 species, representing nine separate families, was recorded during station counts (Table 2). 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. A closed canopy keeps areas beneath the trees in perpetual twilight. Four species, Northern Cardinal (Cardinalis cardinalis), Japanese White-eye (Zosterops japonicus), Yellow-fronted Canary (Ceithagra mozambica), and Red-billed Leiothrix (Leiothrix lutea), accounted for 52% of all birds recorded during station counts. The most frequently recorded species was Northern Cardinal, which accounted for 16% of the total number of individual birds recorded during station point counts. All of the species recorded during the course of this survey are established alien species. Table 2. Avian species detected during point-counts for the Pāhala Community WWTP Project
Common Name Scientific Name ST RA
PHASIANIDAE ‐ Pheasants & Partridges
Meleagridinae ‐Turkeys
Wild Turkey Meleagris gallopavo A 2.00
COLUMBIFORMES
COLUMBIDAE ‐ Pigeons & Doves
Spotted Dove Streptopelia chinensis A 3.17
Zebra Dove Geopelia striata A 2.00
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Table 2 (continued). Common Name Scientific Name ST RA
PASSERIFORMES
ZOSTEROPIDAE ‐White‐eyes
Japanese White‐eye Zosterops japonicus A 3.67
TIMALIIDAE ‐ Babblers
Chinese Hwamei Garrulax canorus A 2.00
Red‐billed Leiothrix Leiothrix lutea A 3.33
STURNIDAE ‐ Starlings
Common Myna Acridotheres tristis A 0.17
FRINGILLIDAE ‐ Fringilline and Carduline Finches & Allies
Carduelinae ‐ Carduline Finches and Hawaiian
Honeycreepers
House Finch Haemorhous mexicanus A 1.33
Yellow‐fronted Canary Ceithagra mozambica A 1.50
CARDINALIDAE ‐ Cardinals & Allies
Northern Cardinal Cardinalis cardinalis A 4.67
THRAUPIDAE ‐ Tanagers
Thraupinae ‐ Core Tanagers
Yellow‐billed Cardinal Paroaria capitata A 1.50
Saffron Finch Sicalis flaveola A 1.67
ESTRILDIDAE ‐ Estrildid Finches
Scaly‐breasted Munia Lonchura punctulata A 0.17
Key to Table 2
ST Status. A Alien – Introduced to the Hawaiian Islands by humans.
RA Relative Abundance – Number of birds detected divided by the number of count stations (6). Mammalian Survey Rather remarkably, we recorded no mammalian species within the survey area. Indeed, there was no indication that pigs (Sus scrofa) utilize the Project area. Discussion Botanical Resources Although some unmaintained or infrequently maintained areas exist on the subject parcel, the entire Project is proposed for land that is highly modified and the flora present subject to alterations, including mowing. Thus, there is no expectation for the site to support remnants of a native forest flora and minimal
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opportunity for native plants to become established, the ‘uhaloa and koali ‘awa being exceptions due to their ability to grow in highly disturbed environments. A previous biological survey (David and Guinther, 2013) conducted on 5 ac (2 ha) of land close by to the east yielded only 25 species of plants, the most abundant being white shrimp plant (Justicia betonica), glycine vine, and Guinea grass. Because that area had been highly disturbed, then not disturbed for a long time, species such as the shrimp plant and particularly Guinea grass had become well-established to the exclusion of other species. Sixteen species (24% of the combined species list) were common to both surveys. Obviously, the macadamia nut orchard is a valuable botanical resource, but a commercial one and not an environmentally sensitive one. The same can be said for the Cook pines (Araucaria columnaris) that line Maile Street along the southwestern side of the parcel. These old trees are an important community landscape element to be retained in place by the Project. Avian Resources The findings of the avian survey are consistent with the location of the site, and the monoculture of macadamia nut trees present on it. No native avian species were recorded during the course of this survey. Although not detected during this survey, endemic Hawaiian Petrel (Pterodroma sandwichensis) and Newell’s Shearwater (Puffinus newelli) have been recorded over-flying the general Project area between April and the end of November each year. The petrel is listed as endangered, and the shearwater as threatened under both federal and State of Hawai‘i endangered species statutes. The primary cause of mortality in both Hawaiian Petrel and Newell’s Shearwater is thought to be predation by alien mammalian species at the nesting colonies (USFWS, 1983; Simons and Hodges, 1998; Ainley et al., 2001). Collision with man-made structures is considered to be second-most significant cause of mortality of these seabirds in Hawai‘i. Nocturnally flying seabirds, especially fledglings on their way to sea in the summer and fall, can become disoriented by exterior lighting. When disoriented, seabirds can collide with man-made structures and, if not killed outright, dazed or injured birds become prey to feral mammals (Hadley, 1961; Telfer, 1979; Sincock, 1981; Reed et al., 1985; Telfer et al., 1987; Cooper and Day, 1998; Podolsky et al., 1998; Ainley et al., 2001; Hue et al., 2001; Day et al., 2003). Neither nesting colonies nor appropriate nesting habitat for either of these listed seabird species occur within or close to the current Project site.
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Mammalian Resources No Hawaiian hoary bats were detected during the course of this survey. It is possible that bats use resources within orchard part of the Project. Although, no rodents were recorded during the course of this survey, it is likely that one or more of the four alien Muridae established on Hawai’i IslandEuropean house mouse (Mus musculus domesticus), roof rat (Rattus rattus), brown rat (Rattus norvegicus), and black rat (Rattus exulans hawaiiensis)use various resources found within the general Project area on a seasonal basis, especially in the macadamia nut orchard. These human commensal species are drawn to areas of human habitation and activity and all are deleterious to native ecosystems and their dependent native fauna. Jurisdictional Waters The subject parcel slopes down to the southwest corner. A street culvert at that location carries runoff in the area under Māmalahoa Highway (Hawaii Belt Road). The National Wetlands Inventory (NWI) Wetlands Mapper (USFW, nd (a)) shows no features occurring on the parcel and no streams are shown on USGS topographic maps (USGS, 1923). Streams in the Pāhala area of the Island do not flow all the way to the sea, but terminate on Keone‘ele‘ele Flat to the southwest. Critical Habitat Federally delineated Critical Habitat is not present in Pāhala area (USFWS, 2012). Thus, the Project will not impinge on federally designated Critical Habitat. No equivalent designation exists under state law Potential Impacts to Protected Species No species of plants or animals currently proposed for listing or listed under either the federal or State of Hawai‘i endangered species statutes (DLNR 1998, 2015; USFWS, nd (b)) were recorded by this survey. Three faunal species not observed, may occur in the general vicinity and are discussed here. Seabirds The principal potential impact that the construction of the project poses to protected seabirds is the increased threat that birds will be downed after becoming disoriented by lights associated with the proposed action during the
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nesting season. The two activities that could pose a threat to these nocturnally flying seabirds are: a) if during construction, it is deemed expedient or necessary to conduct night-time construction activities during the seabird fledging season (which runs from September 15 through December 15); or b) exterior lighting is installed as part of the WWTP facilities. Impacts can be minimized if all external lighting is made dark sky compliant (HDLNR-DOFAW, 2016). Hawaiian hoary bat The potential impact that Project construction poses to the endangered Hawaiian hoary bat would be from clearing and grubbing of the macadamia nut orchard. Trimming or removal of trees within the construction areas may temporarily displace bats using this vegetation for roosting. Hawaiian bats use multiple roosts within their home territories, so the disturbance resulting from removal of trees is likely to be minimal. However, during pupping season, female bats carrying pups may be less able to rapidly vacate a roost site when the tree is felled. Additionally, adult female bats sometimes leave their pups in the roost tree while they themselves forage, and very small pups may be unable to flee a tree that is being felled. Adverse effects from such disturbance 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. References Ainley, D. G, R. Podolsky, L. Deforest, G. Spencer, and N. Nur. 2001. The Status and Population Trends of the Newell’s Shearwater on Kaua’i: Insights from Modeling, in: Scott, J. M, S. Conant, and C. Van Riper III (editors)
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Vanishing Avifauna. Studies in Avian Biology No. 22. Cooper’s Ornithological Society, Allen Press, Lawrence, Kansas. Pp. 108-123. American Ornithologist’s Union. 1998. Check‐list of North American Birds. 7th edition. AOU. Washington, D.C. 829 pp. _______. 2000. Forty-second supplement to the American Ornithologist’s Union
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Ornithologist's Union Check-list of North American Birds. The Auk, 119: 897-906. Banks, R. C., C. Cicero, J. L. Dunn, A. W. Kratter, P. C. Rasmussen, J. V. Remsen, Jr., J. D. Rising, and D. F. Stotz. 2003. Forty-fourth supplement to the American Ornithologist's Union Check-list of North American Birds. The
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Chesser, R. T., R. C. Banks, F. K. Barker, C. Cicero, J. L. Dunn, A. W. Kratter, I. J. Lovette, P. C. Rasmussen, J. V. Remsen, Jr., J. D. Rising, D. F. Stotz, and K. Winker. 2012. Fifty-third supplement to the American Ornithologist Union, Check-list of North American Birds. The Auk, 129: 573-588. ______, _______, _______, _______, _______, _______, _______, _______, _______, _______, _______, and _______.. 2013. Fifty-fourth supplement to the American Ornithologist Union, Check-list of North American Birds. The Auk, 130: 558-71. ______, _______, _______, _______, _______, _______, _______, _______, _______, _______, _______, and _______. 2014. Fifty-fifth supplement to the American Ornithologist Union Check-list of North American Birds. The Auk, Ornithological
Advances, 131: CSi-CSxv. ______, _______, _______, _______, _______, _______, _______, A. G. Navarro-Sigüenza, P. C. Rasmussen, J. V. Remsen, Jr., J. D. Rising, D. F. Stotz, and K. Winker. 2015. Fifty-sixth supplement to the American Ornithologist Union Check-list of North American Birds. The Auk, Ornithological Advances, 132: 748-764. ______, _______, _______, _______, _______, _______, _______, _______, _______, _______, _______, _______, and ______. 2016. Fifty-seventh supplement to the American Ornithologist Union Check-list of North American Birds. The Auk,
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Day, R. H., B. A. Cooper, and T. C. Telfer. 2003. Decline of Townsend’s (Newell’s Shearwaters (Puffinus auricularis newelli) on Kauai, Hawaii. The Auk, 120: 669-679. David, R. E. 2018. Unpublished field notes – Hawai‘i 1980 – 2018. _______, and E. B. Guinther. 2013. Biological surveys conducted for the Pāhala Wastewater Treatment Plant Project, Ka‘ū District, Island of Hawai‘i. Prep for Fukunaga and Assoc. Inc. Rana Biological Consulting, Inc., 17 pp. Hawai‘i Department of Land and Natural Resources (HDLNR). 1998. Chapter 107. Threatened and Endangered Plants. Department of Land and Natural Resources. State of Hawaiʻi. Administrative Rule under Title 13. Subtitle 5, Part 1, dated March 23, 1998. _______. 2015. Chapter 124. Indigenous Wildlife, Endangered, Injurious Wildlife, Introduced Wild Birds, and Introduced Wildlife. Department of Land and Natural Resources. State of Hawaii. Administrative Rule under Title 13. Subtitle 5, Part 2, dated February 17, 2015. Exhibits dated November 1, 2014. Hawai‘i Department of Land and Natural Resources, Division of Forestry and Wildlife (HDLNR-DOFAW). 2016. Wildlife Lighting. PDF available at URL: http://dlnr.hawaii.gov/wildlife/files/2016/03/DOC439.pdf; last accessed on January 17, 2018. Hadley, T. H. 1961. Shearwater calamity on Kauai. Elepaio, 21: 60. Hue, D., C. Glidden, J. Lippert, L. Schnell, J. MacIvor and J. Meisler. 2001. Habitat Use and Limiting Factors in a Population of Hawaiian Dark-rumped Petrels on Mauna Loa, Hawai‘i. Pp. 234-242, in: : Scott, J. M, S. Conant, and C. Van Riper III (editors) Evolution, Ecology, Conservation, and
Management of Hawaiian Birds: A Vanishing Avifauna. Studies in Avian Biology No. 22. Cooper’s Ornithological Society, Allen Press, Lawrence, Kansas. Imada, C. T. 2012. Hawaiian Native and Naturalized Vascular Plants Checklist (December 2012 update). Bishop Museum Tech. Rept. 60. 380 pp. Palmer, D. D. 2003. Hawai`i’s Ferns and Fern Allies. University of Hawaii Press, Honolulu. 324 pp.
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Podolsky, R., D. G. Ainley, G. Spencer, L. de Forest, and N. Nur. 1998. Mortality of Newell’s Shearwaters Caused by Collisions with Urban Structures on Kaua‘i. Colonial Waterbirds, 21: 20-34. Reed, J. R., J. L Sincock, and J. P. Hailman 1985. Light Attraction in Endangered Procellariform Birds: Reduction by Shielding Upward Radiation. The Auk, 102: 377-383. Simons, T. R., and C. N. Hodges. 1998. Dark-rumped Petrel (Pterodroma
phaeopygia). In: A. Poole and F. Gill (editors). The Birds of North America, No. 345. The Academy of Natural Sciences, Philadelphia, PA. and the American Ornithologists Union, Washington, D.C. Sincock, J. L. 1981. Saving the Newellʻs Shearwater. Pp. 76-78 in: Proc. of the Hawaii Forestry and Wildllife Conference, 2-4 October 1980. Department of Land and Natural Resources, State of Hawaii, Honolulu. Staples, G. W. and D. R. Herbst. 2005. A Tropical Garden Flora. Plants Cultivated
in the Hawaiian Islands and other Tropical Places. Bishop Museum, Honolulu. 908 pp. Telfer, T. C. 1979. Successful Newell’s Shearwater Salvage on Kauai. ‘Elepaio, 39:71 _______, J. L. Sincock, G. V. Byrd, and J. R. Reed. 1987. Attraction of Hawaiian seabirds to lights: conservation efforts and effects of moon phase.
Wildlife Soc. Bull., 15: 406-413. U.S. Fish & Wildlife Service (USFWS). 1983. Hawaiian Dark-Rumped Petrel & Newell’s Manx Shearwater Recovery Plan. USFWS, Portland, Oregon. February 1983. _______. no date (a). National Wetlands Inventory website. U.S. Department of the Interior, Fish and Wildlife Service, Washington, D.C. Available online at URL: http://www.fws.gov/wetlands/ Data/Mapper.html; last accessed on July 1, 2018. ______. no date (b). USFWS Endangered Species. Available online at URL:
https://www.fws.gov/endangered/; Last visited on June 3, 2018 and Environmental Conservation Online System (ECOS), online at URL:
https://ecos.fws.gov/ecp/species‐reports; last visited on June 21, 2018.
Biological Surveys PĀHALA WWTP (TMK: 9-6-002: 018)
AECOS Inc. [File: 1545.docx] Page | 17
U.S. Geological Survey (USGS). 1923. 15-minute Series, Topographic Map, Pāhala Quadrangle. Wagner, W. L., D. R. Herbst and S. H. Sohmer. 1990. Manual of the Flowering
Plants of Hawai‘i: Volume I and II. Bishop Museum Special Publication 83. University of Hawai‘i Press. 1853 pp. ________ and ________. 1999. Supplement to the Manual of the flowering plants of
Hawai‘i, pp. 1855-1918. In: Wagner, W. L., D. R. Herbst, and S. H. Sohmer, Manual of the flowering plants of Hawai‘i. Revised edition. 2 vols. University of Hawaii Press and B.P. Bishop Museum.
Summary of Biological Survey Report, August 20, 2018
WILSON OKAMOTO CO RP O RATIO N
INNOVATORS· PLANNERS· ENGINEERS
10349-01 August 20, 2018
Ms. Jodi Charrier, Acting Team Leader
Maui Nui and Hawaii Island Fish and Wildlife Service U.S. Department of the Interior 300 Ala Moana Boulevard Room 3-122, Box 50088
Honolulu, HI 96850
Attention:
Subject:
Eldridge Naboa, Fish and Wildlife Biologist
Draft Environmental Assessment, Pre-Assessment Consultation; Pahala Community Large Capacity Cesspool Replacement Pa'au'au, Ka'ii Ka'u, Hawai'i Response to Comment (0lEPIF00-2018-TA-0275)
Dear Ms. Charrier:
Thank you for your April 23, 2018 comment letter (0lEPIF00-2018-TA-0275) and the April 10, 2018 e-mail message from Eldridge Naboa regarding the County of Hawai'i Department of Environmental Management Pahala Community Large Capacity Cesspool Replacement project.
As stated in the Project Summary, the Pahala Community Large Capacity Cesspool Replacement
project would be funded by an Environmental Protection Agency (EPA) Special Appropriation Grant and by the State of Hawai'i Clean Water State Revolving Fund (CSRF) loan program. As such, we understand consultation will need to be conducted by a federal agency or by a designated non-federal representative.
On June 7, 2018, EPA Region 9 Water Division, designated Eastern Research Group, Inc. (ERG) as the non-federal representative for undertaking the consultation for this project.
As part of the Draft EA, in August 2018, botanical and biological field studies were undertaken
along the streets and adjacent areas of wastewater collection system and at the 14.9-acre
wastewater treatment and disposal facility project site. The results of the field surveys showed the collection system will be installed along already paved roadways within Pahala. They also revealed that vegetation is located entirely within yards and consist of ornamental plants.
1907 S. Beretania Street, Suite 400 • Honolulu, Hawaii • 96826 • (808) 946-2277
10349-01 Letter to Ms. Jodi Charrier, Acting Team Leader Page2 August 20, 2018
The field survey showed 52 species of vascular plants: 2 ferns, one gymnosperm, and 49 species of angiosperms (flowering plants). Only two species ( 4%) 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 avian survey 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 species recorded during the course of the survey are established alien species. No native avian species were recorded during the course of this survey.
The field survey report indicated that, although not detected during the survey, the endemic Hawaiian Petrel (Pterodroma sandwichensis) and Newell's Shearwater (Pujfinus newelli) have been recorded over-flying the general area between April and the end of November each year. The petrel is listed as endangered, and the shearwater as threatened under both federal and State of Hawai'i endangered species statutes.
No species of plants or animals currently proposed for listing or listed under either the federal or State ofHawai'i endangered species statutes were recorded by the survey.
The Draft EA, will include a discussion of the avoidance and minimization measures as set forth in your April 23, 2108 letter.
We appreciate your participation in the Draft EA process.
Vice President, Director Planning
cc: D. Beck, DEM K.Rao, EPAB.Rosen, ERGC.Lekven, PE, BC
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Pacific Islands Fish and Wildlife Office
In Reply Refer To:
0lEPIF00-2018-TA-0275 0lEPIF00-2019-1-0153
Mr. Patrick Goodwin Environmental Scientist
14555 Avion Parkway, Suite 200 Chantilly, Virginia 20151-1102
300 Ala Moana Boulevard Honolulu, Hawaii 96850
February 15, 2019
Subject: Informal Consultation for the Pahala Large Capacity Cesspool Replacement Project; Pahala, Kau District, Island and County of Hawaii
Dear Mr. Patrick Goodwin:
The U.S. Fish and Wildlife Service (Service) received your correspondence on December 28, 2018, requesting our concurrence with your determination that the proposed Pahala Large
Capacity Cesspool Replacement Project, may affect but is not likely to adversely affect the federally endangered Hawaiian hoary bat (Lasiurus cinereus semotus), Hawaiian Hawk (Buteo solitarius), Hawaiian goose (Branta (=Nesochen) sandvicensis), Hawaiian Petrel (Pterodroma sandwichensis), Band-rumped Storm-Petrel (Oceanodroma castro), Hawaiian Stilt (Himantopus mexicanus knudseni), and Hawaiian Coot (Fulica alai), and the threatened
Newell's Shearwater (Puffinus newelli). This response is in accordance with Section 7 of the Endangered Species Act (ESA) of 1973, as amended (16 U.S.C 1531 et seq.).
Project Description
The proposed project is located in Pahala, Kau District, Hawaii. Funding for this project is
provided by a Special Appropriation Grant from Environmental Protection Agency (EPA) and a loan from the State of Hawaii Clean Water State Revolving Fund. The project involves replacing two large-capacity cesspools (LCCs) with a new County-owned wastewater collection system to be constructed primarily within the existing public right-of-way; a treatment and disposal system that will occupy a 14.9-acre site that is currently a privately
owned macadamia nut plantation; and closure of the two LCCs.
The proposed project is located in the community of Pahala, a former sugar farming and processing operation, in the Kau District, Island of Hawaii. In 1999, pursuant to the Safe Drinking Water Act, EPA promulgated regulations (40 CFR 144.14) requiring the elimination
or closure of all LCCs by April 2005. In 2010, the C. Brewer Company transferred the ownership and operation of the LCCs to the County, which is bringing these wastewater systems into compliance with the Safe Drinking Water Act.
Mr. Patrick Goodwin 2
Once the new system is in place, the County will close and abandon the existing LCCs. This system includes some lines located in the backyards of residential lots and some within public streets; therefore, abandoning the lines in place will minimize impacts related to their excavation and removal. The cut ends of the abandoned laterals to the collection system will
be plugged with concrete to prevent unauthorized use of the old system and to avoid the need
to maintain an unused underground hydraulic conduit. The two LCCs will also be abandoned and closed; the specific closure methods have not yet been determined but will be consistent with the requirements set forth in Hawaii Administrative Rules §11-23-19.
Avoidance and Minimization Measures
Hawaiian hoary bat 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 (ft)
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 three feet to higher than 500 ft above the ground and can become entangled in barbed wire used for fencing.
To avoid and minimize impacts to the Hawaiian hoary bat, the project:
•Will not disturb, remove, or trim woody plants greater than 15 ft tall during the batbirthing and pup rearing season (June 1 through September 15).•Will not use barbed wire for fencing.
Hawaiian hawk The Hawaiian hawk is known to occur across a broad range of forest habitats throughout the Island of Hawaii. Loud, irregular and unpredictable activities, such as using heavy equipment or
building a structure, near an endangered Hawaiian hawk nest may cause nest failure. Harassment of Hawaiian hawk nesting sites can alter feeding and breeding patterns or result in nest or chick abandonment. Nest disturbance can also increase exposure of chicks and juveniles to inclement weather or predators.
To avoid and minimize impacts to Hawaiian hawks, the project:
•If work must be conducted during the March 1 through September 30 Hawaiian hawkbreeding season, a biologist familiar with the species will conduct a nest search of the
project footprint and surrounding areas immediately prior to the start of construction
activities.
o Pre-disturbance surveys for Hawaiian hawks are only valid for 14 days. Ifdisturbance for the specific location does not occur within 14 days of the survey,another survey will be conducted.•Will not clear vegetation or conduct construction activities within 1,600 ft of any active
Hawaiian hawk nest during the breeding season until the young have fledged.•Regardless of the time of year, no trimming or cutting trees containing a hawk nest willoccur, as nests may be re-used during consecutive breeding seasons.
Mr. Patrick Goodwin 3
Hawaiian goose Hawaiian goose are found on the islands of Hawaii, Maui, Molokai, and Kauai predominately, with a small population on Oahu. They are observed in a variety of habitats, but prefer open areas, such as pastures, golf courses, wetlands, natural grasslands and shrub lands, and lava flows.
Threats to the species include introduced mammalian and avian predators, wind facilities, and
vehicle strikes.
To avoid and minimize impacts to the Hawaiian goose, the project:
•Will not approach, feed, or disturb Hawaiian goose.•If Hawaiian goose are observed loafing or foraging within the project area during thebreeding season (September through April), a biologist familiar with the nesting behaviorwill survey for nests in and around the project area prior to the resumption of any work.
Surveys will be repeated after any subsequent delay of work of three or more days
( during which the birds may attempt to nest).o All work will cease immediately and the Service will be contacted for furtherguidance if a nest is discovered within a radius of 150 ft of proposed work, ora previously undiscovered nest is found within said radius after work begins.•In areas where Hawaiian goose are known to be present, the project will post andimplement reduced speed limits, and inform project personnel and contractors about thepresence of endangered species on-site.
Hawaiian petrel, Band-rumped storm-petrel, and Newell's shearwater
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 avoid and minimize potential project impacts to seabirds, the project:
•Will fully shield all outdoor lights so the bulb can only be seen from below bulb heightand only use when necessary.•Will install automatic motion sensor switches and controls on all outdoor lights or tumoff lights when human activity is not occurring in the lighted area.•Will avoid nighttime construction during the seabird fledging period, September 15through December 15.
Hawaiian stilt and Hawaiian coot Listed Hawaiian waterbirds are found in fresh and brackish-water marshes and natural or manmade 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.
Mr. Patrick Goodwin 4
Based on the project details provided, our information suggests that your project may result in standing water or the creation of open water, thus attracting Hawaiian waterbirds to the site. 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 impacts to waterbirds, the project:
•To discourage waterbird use of the facility, the subsurface-flow-constructed wetland willnot have areas of open water; asphalt rather than gravel will be used to provide accessaround the lagoons; the lagoons will be lined with a high density polyethylyne liner,
rather than with substrate that would support vegetation growth; shade balls will be usedin the largest lagoon to discourage algal growth; and the lagoons will be bordered bygroves rather than bare land.•The security fence around the perimeter of the treatment and disposal facility will
exclude larger non-native mammalian predators.•In areas where waterbirds are known to be present, the project will post and implementreduced speed limits, and inform project personnel and contractors about the presence ofendangered species on-site.•If water resources are located within or adjacent to the project site, the project willincorporate applicable best management practices regarding work in aquaticenvironments into the project design.•A biological monitor that is familiar with the species' biology will conduct waterbird nest
surveys where appropriate habitat occurs within the vicinity of the proposed project site
prior to project initiation. Surveys will be repeated again within 3 days of projectinitiation and after any subsequent delay of work of 3 or more days ( during which thebirds may attempt to nest). If a nest or active brood is found:o The Service will be contacted within 48 hours for further guidance.
o Will establish and maintain a 100-ft buffer around all active nests and/or
broods until the chicks/ducklings have fledged. Will not conduct potentiallydisruptive activities or habitat alteration within this buffer.•A biological monitor that is familiar with the species' biology will be present on the
project site during all construction or earth moving activities until the chicks/ducklings
fledge to ensure that waterbirds and nests are not adversely impacted.
Minimize Spread of Rapid Ohia Death Rapid Ohia Death (ROD), a newly identified disease, has killed large numbers of mature ohia trees (Metrosideros polymorpha) in forests and residential areas of Hawaii Island. The disease is
caused by a vascular wilt fungus (Ceratocystis fimbriata). Crowns of an affected tree tum
yellowish or brown within days to weeks and dead leaves typically remain on branches for some time. All ages of ohia trees can be affected and can have symptoms of browning of branches or leaves. As of early 2017 the disease has been confirmed in all districts except North and South Kohala. Additional information on ROD can be found at:
Mr. Patrick Goodwin
http://www2.ctahr.hawaii.edu/forestry/downloads/ROD-trifold-03.2016.pdf and http:/ /www2.ctahr.hawaii.edu/forestry /disease/ohia _ wilt.html.
5
The following avoidance and minimization measures should be followed for projects working in
ohia forests or at sites with ohia trees on Hawaii Island:
1)A survey of the proposed project site should be conducted within two weeks prior to anytree cutting to determine if there are any infected ohia trees. If infected ohia are suspectedat the site, the following agencies should be contacted for further guidance.
a.Service -please contact the name at the bottom of this letter.
b. Dr. J.B. Friday, University of Hawaii Cooperative Extension Service,808-969-8254 or jbfriday@hawaii.educ.Dr. Flint Hughes, USDA Forest Service, 808-854-2617, flrnghes@fs.fed.usd.Dr. Lisa Keith, USDA Agriculture Research Service,808-959-4357, Lisa.Keith@ars.usda.gov
2)Both prior to cutting ohia and after the project is complete:a.Tools used for cutting infected ohia trees should be cleaned with a 70 percentrubbing alcohol solution. A freshly prepared 10 percent solution of chlorine
bleach and water can be used as long as tools are oiled afterwards, as chlorine
bleach will corrode metal tools. Chainsaw blades should be brushed clean,sprayed with cleaning solution, and run briefly to lubricate the chain.b.Vehicles used off-road in infected forest areas should be thoroughly cleaned. Thetires and undercarriage of the vehicle should be cleaned with detergent if they
have travelled from an area with ROD or travelled off-road. Use a pressure
washer with soap to clean all soil off of the tires and vehicle undercarriage.c.Shoes and clothing used in infected forests should also be cleaned. Shoes shouldbe decontaminated by dipping the soles in 70 percent rubbing alcohol to kill theROD fungus. Other gear can be sprayed with the same cleaning solutions.
Clothing can be washed in hot water and detergent.
d.Wood of affected ohia trees should not be transported to other areas of HawaiiIsland or interisland. All cut wood should be left on-site to avoid spreading thedisease. The pathogen may remain viable for over a year in dead wood. TheHawaii Department of Agriculture has passed a quarantine rule that prohibits
interisland movement, except by permit, of all ohia plant or plant parts.
Mr. Patrick Goodwin 6
The Service has analyzed potential impacts to listed species due to the implementation of your project. Based on the includsion 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 Pahala Large Capacity Cesspool 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.
Thank you for participating with us in the protection of our endangered species. If you have any further questions or concerns regarding this consultation, please contact Eldridge Naboa, Fish
and Wildlife Biologist, 808-284-0037, e-mail: eldridge naboa@fws.gov. When referring to this
project, please include this reference number: 0JEPIF00-2019-1-0153.
Sincerely,
Digitally signed JODI by JODI
CHARRIER CHARRIER Date:2019.02.15
15:06:51 -1 0'00' Jodi Charrier
Acting Island Team Leader
Maui Nui and Hawaii Island
Mr. Patrick Goodwin 7
BIOSECURTY PROTOCOLS -HAW All ISLAND (JULY 2018)
The following biosecurity protocol (based on National Park Service, State of Hawaii, U.S. Fish and Wildlife, U.S. Geological Survey, and the DOI Office of Native Hawaiian Relations
guidance) should be followed when operating on Hawaii Island to prevent the introduction of
harmful invasive species including frogs, ants, weeds, and fungi into local natural areas ( e.g., Hawaii Volcanoes National Park, Hakalau Forest National Wildlife Refuge, State of Hawaii "Natural Areas") and areas with native habitat (habitat that is primarily composed of native vegetation), other islands in Hawaiian archipelago, or the U.S. mainland. The protocol also
includes suggestions for keeping field staff safe from certain invasive species.
1.All work vehicles, machinery, and equipment should be cleaned, inspected by its user,
and found free of mud, dirt, debris and invasive species prior to entry into the natural
areas or native habitat.a.Vehicles, machinery, and equipment must be thoroughly pressure washed in a designatedcleaning area and visibly free of mud, dirt, plant debris, insects, frogs (including frog eggs) and
other vertebrate species such as rats, mice and non-vegetative debris. A hot water wash ispreferred. Areas of particular concern include bumpers, grills, hood compartments, areas underthe battery, wheel wells, undercarriage, cabs, and truck beds (truck beds with accumulatedmaterial (intentionally placed or fallen from trees) are prime sites for hitchhikers).
b.The interior and exterior of vehicles, machinery, and equipment must be free of rubbish andfood. The interiors of vehicles and the cabs of machinery must be vacuumed clean. Floor matsshall be sanitized with a solution of >70% isopropyl alcohol or a freshly mixed 10% bleachsolution.
c.Any machinery, vehicles, equipment, or other supplies found to be infested with ants (or otherinvasive species) must not enter natural areas or native habitat. Treatment is the responsibility ofthe equipment or vehicle owner and operator.
2.Little Fire Ants -All work vehicles, machinery, and equipment should be inspected forinvasive ants prior to entering the natural areas or native habitat.a.A visual inspection for little fire ants should be conducted prior to entry into natural areas ornative habitat.
b.Hygiene is paramount but even the cleanest vehicle can pick up a little fire ant. Place
MaxForce Complete Brand Granular Insect Bait (1.0% Hydramethylnon;http://littlefireants.com/Maxforce%20Complete.pdf) into refillable tamper resistant bait stations.An example of a commercially available refillable tamper resistant bait station is the Ant CafePro (https://www.antcafe.com/). Place a bait station (or stations) in vehicle. Note larger vehicles,such as trucks, may require multiple stations. Monitor bait stations frequently ( every week at a
minimum) and replace bait as needed. If the station does not have a sticker to identify thecontents, apply a sticker listing contents to the station.
c.Any machinery, vehicles, equipment, or other supplies found to be infested with ants (or otherinvasive species) must not enter natural areas or native habitat until it is sanitized and re-tested
following a resting period. Infested vehicles must be sanitized following recommendations bythe Hawaii Ant Lab (http://www.littlefireants.com/) or other ant control expert and in accordance
Mr. Patrick Goodwin 8
with all State and Federal laws. Treatment is the responsibility of the equipment or vehicle owner.
d.Gravel, building materials, or other equipment such as portable buildings should be baitedusing MaxForce Complete Brand Granular Insect Bait (1.0% Hydramethylnon;
http://littlefireants.com/Maxforce%20Complete.pdf) or AmdroPro (0. 73% Hydramethylnon;http:/ /littlefireants.com/ Amdro%20Pro.pdt) following label guidance.
e.Storage areas that hold field tools, especially tents, tarps, and clothing should be baited using
MaxForce Complete Brand Granular Insect Bait (1.0% Hydramethylnon;
http://littlefireants.com/Maxforce%20Complete.pdf) or AmdroPro (0.73% Hydramethylnon;
http://littlefireants.com/ Amdro%20Pro.pdt) following label guidance.
3.Base yards and staging areas inside and outside areas must be kept free of invasivespecies.a.Base yards and staging areas should be inspected at least weekly for invasive species and any
found invasive removed immediately. Pay particular attention to where vehicles are parkedovernight, keeping areas within 10-meters of vehicles free of debris. Parking on pavement andnot under trees, while not always practical is best.
b.Project vehicles or equipment stored outside of a base yard or staging area, such as a private
residence, should be kept in a pest free area.
4. All cutting tools must be sanitized to prevent the Rapid Ohia Death (ROD) fungus.a.A void wounding ohia trees and roots with mowers, chainsaws, weed eaters, and other tools.Cut only the minimum amount of trees and branches as approved for the project.
b.All cutting tools, including machetes, chainsaws, and loppers must be sanitized to removevisible dirt and other contaminants prior to entry into natural areas or areas with native habitat,and when moving to a new project area within the native habitat area. Tools may be sanitizedusing a solution of>70% isopropyl alcohol or a freshly mixed 10% bleach solution. One minute
after sanitizing, you may apply an oil based lubricant to chainsaw chains or other metallic partsto prevent corrosion.
c.Only dedicated tools and chainsaws should be used to sample known or suspected RODinfected trees.
d. Vehicles, machinery, and equipment must be cleaned as described in (1) above.
5.Imported firewood, logs, and ohia parts:a.Ohia firewood, ohia logs, and ohia parts should not be transported.
6.For individuals working in the field:a.Before going into the field, visually inspect and clean your clothes, boots, pack, radioharness, tools and other personal gear and equipment, for seeds, soil, plant parts, insects, andother debris. A small brush is handy for cleaning boots, equipment and gear. Soles of shoes
should be sanitized using a solution of >70% isopropyl alcohol or a freshly mixed 10% bleachsolution.
Mr. Patrick Goodwin 9
b.Immediately before leaving the field, visually inspect and clean your clothes, boots, pack,radio harness, tools, and other personnel gear and equipment, for seeds, soil, plant parts, insects,and other debris. Soles of shoes should be sanitized using a solution of >70% isopropyl alcoholor a freshly mixed 10% bleach solution.
c.Little fire ants nest in trees. If you are under a tree and that tree is bumped or somehowstressed, the threat response of the ants is to fall from the leaves and sting the person under thetree. If you are subject to an ant attack, do not panic. The ants are extremely small but their stingsare painful so make sure you remove all ants from your body and clothing. The stings cause inch
long welts that are itchy and painful, and can last for weeks. Treat stings as you would other
insect stings. In some persons stings can produce life threatening reactions. Stockingantihistamine in the first aid kit is a reasonable precaution.
d.Rat Lungworm disease is caused by a parasite that can infect humans who consume raw or
undercooked infected snails or slugs or consume raw produce that contains a small infected snail
or slug. Infection is rare but can be serious. Symptoms can include severe headache, neckstiffness, low grade fever, nausea, and vomiting anywhere from 1-6 weeks after exposure. Thedisease is not spread person to person. Anyone who handles snails or slugs should wear glovesand/or wash hands. Eating unwashed produce is discouraged.
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
February 2020
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Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
February 2020
Appendix D
Draft Archeological Inventory Survey (AIS) Report
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
February 2020
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Harry Kim
Mayor
Wilfred M. Okabe
Managing Director
William A. Kucharski
Director
Diane A. Noda
Deputy Director
<tlnunflJ nf ~afuai'i
DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
345 KekOanao'a Street, Suite 41 · Hilo, Hawai'i 96720
Ph: (808) 961-8083 · Fax: {808) 961-8086
Email: cohdem@hawaiicounty.gov
March 11, 2019
Dr. Alan S. Downer, SHPD Administrator
Department of Land and Natural Resources
State Historic Preservation Division
601 Kam6kila Boulevard, Suite 555
Kapolei, Hawai'i 96707
Re: Draft Archaeological Inventory Survey for the Pahala Wastewater Treatment
Plant and Sewer System Project, Hionamoa, Palima, and Pa'au'au 1 and 2
Ahupua'a, Ka'u District, Hawai'i Island
TMKs: (3) 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and
County of Hawai'i Right-of-Ways (Bautista et al. 2019)
Submitted for HRS 6E-8 Review
Dear Dr. Downer:
The County of Hawai'i Department of Environmental Management is submitting the attached
Draft Archaeological Inventory Survey (AIS) for the Pahala Wastewater Treatment Plant and
Sewer System Project, Hionamoa, Palima, and Pa'au'au 1 and 2 Ahupua'a, Ka'Q District, Hawai'i
Island, TM Ks: (3) 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County of
Hawai'i Right-of-Ways {Bautista et al. 2019) for SHPD review, along with a 6E submittal filing fee
form and check. These materials are additional submittals associated with existing Log No.
2018.000722.
The County of Hawai'i contracted Brown and Caldwell and its sub-consultants, Wilson Okamoto
Corporation and Cultural Surveys of Hawai'i Inc., to prepare the attached AIS and has
authorized them to coordinate directly with SHPD for processing and review and to address
associated SHPD comments for this submittal.
The project's point of contact at the County of Hawai'i Department of Environmental
Management is:
County of Hawai'i is an Equal Opportunity Provider and Employer
Dr. Alan S. Downer, SHPD Administrator
March 11, 2019
Page 2
William A. Kucharski, Director
345 Kekuanaoa Street, Suite 41
Hilo, Hawai'i 96720
Phone: (808) 961-8083
Email: william.kucharski@hawaiicounty.gov
The project's point of contact at the County of Hawai'i Department of Environmental
Management's Wastewater Division is:
Dora Beck, Wastewater Division Chief
108 Railroad Avenue
Hilo, Hawai'i 96720
Phone: (808) 961-8513
Email: dora.beck@hawaiicounty.gov
If you have any questions or comments, please contact Craig Lekven with Brown and Caldwell
at (808) 442-3301. You may also reach him by email at CLekven@brwncald.com.
Sincerely,
!/4t(:~L,
William A. Kucharski
Director
WK:mef
Encs: Submittal Form
Draft AIS
Check for Filing Fee
cc: Diane Noda, DEM Deputy Director
Dora Beck, DEM-WWD Chief
Craig Lekven, P.E., Brown and Caldwell
John Sakaguchi, Wilson Okamoto Corporation
10349-01
March 11, 2019
WILSON OKAMOTO CO RP O RA TIO N
INNOVATORS· PLANNERS· ENGINEERS
Dr. Alan S. Downer, SHPD Administrator
DLNR-State Historic Preservation Division
Kakuhihewa Building, Suite 555 601 Kamokila Boulevard Kapolei, Hawai'i 96707
Attention:
Subject:
Dear Dr. Downer:
Dr. Susan Lebo, Archaeology Branch Chief
Draft Archaeological Inventory Survey for the Paha/a WastewaterTreatment Plant and Sewer System Project, Hionamoa, Palima, and Pa 'au 'au I and 2 Ahupua 'a, Ka 'ft District, Hawai 'i Island, TMKs: {3 J 9-6-002:016 por. and OJ 8 por., 9-6-005:036 por. and 044, and County ofHawai 'i Right-of-Ways (Bautista et al. 2019) submitted for HRS 6E-8 review
We are submitting the following:
1)One ( 1) cardstock copy of the Draft Archaeological Inventory Survey for the Paha/aWastewater Treatment Plant and Sewer System Project, prepared by Cultural SurveysHawaii, March 2019;
2)Filing fee check of $450.00 payable to: Hawaii Historic Preservation Special Fund; and3)Two (2) copies of the 6E filing fee form.
An electronic document link and related information has been sent to
DLNR.Intake.SHPD@hawaii.gov. If you have any questions, please call me at 808-946-2277.
Sincere! ,
� Vice President, Director of Planning
cc: W.Kucharski, COH DEMD.Beck, COH WWDS.Mendonca, COH WWDK.Roa, EPA
C.Levken; BC; W. Folk; CSH
Enclosures
1907 5. Beretania Street, Suite 400 • Honolulu, Hawaii• 96826 • (808) 946-2277
DAVID Y. IGE GOVERNOR OF HAWAII
STATE OF HAWAII DEPARTMENT OF LAND AND NATURAL RESOURCES
STATE HISTORIC PRESERVATION DIVISION KAKUHIHEWA BUILDING 601 KAMOKILA BLVD, STE 555 KAPOLEI, HAWAII 96707
SUZANNE D. CASE CHAIRPERSON BOARD OF LAND AND NATURAL RESOURCES COMMISSION ON WATER RESOURCE MANAGEMENT
ROBERT K. MASUDA FIRST DEPUTY
JEFFREY T. PEARSON, P.E. 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
HRS 6E Submittal Filing Fees All submittals must have the appropriate filing fee in accordance with HAR §13-275-4 or HAR §13-284-4. All contact fields below must be complete and accurate.
Landowner:
(if privately-owned historic property on Hawaii Register, HRS §6E-10)
Agency:
Contact Name:
Mailing Address:
Phone: Email:
Title of Report/Plan:
Ahupua‘a: District: Island:
TMK(s):
Contract Firm:
(firm who completed the work on behalf of the agency) Contact Name: Phone: Email:
Check if Report/Plan is a re-submittal (no fee) Check if Field Inspection Report requested by SHPD (no fee) _____ Check if Final Report (no fee)
$0 Archaeological Monitoring Report, no resources reported
$25 Archaeological Monitoring Plan $25 Burial Disinterment Report $25 Request from Agency for Determination Letter per HAR §13-275 $50 Archaeological Assessment (AIS with negative findings) $50 Osteological Analysis Report $100 Archaeological Monitoring Report, resources reported
$150 Archaeological Inventory Survey Plan, Archaeological Data Recovery Plan, or Preservation Plan $250 Burial Treatment Plan (BTP)
$450 Archaeological, Architectural, or Ethnographic Survey Report $450 Archaeological Data Recovery Report Fee Total: Make check payable to “Hawaii Historic Preservation Special Fund”
For Office Use Only:
rev. 11/9/2017
Date Received: Payment Method: Cash Amount $
Log No.: Check No. Amount $
Receipt Issued: Money Order Amount $
Cultural Surveys Hawai‘i
(808) 262-9972 @culturalsurveys.com
Draft Revision Final
n/a
Department of Environmental Management, County of Hawai'i
William A. Kucharski, Director
345 Kekuanaoa Street Suite 41, Hilo Hawaii 96720
(808) 961-8083 william.kucharski@hawaiicounty.gov
Draft Archaeological Inventory Survey for the Pāhala Wastewater Treatment Plant and
Sewer System Project, Hionamoa, Pālima, and Pāދauދau 1 and 2 Ahupua‘a, Ka‘nj District,
Hionamoa, Pālima, and ...Ka‘nj Hawai‘i
[3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County of Hawaiދi Right-o
William Folk
wfolk
4
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
Draft
Archaeological Inventory Survey for the
Pāhala Wastewater Treatment Plant and
Sewer System Project,
Hionamoa, Pālima, and Pāʻauʻau 1 and 2 Ahupua‘a,
Ka‘ū District, Hawai‘i Island
TMKs: [3] 9-6-002:016 por. and 018 por.,
9-6-005:036 por. and 044, and
County of Hawaiʻi Right-of-Ways
Prepared for
Wilson Okomoto Corporation
and the
County of Hawaiʻi Department of Environmental Management, Wastewater Division
Prepared by
Olivier M. Bautista, B.A., Sarah Wilkinson, B.A., and Hallett H. Hammatt, Ph.D. Cultural Surveys Hawai‘i, Inc. Kailua, Hawai‘i
(Job Code: HIONAMOA 2)
March 2019
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Management Summary
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawai‘i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
i
Management Summary
Reference Archaeological Inventory Survey for the Pāhala Wastewater Treatment
Plant and Sewer System Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2 Ahupua‘a, Ka‘ū District, Hawai‘i Island, TMKs: [3] 9-6-002:016 por.
and 018 por., 9-6-005:036 por. and 044, and County of Hawaiʻi Right-of-Ways (Bautista et al. 2019)
Date March 2019
Project Number(s) Cultural Surveys Hawai‘i, Inc. (CSH) Job Code: HIONAMOA 2
Investigation Permit Number CSH completed the archaeological inventory survey (AIS) fieldwork under archaeological fieldwork permit numbers 18-15 and 19-07, issued by the Hawai‘i State Historic Preservation Division (SHPD) per
Hawai‘i Administrative Rules (HAR) §13-282.
Agencies United States Environmental Protection Agency (EPA); Hawaiʻi State Department of Health (DOH); SHPD; County of Hawai‘i Department of
Environmental Management (DEM), Wastewater Division
Land Jurisdiction County; private (Kamehameha Schools, Olson Trust)
Project Proponent County of Hawai‘i DEM
Project Funding EPA (EPA Grant XP-96942401-6); State Revolving Fund
Project Location The project is located in the town of Pāhala, approximately 5 km
(3.1 miles) back from the coast in the Ka‘ū District, Hawai‘i Island. The
project area crosses portions of Hionamoa, Pālima, and Pāʻauʻau 1 and 2 Ahupuaʻa. The proposed treatment plant is located adjacent to the Maile Street and Hawaiʻi Belt Road (Route 11) intersection. The project
and is depicted on a portion of the 1995 Pahala U.S. Geological Survey (USGS) 7.5-minute topographic quadrangle.
Project Description The project includes closure of two Large Capacity Cesspools (LCCs)
and development of a new collection system and treatment and disposal
facility to service the Pāhala community. The collection system is located on county streets. The treatment disposal facility will occupy 14.9 acres and is located on a portion a 42.5-acre property (TMK: [3] 9-6-002:018) near the southern edge of Pāhala Town presently owned by
Kamehameha Schools and under lease to Royal Hawaiian Orchards.
Almost the entire parcel is planted in a commercial macadamia nut
orchard, with a macadamia nut processing plant parking lot in the southeastern corner outside the limits of the current project area.
Area of Potential Effect (APE) and AIS Project Area Acreage
The project APE comprises 57.7 acres (23.4 hectares) in Pāhala Town,
while the AIS project area is a 29.3-acre (11.8 hectares) area within the APE. The TMK parcels listed under “Reference” above are those associated with the project area; a full list of TMK parcels for the
overall APE is given in Appendix A.
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Management Summary
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawai‘i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
ii
The APE includes the following:
1. The 14.9-acre wastewater treatment plant (WWTP) site, within which all project-related staging, including for the collection
system and the treatment and disposal facility, will be located;
2. An approximately 1,500-foot (ft) long by 25-ft wide utility
easement (about 0.94 acres) located entirely within TMK: [3] 9-6-002:018 to connect the collection system line and other utilities to the WWTP;
3. The path of the new sewer collection lines, to be located within
the 22- to 24-ft wide travel surface of select county streets;
4. Sewer line easements of similar width (22-24 ft) through TMKs: [3] 9-6-005:036 and 044 connecting the collection lines to the proposed Pāhala WWTP site;
5. The existing LCC 1 and 2 locales (located in TMKs: [3] 9-6-
002:016 and 9-6-016:041, respectively), and an approximately
100-m (328-ft) long by 15-m (49-ft) wide corridor along the
existing sewer line easement in TMK: [3] 9-6-002:016 between Maile Street and LCC 1; and
6. Numerous single-family residential/other properties with
existing sewer laterals, some of which may need to be
replaced/repaired/rehabilitated by the County.
The AIS project area comprises Items 1–5 within the project APE, except for the LCC 2 location behind a private residence in TMK: [3] 9-
6-016:041. It also does not include the numerous private properties
located along the county streets selected for new sewer collection lines (Item 6).
Historic Preservation
Regulatory Context This AIS investigation was designed to comply with both federal and
Hawai‘i State environmental and historic preservation review legislation. Due to federal (EPA) funding, this project is a federal
undertaking, requiring compliance with Section 106 of the National Historic Preservation Act (NHPA) and the National Environmental
Policy Act (NEPA). As a county project within both private and county
lands, the project is also subject to Hawai‘i State environmental and
historic preservation review legislation (Hawai‘i Revised Statutes [HRS] §343 and HRS §6E-8/HAR §13-275, respectively).
In consultation with the SHPD, this archaeological inventory survey
(AIS) investigation fulfills the requirements of HAR §13-276 and the
Secretary of the Interior’s Standards for Archaeology and Historic
Preservation. It was conducted to identify, document, and make National Register of Historic Places (National Register) and Hawai‘i Register of Historic Places (Hawai‘i Register) eligibility
recommendations for any historic properties. This report is also
intended to support any project-related historic preservation
consultation with stakeholders such as state and county agencies and
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Management Summary
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawai‘i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
iii
interested Native Hawaiian Organizations (NHOs) and community
groups, if applicable.
Pacific Legacy in 2016 conducted an archaeological field inspection of
the entire 42.5-acre TMK: [3] 9-6-002:018 (Cleghorn 2016). The
11 November 2016 letter report was addressed to Dora Beck, P.E.,
Wastewater Division Chief for the County DEM Wastewater Division.
The report noted extensive ground disturbance throughout the parcel conducted “prior to the planting of the present macadamia nut orchard.
The area at the southeastern corner of the parcel that is not planted in
macadamia nut trees has also been extensively disturbed and a portion
of it serves as a graveled parking lot for the adjacent macadamia nut
processing plant.” A sealed lava tube entrance is present in this corner of the parcel outside the current project area. No surface archaeological
features were documented by Cleghorn (2016). A handful of surface
artifacts, including a single discoidal hammerstone and fragmental
bottle glass and ceramics, were documented within the northern portion
of the parcel outside the current project area. Cleghorn (2016) recommended consultation with SHPD about project historic
preservation requirements, noting that SHPD would likely require an
AIS. Cleghorn (2016) also recommended limiting the project area
footprint to avoid the lava tube located in the southeastern corner of TMK: [3] 9-6-002:018.
On 17 October 2017 the project proponent provided a written request to
the SHPD for a letter of determination in accordance with HAR §13-
275-3 (Appendix B). The Cleghorn (2016) letter report was attached as
supportive information.
CSH on 22 February 2018 met with SHPD Archaeology Branch Chief Dr. Susan Lebo to follow up on a 17 October 2017 request for project
determination. During this meeting Dr. Lebo indicated the following:
• An AIS should be undertaken addressing the entire area of
proposed ground disturbance, with subsurface testing;
• The AIS should include a “good faith effort” to address possible
lava tubes within the area of proposed ground disturbance;
• Backhoe assisted excavations should be conducted within
select proposed features at the plant site;
• All areas of the project not included in TMK: [3] 9-6-002:018
should be addressed, in particular the lateral installations along the county roadways; these areas probably would not require subsurface testing but should be evaluated for any relation to a possible historic plantation village or historic property
designation.
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Management Summary
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawai‘i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
iv
The items outlined above, and a more detailed summary of the subsurface testing schema, were supplied in a 22 March 2018 county DEM letter addressed to SHPD, which requested formal written
concurrence with the AIS approach; additional materials were
subsequently supplied to SHPD on request (see Appendix B). SHPD
replied to this letter concurring with the AIS approach in a §6E-8 and
NHPA Section 106 Review letter dated 20 August 2018 (Log No.: 2018.00722; Doc. No.: 1808JA02) (Appendix C).
CSH on 6 December 2018 met with Dr. Susan Lebo and Dr. Jane Allen
of SHPD to discuss the project APE and documentation requirements (Appendix D).
Fieldwork Effort CSH archaeologists Olivier Bautista, B.A., and Sarah Wilkinson, B.A.,
conducted fieldwork on 18 September 2018, 1–4 October 2018, and
10 January 2019 under the general supervision of Principal Investigator
Hallett H. Hammatt, Ph.D. This work required approximately 8 person-days to complete.
Consultation Consultation is being undertaken for the project to comply with Section 106 of the NHPA. Presently, Section 106 consultation with community, agency, and Native Hawaiian Organizations has been initiated and is ongoing by the project proponents. The results of the
current investigation will be utilized in these ongoing efforts. To date,
no historic properties have been assessed as having traditional cultural significance to an ethnic group (Criterion e) within the project area.
Historic Properties
Identified Two newly documented historic properties were identified through
background research: State Inventory of Historic Places (SIHP) #s 50-
10-69-31088 is the historic Wood Valley Road/Coastal Road corridor, and SIHP # 50-10-69-31089 is the historic Volcano Road corridor. They are both assessed as significant under Criterion d for yielding
important information for research on former rights of way in Pahala
history. Constructed elements of the portions of these road alignments within the project area have been thoroughly impacted by the development of modern roadways, becoming Maile Street and Pikake Street in Pahala town within the original corridors. Due to the impacts
and changes to these roads in Pāhala over time these historic properties only maintain integrity of location of the old corridor.
SIHP # s -31088 and -31089 are assessed as significant under Criterion d per HAR §13-275-6 for the information they have yielded about primary transportation routes in the Pāhala vicinity during the late
nineteenth and early twentieth centuries.
Effect Recommendation Following consultation among EPA, DOH, DEM, and SHPD regarding the project effect for the segments of the Wood Valley/Coastal Road
(SIHP # 50-10-69-31088) and Volcano Road (SIHP # 50-10-69-31089)
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Management Summary
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawai‘i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
v
within the project area under HRS §6E-8, per HAR § 13-275-7(a)(1) the
County of Hawaiʻi DEM’s project effect determination is “no historic properties affected.” In accordance with federal regulations (36 CFR
800.5), the AIS results support a determination of “no historic
properties affected.”
Mitigation Recommendations No mitigation commitments are recommended for the portions of SIHP #s 50-10-69-31088 and -31089 within the project area. The portions of
these historic properties within the project area only maintain integrity of location as all of the constructed elements of the original Wood Valley/Coastal road and Volcano road are no longer evident today.
While this project will have no effect on historic properties, archaeological monitoring during construction for identification and/or
cautionary measures is proposed. This is based on the location of the
project being within the “Pahala Historic District” (SIHP # 50-10-69-
07362), as well as the presence near the project area of three historic properties as follows:
• a lava tube system (SIHP # 50-10-69-27570) with some cultural modifications beneath Pahala town;
• Kaʻū High and Pāhala Elementary School (SIHP # 50-10-69-07522), a National Register-eligible historic property; and
• the Hawaiʻi Belt Road, (SIHP # 50-10-47-30187), a National Register-eligible historic property south of the project area.
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawai‘i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
vi
Table of Contents
Management Summary ............................................................................................................ i
Section 1 Introduction ............................................................................................................. 1
Project Background ....................................................................................................................... 1 Historic Preservation Regulatory Context and Document Purpose ............................................... 8 Environmental Setting ................................................................................................................... 9
1.3.1 Natural Environment............................................................................................................... 9 1.3.2 Built Environment................................................................................................................. 10
Section 2 Methods .................................................................................................................. 13
Field Methods .............................................................................................................................. 13
2.1.1 Pedestrian Survey ................................................................................................................. 13 2.1.2 Subsurface Testing ................................................................................................................ 13
Laboratory Methods ..................................................................................................................... 13 Research Methods ........................................................................................................................ 14 Consultation Methods .................................................................................................................. 14
Section 3 Background Research ........................................................................................... 15
Traditional and Historical Background ........................................................................................ 15 3.1.1 Traditional Accounts............................................................................................................. 15
3.1.2 Early Historic Period ............................................................................................................ 16
3.1.3 The Māhele and the Kuleana Act ......................................................................................... 19 3.1.4 Mid- to Late 1800s ................................................................................................................ 21
3.1.5 1900s ..................................................................................................................................... 25 3.1.6 Contemporary Land Use ....................................................................................................... 29 Previous Archaeological Research .............................................................................................. 33
3.2.1 Previous Archaeological Studies .......................................................................................... 33 National Register-Eligible Historic Properties in the Vicinity .................................................... 40 3.3.1 Kaʻū High and Pāhala Elementary School ............................................................................ 40
3.3.2 Māmalahoa Highway ............................................................................................................ 40 Background Summary and Predictive Model .............................................................................. 40
Section 4 Results of Fieldwork .............................................................................................. 42
Pedestrian Inspection Results ...................................................................................................... 42 Subsurface Testing Results .......................................................................................................... 54 4.2.1 Test Excavation 1 (TE 1) ...................................................................................................... 54
4.2.2 Test Excavation 2 (TE 2) ...................................................................................................... 60 4.2.3 Test Excavation 3 (TE 3) ...................................................................................................... 60 4.2.4 Test Excavation 4 (TE 4) ...................................................................................................... 60
4.2.5 Test Excavation 5 (TE 5) ...................................................................................................... 60 4.2.6 Test Excavation 6 (TE 6) ...................................................................................................... 60
4.2.7 Test Excavation 7 (TE 7) ...................................................................................................... 71
Section 5 Historic Property Descriptions ............................................................................. 74
SIHP # 50-10-69-31088 ............................................................................................................... 74 SIHP # 50-10-69-31089 ............................................................................................................... 77
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawai‘i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
vii
Section 6 Significance Assessments and Register Eligibility .............................................. 78
Significance Assessments under HRS §6E .................................................................................. 78 National Register and Hawai‘i Register Eligibility Determination ............................................. 78
Section 7 Summary and Interpretation ............................................................................... 80
Section 8 Project Effect and Mitigation Recommendations ............................................... 81
Project Effect ............................................................................................................................... 81
Mitigation Recommendations ...................................................................................................... 81
Section 9 References Cited .................................................................................................... 82
Appendix A APE Land Jurisdiction ..................................................................................... 86
Appendix B County of Hawaiʻi Correspondence to SHPD ................................................ 88
Appendix C SHPD Correspondence................................................................................... 102
Appendix D SHPD Meeting Notes ...................................................................................... 104
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawai‘i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
viii
List of Figures
Figure 1. Portion of the 1995 Pahala USGS 7.5-minute topographic quadrangle showing the
location of the project area ...................................................................................................2
Figure 2. Tax Map Key (TMK) [3] 9-6-05 showing the northern portion of the project area (Hawai‘i TMK Service 2018) ..............................................................................................3 Figure 3. TMK: [3] 9-6-02 showing the southern portion of the project area (Hawai‘i TMK
Service 2018) .......................................................................................................................4
Figure 4. Aerial photograph of the project area (Google Earth 2013) .............................................5
Figure 5. Aerial photograph of the project area, showing its configuration within the greater
project APE and the locations of LCCs 1 and 2 (Google Earth 2013) ................................6 Figure 6. Preliminary site plan showing the 14.9-acre Pāhala WWTP and utility easement
through TMK: [3] 9-6-002:018 (courtesy of client) ............................................................7
Figure 7. Overlay of Soil Survey of the State of Hawaii (Sato et al. 1972), indicating soil types
within and surrounding the project area (USDA SSURGO 2001) ....................................11
Figure 8. Portion of R.F. Pierce’s 1914 map of Kalaala and Moaula-Kopu-Makaka Makai Government Tracts, showing the project area in relation to roads, trails, and the plantation
railroad ...............................................................................................................................20
Figure 9. F.S. Lyman 1877 map of Hawaiian Agricultural Company sugarcane lands, showing
the project area in relation to the Pāhala Mill and developed cane lots .............................23
Figure 10. Portion of W.A. Wall’s 1886 map of Hawai‘i Island, showing the project area in relation to sugar mills and harbors in windward Kaʻū .......................................................24
Figure 11. Portion of J.M. Donn’s 1906 map of Hawai‘i Island, showing the project area in
relation to Pāhala Mill, school, post office, and areas of different land use ......................26
Figure 12. 1929 map of Hawaiian Agricultural Co. cane fields, showing the location of the
project area .........................................................................................................................27 Figure 13. Portion of the 1930 Palima Point USGS 7.5-minute topographic quadrangle showing
the project area in relation to the mill, school, church, roads, and railroad in the Pāhala
vicinity ...............................................................................................................................28
Figure 14. Portion of the 1967 Pahala USGS 7.5-minute topographic quadrangle showing the
project area and development within Pāhala Town ...........................................................30 Figure 15. Portion of an undated field map of the Pahala Mill and Camp reprinted in Cleghorn
(2016:13) showing the project area in relation to plantation features ...............................31
Figure 16. Portion of the 1977 USGS orthophotoquad aerial photo, Pahala Quadrangle, showing
the project area and continued development of Pāhala Town ...........................................32
Figure 17. Portion of the 1995 Pahala USGS 7.5-minute topographic quadrangles showing previous archaeological studies in the vicinity of the project area ....................................35
Figure 18. Portion of the 1995 Pahala USGS 7.5-minute topographic quadrangles showing
locations of sites documented in previous archaeological studies in the vicinity of the
project area .........................................................................................................................36
Figure 19. Aerial photo showing the Escott (2013) project area and site locations (Escott 2013:18) .............................................................................................................................38
Figure 20. Survey map of SIHP # -29501 burial and SIHP # -27570 lava tube ceiling thicknesses
(Escott 2013:19); note the tube is set back from Kamani Street and Puahala Street where
a portion of the current project area is located ...................................................................39
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawai‘i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
ix
Figure 21. Aerial photo of the project area (Google Earth 2013) showing the locations of newly documented historic properties ..........................................................................................43
Figure 22. Photo showing the portion of the easement in TMK: [3] 9-6-005:036 that extends
from Maile Street along an existing asphalt driveway; view northwest ............................44
Figure 23. Photo showing the portion of the easement in TMK: [3] 9-6-005:036 that passes
through the old plantation maintenance yard; the structures present to either side are outside the project area; view to northwest........................................................................44
Figure 24. Photo showing the forested area between the maintenance yard and Ilima Street at the
northern end of the easement in TMK: [3] 9-6-005:036; view to northwest .....................45 Figure 25. Photo showing the location where the easement in TMK: [3] 9-6-005:036 exits at Ilima Street (frame right); the earthen drainage channel extending from the Huapala Street culvert is beneath the grass to the left of the road; view to southwest ....................45
Figure 26. Photo looking down Huapala Street; note linear drainage in grassy lawn on left side of
photo; view to southeast.....................................................................................................46
Figure 27. Photo looking up Ilima Street; note drainage in grassy shoulder on right side of photo; view to northwest ...............................................................................................................46 Figure 28. Photo looking up Hinano Street from the eastern Huapala Street intersection; view to
northwest ............................................................................................................................47
Figure 29. Photo looking up Hala Street from the Hinano Street intersection; view to north .......47
Figure 30. Photo of the intersection of Pikake and Puahala streets; view to northwest ................48
Figure 31. Photo of the culvert located at the Huapala Street and Ilima Street intersection; view to northeast .........................................................................................................................48
Figure 32. Photo looking up Pikake toward the Kamani Street intersection; commercial center is
visible to the right; view to north .......................................................................................50 Figure 33. Photo showing the Pikake Street terminus at Maile Street; Hawaiian Telcom building
is on opposite corner; view to southwest ...........................................................................50 Figure 34. Photo of a portion of Maile Street within the project area, showing the Pikake Street
intersection in the background and the HELCO building (left frame); view to northeast .51
Figure 35. Photo of a portion of Maile Street in the project area, showing the Lower Moaula
Road fork in the far background; view to southwest .........................................................51
Figure 36. Representative photo of the macadamia orchard; note the surface irrigation lines between the trees; view to southwest .................................................................................52
Figure 37. Photo of the paved road that passes through the macadamia orchard between Maile
Street and the macadamia nut husking plant; this road forms the mauka boundary of the
proposed WWTP site portion of the project area; view to northeast .................................52
Figure 38. Photo showing the margin of the macadamia orchard at the southeastern corner of the proposed WWTP site portion of the project area; a dozer push pile is present beneath the
grass along the left side of the photo; view to southwest ..................................................53
Figure 39. Photo showing a portion of the linear push pile/berm located along the wind break bisecting the macadamia orchard; view to southwest ........................................................53
Figure 40. Photo of the sewer manhole located along the existing, maintained sewer easement within TMK: [3] 9-6-002:016; view to southwest .............................................................55
Figure 41. Photo showing the LCC 1 location at the makai terminus of the existing, maintained
sewer easement within TMK: [3] 9-6-002:016; view to south ..........................................55
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawai‘i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
x
Figure 42. Aerial photograph showing the locations of the seven test excavation trenches within the proposed WWTP site portion of the project area (TE 1 through TE 7) (Google Earth
2013) ..................................................................................................................................56
Figure 43. Preliminary WWTP site plan, overlain with locations of the seven test excavation
trenches within the proposed WWTP site portion of the project area (TE 1 through TE 7)
(site plan courtesy of client, with Google Earth 2013 overlay added)...............................57 Figure 44. Photo of TE 1 marked out with flagging tape prior to excavation; view to southwest 58
Figure 45. Photo of TE 1 northwest sidewall profile; view to northwest .....................................58
Figure 46. Profile of TE 1 northwest sidewall ...............................................................................59
Figure 47. Photo of TE 2 marked out with flagging tape prior to excavation; view to southeast .61
Figure 48. Photo of TE 2 southwest sidewall; view to northeast...................................................61 Figure 49. Stratigraphic profile of TE 2 southwest sidewall .........................................................62
Figure 50. Photo of TE 3 marked out with flagging tape prior to excavation; view to southeast .63
Figure 51. Photo of TE 3 west sidewall; view to northeast ...........................................................63
Figure 52. Stratigraphic profile of TE 3 northeast sidewall...........................................................64
Figure 53. Photo of TE 4 marked out with flagging tape prior to excavation; view to south .......65 Figure 54. Photo of TE 4 northwest sidewall; view to northwest ..................................................65
Figure 55. Stratigraphic profile of TE 4 northwest sidewall .........................................................66
Figure 56. Photo of TE 5 marked out with flagging tape prior to excavation; view to southwest 67 Figure 57. Photo of TE 5 southwest sidewall; view to south.........................................................67
Figure 58. Stratigraphic profile of TE 5 southwest sidewall .........................................................68 Figure 59. Photo of TE 6 marked out with flagging tape prior to excavation; view to southwest 69
Figure 60. Photo of TE 6 southeast sidewall; view to southeast ...................................................69
Figure 61. Stratigraphic profile of TE 6 southeast sidewall ..........................................................70
Figure 62. Photo of TE 7 marked out with flagging tape prior to excavation; view to southwest 72 Figure 63. Photo of TE 7 south sidewall; view to southeast ..........................................................72 Figure 64. Stratigraphic profile of TE 7 southeast sidewall ..........................................................73
Figure 65. Portions of the 1995 Wood Valley, Pahala, Punaluu, and Naalehu USGS 7.5-minute
topographic quadrangles showing the location of the project area in relation to historic roadways ............................................................................................................................75
Figure 66. Portions of the 1995 Pahala and Punaluu USGS 7.5-minute topographic quadrangles showing the location of the project area in relation to historic roadways .........................76
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawai‘i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
xi
List of Tables
Table 1. Previous archaeological studies in the vicinity of the project area ..................................34
Table 2. TE 1 stratigraphic description ..........................................................................................59
Table 3. TE 2 stratigraphic description ..........................................................................................62
Table 4. TE 3 stratigraphic description ..........................................................................................64 Table 5. TE 4 stratigraphic description ..........................................................................................66
Table 6. TE 5 stratigraphic description ..........................................................................................68
Table 7. TE 6 stratigraphic description ..........................................................................................70
Table 8. TE 7 stratigraphic description ..........................................................................................73
Table 9. Sites identified within the current project area ................................................................74
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Introduction
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawai‘i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
1
Section 1 Introduction
Project Background
At the request of Wilson Okomoto Corporation and on behalf of the County of Hawaiʻi
Department of Environmental Management, Wastewater Division, Cultural Surveys Hawai‘i, Inc.
(CSH) has prepared this archaeological inventory survey report (AISR) for the Pāhala Wastewater Treatment Plant and Sewer System project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2 Ahupua‘a,
Ka‘ū District, Hawai‘i Island, TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County of Hawaiʻi Right-of-Ways. The project area is located within a larger Area of
Potential Effect (APE) in the town of Pāhala. The project area is depicted on a portion of the 1995
Pahala U.S. Geological Survey (USGS) 7.5-minute topographic quadrangle (Figure 1), tax map
plats (Figure 2 and Figure 3), and a 2013 aerial photograph (Figure 4).
The project includes closure of two Large Capacity Cesspools (LCCs) and development of a new collection system and treatment and disposal facility to service the Pāhala community. The
collection system is located on county streets. The treatment disposal facility will occupy
14.9 acres and is located on a portion a 42.5-acre property (TMK: [3] 9-6-002:018) near the
southern edge of Pāhala Town adjacent to the Maile Street and Hawaiʻi Belt Road (Route 11) intersection. This parcel is presently owned by Kamehameha Schools and under lease to Royal Hawaiian Orchards. Almost the entire parcel is planted in a commercial macadamia nut orchard,
with a macadamia nut processing plant parking lot in the southeastern corner outside the limits of
the current project APE.
The project APE comprises 57.7 acres (23.4 hectares) in Pāhala Town, while the AIS project area is a 29.3-acre (11.8 hectares) area within the APE (Figure 5). The TMK parcels listed above are those associated with the project area; a full list of TMK parcels for the overall APE is given
in Appendix A. The APE includes the following:
1. The 14.9-acre wastewater treatment plant (WWTP) site, within which all project-related
staging, including for the collection system and the treatment and disposal facility, will be located (Figure 6); 2. An approximately 1,500-foot (ft) long by 25-ft wide utility easement (about 0.94 acres)
located entirely within TMK: [3] 9-6-002:018 to connect the collection system line and
other utilities to the WWTP (see Figure 6); 3. The path of the new sewer collection lines, to be located within the 22- to 24-ft wide travel surface of select county streets; 4. Sewer line easements of similar width (22-24 ft) through TMKs: [3] 9-6-005:036 and
044 connecting the collection lines to the proposed Pāhala WWTP site;
5. The existing LCC 1 and 2 locales (located in TMKs: [3] 9-6-002:016 and 9-6-016:041,
respectively), and an approximately 100-m (328-ft) long by 15-m (49-ft) wide corridor
along the existing sewer line easement in TMK: [3] 9-6-002:016 between Maile Street and LCC 1; and
6. Numerous single-family residential/other properties with existing sewer laterals, some
of which may need to be replaced/repaired/rehabilitated by the County.
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Introduction
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawai‘i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
2
Figure 1. Portion of the 1995 Pahala USGS 7.5-minute topographic quadrangle showing the
location of the project area
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Introduction
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawai‘i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
3
Figure 2. Tax Map Key (TMK) [3] 9-6-05 showing the northern portion of the project area (Hawai‘i TMK Service 2018)
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Introduction
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawai‘i
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
4
Figure 3. TMK: [3] 9-6-02 showing the southern portion of the project area (Hawai‘i TMK Service 2018)
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Introduction
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
5
Figure 4. Aerial photograph of the project area (Google Earth 2013)
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Introduction
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
6
Figure 5. Aerial photograph of the project area, showing its configuration within the greater project
APE and the locations of LCCs 1 and 2 (Google Earth 2013)
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Introduction
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
7
Figure 6. Preliminary site plan showing the 14.9-acre Pāhala WWTP and utility easement through TMK: [3] 9-6-002:018 (courtesy of client)
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Introduction
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
8
The AIS Project Area comprises Items 1–5 within the project APE, except for the LCC 2 location behind a private residence in TMK: [3] 9-6-016:041. It also does not include the numerous
private properties located along the county streets selected for new sewer collection lines (Item 6).
The gravity sewer collection system lines will be mostly 8-inch diameter lines with the others
from 12 to 16 inches, depending on their location, and will be placed in trenches located within
the county streets. The trenches will be 3 to 4 ft wide and will be approximately 6 ft deep, or deeper depending on the location. For the former C. Brewer properties, the sewer laterals connecting the
parcels to the collection system in the street have already been installed, although some of them
may need to be replaced/repaired/rehabilitated by the County. For other properties that may eventually connect, the owners will be responsible for the improvements on their private property
to connect to the collection system at the property line.
Historic Preservation Regulatory Context and Document Purpose
This AIS investigation was designed to comply with both federal and Hawai‘i State
environmental and historic preservation review legislation. Due to federal (Environmental Protection Agency [EPA]) funding, this project is a federal undertaking, requiring compliance with
Section 106 of the National Historic Preservation Act (NHPA) and the National Environmental
Policy Act (NEPA). As a county project within both private and county lands, the project is also
subject to Hawai‘i State environmental and historic preservation review legislation (Hawai‘i Revised Statutes [HRS] §343 and HRS §6E-8/Hawai‘i Administrative Rules [HAR] §13-275, respectively).
In consultation with the State Historic Preservation Division (SHPD), this AIS investigation
fulfills the requirements of HAR §13-276 and the Secretary of the Interior’s Standards for
Archaeology and Historic Preservation. It was conducted to identify, document, and make National Register of Historic Places (National Register) and Hawai‘i Register of Historic Places (Hawai‘i Register) eligibility recommendations for any cultural resources/historic properties. This
report is also intended to support any project-related historic preservation consultation with
stakeholders such as State and County agencies and interested Native Hawaiian Organizations
(NHOs) and community groups, if applicable.
Pacific Legacy in 2016 conducted an archaeological field inspection of the entire 42.5-acre TMK: [3] 9-6-002:018 (Cleghorn 2016). The 11 November 2016 letter report was addressed to
Dora Beck, P.E., Wastewater Division Chief for the County Department of Environmental
Management (DEM) Wastewater Division. The report noted extensive ground disturbance
throughout the parcel conducted “prior to the planting of the present macadamia nut orchard. The
area at the southeastern corner of the parcel that is not planted in macadamia nut trees has also been extensively disturbed and a portion of it serves as a graveled parking lot for the adjacent
macadamia nut processing plant.” A sealed lava tube entrance is present in this corner of the parcel
outside the current project area. No surface archaeological features were documented by Cleghorn
(2016). A handful of surface artifacts, including a single discoidal hammerstone and fragmental
bottle glass and ceramics, were documented within the northern portion of the parcel outside the current project area. Cleghorn (2016) recommended consultation with SHPD about project historic
preservation requirements, noting that SHPD would likely require an AIS. Cleghorn (2016) also
recommended limiting the project area footprint to avoid the lava tube located in the southeastern corner of TMK: [3] 9-6-002:018.
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Introduction
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
9
On 17 October 2017 the project proponent provided a written request to the SHPD for a letter of determination in accordance with HAR §13-275-3 (Appendix A). The Cleghorn (2016) letter
report was attached as supportive information.
CSH on 22 February 2018 met with SHPD Archaeology Branch Chief Dr. Susan Lebo to follow
up on 17 October 2017 request for project determination. During this meeting Dr. Lebo indicated the following:
• An AIS should be undertaken addressing the entire area of proposed ground disturbance,
with subsurface testing;
• The AIS should include a “good faith effort” to address possible lava tubes within the area of proposed ground disturbance;
• Backhoe assisted excavations should be conducted within select proposed features at
the plant site;
• All areas of the project not included in TMK: [3] 9-6-002:018 should be addressed, in particular the lateral installations along the county roadways; these areas probably would not require subsurface testing but should be evaluated for any relation to a
possible historic plantation village or historic property designation.
The items outlined above, and a more detailed summary of the subsurface testing schema, were
supplied in a 22 March 2018 county DEM letter addressed to SHPD, which requested formal written concurrence with the AIS approach; additional materials were subsequently supplied to SHPD on request (see Appendix A). SHPD replied to this letter concurring with the AIS approach
in a §6E-8 and NHPA Section 106 Review letter dated 20 August 2018 (Log No.: 2018.00722;
Doc. No.: 1808JA02) (Appendix B).
CSH on 6 December 2018 met with Dr. Susan Lebo and Dr. Jane Allen of SHPD to discuss the project APE and documentation requirements (Appendix D).
Environmental Setting
1.3.1 Natural Environment
The project area is situated approximately 5 km (3.1 miles) back from the coast on the
southeastern slope of Mauna Loa volcano, at an elevation of 170–305 m (590–1,000 ft) above
mean sea level (amsl). The Pāhala Town vicinity receives an annual average rainfall of 52 inches
(Giambelluca et al. 2013), which today supports commercial agricultural crops like coffee and
macadamia nuts and historically supported sugarcane. The Kaʻū Forest Reserve is located approximately 2.5 miles upslope. Gulches carrying flood waters from the forest reserve makai (seaward; downslope) bracket the town; no natural waterways are present within the project area.
Vegetation within the proposed treatment plant 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 extends through the orchard and areas of grasses and weeds. Landscaped residential yards line the sides of the County roadways in Pāhala Town. The terrain along the roadways ranges from level to sloped.
The unique geology of its upper slopes, lined with a string of large puʻu (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 “Pāhala Ash.”
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Introduction
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
10
According to the U.S. Department of Agriculture (USDA) Soil Survey Geographic (SSURGO) database (2001) and soil survey data gathered by Sato et al. (1973), the project area’s soils consist
of soils from the Waiaha and Naalehu series (Figure 7). The northern half of the project area is
Waiaha silt loam, 0 to 10% slopes (WAC), and the southeastern corner is Waiaha silt loam, 10 to 20% slopes (WKD). The remaining portions of the project area are Naalehu silty clay loam 0%-
10% slopes (NaC) and Naalehu silty clay loam 10%-20% slopes (NaD) (see Figure 7).
Waiaha soils are described as
shallow, well-drained silt loams that formed in volcanic ash. These soils are nearly
level to moderately steep and most areas are extremely stony . . . The natural
vegetation consists of kiawe, koa haole, natal redtop, lantana, guineagrass, and bermudagrass. . .
Waiaha soils are used for pasture. [Sato et al. 1973:52]
The WAC type has a non-stony surface layer and “receives more rain during the winter than
the extremely stony soil;” it is also used for orchards (Sato et al. 1973:53).
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 used for pasture. [Sato et al. 1973:40]
1.3.2 Built Environment
The entire project area has been altered by agricultural, commercial, and residential development. The location of the proposed treatment plant is currently an active macadamia nut
orchard operated by Royal Hawaiian Orchards. This portion of the project area is on the southern
outskirts of Pāhala Town, bound to the west by Maile Street, to the south by the Hawaiʻi Belt Road
or Māmalahoa Highway (State Inventory of Historic Places [SIHP] # 50-10-47-30187), to the north by additional macadamia orchard, and to the east by an unimproved jeep road separating the orchard from the Royal Hawaiian processing facilities. This road is bound to the east by a concrete
flume extending mauka-makai (from mountains to sea), located outside the project area. An
unnamed paved roadway forms the approximate northern boundary of the proposed plant area; this
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 trees forming additional wind-breaks; unimproved access roads run along
both sides of this push pile.
The proposed sewer collection line extends for the most part along existing, paved County roadways including Maile Street, Pikake Street, Ilima Street, Huapala Street, Hinano Street,
Kamani Street, and Puahala Street (see Figure 4). These roadways extend through predominately
residential areas of Pāhala Town. The portion of Maile Street in which the sewer line will be placed
is located between the Pikake Street/Old Camp Mill Road intersection and the Lower Moaʻula
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Introduction
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
11
Figure 7. Overlay of Soil Survey of the State of Hawaii (Sato et al. 1972), indicating soil types
within and surrounding the project area (USDA SSURGO 2001)
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Introduction
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
12
Road fork. Remnants of the sugar mill and associated plantation structures are present on either side of Maile Street outside of the project area.
Three sewer line easements are proposed for portions of the sewer line not within county
roadways. One of these easements would extend along the southernmost segment of Pikake Street,
which crosses privately owned TMK: [3] 9-6-005:044. This sewer line easement would also be
within the existing paved roadway. Another easement extends from the eastern section of ‘Ilima Street through the old Pāhala Sugar Mill maintenance yard at TMK: [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 a portion of a roadway used to access Kaʻalaʻiki Road/Pāhala Cane Haul Road. Though this overall parcel is within the project APE, no new sewer connections are proposed under the current project for any of its structures. The easement extends between and around the existing
historic structures on this parcel and exits the property at Maile Street, where the line then extends
southeast into TMK: [3] 9-6-002:018. The sewer line runs through the macadamia nut orchard,
connecting to the northern corner of the proposed plant site.
The project involves the closure of the two existing LCCs (LCC 1 and LCC 2). LCC 1 is located in TMK [3] 9-6-002:016 south of Maile Street, at the terminus of a sewer easement maintained by
the County. The portion of the parcel containing LCC 1 and its associated easement are fallow
cane land. LCC 2 and its tie-ins to existing sewer lines are located behind a private residence at TMK [3] 9-6-016:041. This residential property comprises a main dwelling, outbuildings,
driveway, and landscaped yard.
The sewer collection and transmission lines overlap with the known boundaries of the “Pāhala
Historic District.” In the 1970s the majority of Pāhala Town was designated SIHP # 50-10-69-
07362, a historic district associated with the historic sugar plantation and village. This historic
property is not listed on the National Register or Hawai’i Register, and to the best of our knowledge has never been evaluated for eligibility for listing on these registers. CSH was unable to locate any records on file at the SHPD offices in Hilo or Kapolei pertaining to SIHP # -07362.
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Methods
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
13
Section 2 Methods
Field Methods
CSH completed the fieldwork component of this archaeological inventory survey under
archaeological fieldwork permit number 18-15, issued by the SHPD pursuant to HAR §13-282.
Fieldwork was conducted on 18 September 2018 and 10 January 2019 by CSH Field Supervisor
Olivier Bautista, B.A., and Project Director Sarah Wilkinson, B.A.; and on 1-4 October 2018 by
Olivier Bautista B.A., under the general supervision of CSH Principal Investigator Hallett H. Hammatt, Ph.D. This work required approximately 8 person-days to complete. In general,
fieldwork included 100% pedestrian inspection of the project area, GPS data collection, and
subsurface testing.
2.1.1 Pedestrian Survey
A 100%-coverage pedestrian inspection of the project area was undertaken for the purpose of historic property identification and documentation. The pedestrian survey was accomplished
through systematic sweeps spaced 2-5 m apart depending on ground visibility.
Where a new historic property was encountered, the determination of its boundary was based
on factors including apparent age, architectural style, and the spatial and functional
interrelationships of both natural and man-made features.
2.1.2 Subsurface Testing
A program of subsurface testing was undertaken for the AIS to assess the potential for
subsurface archaeological features, including but not limited to buried cultural deposits and/or culturally modified lava tubes. The number and locations of the test excavations were chosen based on consultation with SHPD (see Appendices A and B). The subsurface testing program consisted of backhoe assisted excavation of seven trenches within the proposed plant site: one each within
proposed Lagoons 1 and 4, Groves 1–4, and the Wetland area. The test excavations were placed
to avoid trees, roots, and irrigation lines. In general, the seven linear trenches measured
approximately 5 m (20 ft) long and 1.0 m (3.2 ft), and all trenches were excavated to bedrock.
A stratigraphic profile of each test excavation was drawn and photographed. The observed sediments were described using standard USDA soil description observations/terminology.
Sediment descriptions included Munsell color; texture; consistence; structure; plasticity;
cementation; origin of sediments; descriptions of any inclusions, such as cultural material and/or
roots; lower boundary distinctiveness and topography; and other general observations. Were
stratigraphic anomalies or potential cultural deposits exposed, these were to be carefully represented on test excavation profile maps.
Laboratory Methods
No samples or cultural materials were collected during the AIS fieldwork; therefore, laboratory studies were unnecessary.
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Methods
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
14
Research Methods
Background research included a review of previous archaeological studies on file at the SHPD;
review of documents at Hamilton Library of the University of Hawai‘i, the Hawai‘i State Archives,
the Mission Houses Museum Library, the Hawai‘i Public Library, and the Bishop Museum Archives; study of historic photographs at the Hawai‘i State Archives and the Bishop Museum
Archives; and study of historic maps at the Survey Office of the Department of Land and Natural
Resources. Historic maps and photographs from the CSH library were also consulted. In addition,
Māhele records were examined from the Waihona ‘Aina database (Waihona ‘Aina 2000).
This research provided the environmental, cultural, historic, and archaeological background for the project area. The sources studied were used to formulate a predictive model regarding the
expected types and locations of cultural resources in the project area.
Consultation Methods
Consultation is being undertaken for the project to comply with Section 106 of the National
Historic Preservation Act (NHPA). Presently, Section 106 consultation with community, agency,
and Native Hawaiian Organizations has been initiated and is ongoing by the project proponents. The results of the current investigation will be utilized in these ongoing efforts. No historic properties have been assessed as having traditional cultural significance to an ethnic group (Criterion e) within the project area.
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Background Research
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
15
Section 3 Background Research
Traditional and Historical Background
3.1.1 Traditional Accounts
The district of Kaʻū is the southernmost and largest district of Hawaiʻi Island, encompassing
over 600,000 acres and nearly 30 ahupuaʻa (land divisions usually extending from uplands to the sea). The current project area crosses the boundaries of four ahupuaʻa, including (from west to east) Hionamoa, Pālima and Pāʻauʻau 1 and 2. According to Pukui et al. (1976:173, 177), Pāʻauʻau translates as “bath enclosure,” and Pālima literally means “five-fold.” The meaning of “Hionamoa”
was not found.
Traditional accounts concerning the area known as Pāhala are limited, likely due to scarcity of
pre-Contact settlement in the vicinity. Pāhala is a historic-era settlement that formed around a
sugar plantation in the late 1800s; the name “Pāhala” refers to a practice in the cane fields of “cultivation by burning mulch” (Pukui et al. 1976:174) made from the hala tree (Pandanus
tectorius). That sugar became one of the first industries of Kaʻū is indicative of the suitability of
this inland regions for agriculture: Handy and Handy (1972:558) note that the kula (plains) lands
of Kaʻū are “perhaps the finest arable country in the Hawaiian Islands.”
Given its geological and climatic complexity, it is not surprising that Kaʻū came to be known as a land of fierce and independent people, a “fatal land to chiefs.” These characteristics are
expressed in David Malo’s (1951) delineation of the responsibilities of the aliʻi (chiefly class), and
of the treatment meted out to those aliʻi who abused their power:
It was the king’s duty to seek the welfare of the common people, because they
constituted the body politic. Many kings have been put to death by the people because of their oppression of the maka‘āinana [populace].
The following kings lost their lives on account of their cruel exactions on the
commoners: Koihala was put to death in Kau, for which reason the district of Kau was called The Weir (Makaha) [Mākaha, “fierce Ka‘ū”]. [Malo 1951:195]
Samuel Kamakau, in Ruling Chiefs of Hawai‘i, mentions Ka‘ū as he recounts the political unification of the island of Hawai‘i under ‘Umi-a-Līloa during the sixteenth century.
I-mai-ka-lani was the chief of Ka-u. He was blind, but noted for his strength and
skill in battle. Many chiefs who had fought against him were destroyed. . . . ‘Umi-a-Liloa feared I-mai-ka-lani. . . After I-mai-ka-lani became blind the fight between him and ‘Umi continued . . . After I-mai-ka-lani’s death Ka-u became ‘Umi-a-Liloa’s. [Kamakau 1961:18–19]
Kamakau also details the shifts of power within Ka‘ū and other districts through generations on
the island of Hawai‘i. Power, apparently, did not necessarily transfer from a ruler to his descendants (Kamakau 1961:61–65).
At times, the contiguous districts Kohala, Kona, and Ka‘ū formed a triumvirate under a single ruler. However, such unions were subject to change as, according to Kamakau, in later times rule
over Ka‘ū was consolidated with that of Puna:
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Ka-lani-‘opu‘u and Keoua were the hereditary heirs to the land of Hawaii, for it had belonged to their father, Ka-lani-nui-‘i-a-mamao, and [his brother] Ka-lani-ke‘e-
au-moku; but Alapa‘i had seized it through force of arms and had slain the
inheritors.
. . . a great battle was fought [between Ka-lani-‘opu‘u and Alapa‘i] at Kualoa and
Mokaulele all the way to Mahinaakaka, at which Ka-lani-‘opu‘u almost lost his life . . . Ka-lani-‘opu‘u’s men were victorious that day, and the chief realized how
powerful his following was in chiefs and fighting men and how strong he himself
was to break men’s bones with his hands.
After this battle Mahinaakaka, Ka-lani-‘opu‘u ruled over Ka-‘u and Puna, for he was a native of Ka-‘u. There were the birth sands of his ancestors. [Kamakau 1961:76–77]
Kamakau’s account suggests the precariousness of the inter-district power combinations by the
ruling ali‘i during traditional Hawaiian times in Ka‘ū and other districts.
The chief Ka-lani-‘opu‘u ruled Ka‘ū during the eighteenth century just before the first European
visitors began to record their early impressions of the land and its people.
3.1.2 Early Historic Period
Lt. James King, sailing off the island of Hawai‘i during the 1779 voyage of Captain James
Cook, described the Ka‘ū first seen by Europeans:
The coast of Kaoo [Ka‘ū] presents a prospect of the most horrid and dreary kind:
the whole country appearing to have undergone a total change from the effects of some dreadful convulsion. The ground is every where covered with cinders and
intersected in many places with black streaks, which seem to mark the course of a
lava that has flowed, not many ages back, from the mountain Roa [Mauna Loa] to
the shore. The southern promontory looks like the mere dregs of a volcano. The
projecting headland is composed of broken and craggy rocks, piled irregularly on one another, and terminating in sharp points. [King 1784:104]
The only onshore exploration at Ka‘ū involved a search for freshwater:
When [Mr. Bligh] landed, he found no stream or spring, but only rain-water,
deposited in holes upon the rocks; and even that was brackish, from the spray of
the sea; and that the surface of the country was entirely composed of flags and ashes, with a few plants here and there interspersed. [King 1784:545]
Archibald Menzies, a surgeon and naturalist on the 1794 voyage of Captain George Vancouver,
describing an excursion from Kona across Ka‘ū to the top of Mauna Loa, found a different scene in areas that received more rainfall. Menzies writes of
a fine fertile valley [where he] put up for the night at a village called Kioloku, on a rich plantation belonging to Keawe-a-heulu.
. . . This was by far the most populous village we had yet met with since we left
Kealakekua. Towards the dusk of the evening, there fell some showers of rain
which gave a gay and refreshing look to the most enchanting scenes of rural
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industry with which we were surrounded. The economy with which these people laid out and managed their ground and the neatness with which they cultivated their
little fields made the whole valley appear more like a rich garden than a plantation.
A stream of water which fell from the mountain through the middle of it was ingeniously branched off on each side to flood and fertilize the most distant fields
at pleasure. [Menzies 1920:184–185]
This abundance was not isolated; continuing on his way east through the ahupua‘a of Honu‘apo
(approximately 9 miles southwest of Pālima), Menzies found
. . . the people everywhere busily employed in their little fields, many of which
were here cropped with plantains and bananas that had a ragged appearance from having little or no shelter, yet they bore fruit tolerably well. [Menzies 1920:185]
In 1823, Rev. William Ellis, journeying like Menzies from Kona through Ka‘ū, recorded his
impressions of the land, demonstrating like Menzies a willingnessto look and let the land speak
for itself. He describes the valley of Wai‘ōhinu (located approximately 12 miles southwest of the
project area) as open toward the sea, and on both sides adorned with gardens and interspersed with cottages, even to the summits of the hills.
A fine stream of fresh water, the first we had seen on the island, ran along the centre
of the valley, while several smaller ones issued from the rocks on the opposite side,
and watered the plantations below.
Our road, for a considerable distance, lay through the cultivated parts of this beautiful valley: the mountain taro, bordered by sugar-cane and bananas, was planted in fields six or eight acres in extent, on the sides of the hills, and seemed to
thrive luxuriantly. [Ellis 1963:133–134]
Ellis’ account confirms the upland luxuriance that had made the ahupua‘a of Wai‘ōhinu a center for the ali‘i of Ka‘ū. As Ellis continued his journey he moved closer to the coast and his journal
illumines areas where western eyes had previously perceived only a “prospect of the most horrid and dreary kind.” Travelling northeast toward Punalu‘u (located approximately 4.5 miles
southwest of the project area), Ellis found the countryside “more thickly inhabited [as his walk
continued] . . . The villages along the sea shore, were near together, and some of them extensive”
(Ellis 1963:136). Ellis also notes the intervening broad stretches of rough ‘a‘ā between the habitation areas. These flows had been made traversable by waterworn boulder paths. Ellis thus reveals the desolate coastline described 44 years earlier by James King was in fact the site of a
well-populated, active culture and economy where habitation centers, though isolated, were
accessible to each other and to the resources of land and sea.
William Ellis in 1823 may have been the first missionary to visit Ka‘ū. During the 1830s
Protestant missionaries based in Kona and Hilo made occasional tours into Ka‘ū, but a permanent missionary presence was not installed until the early 1840s when Catholic and Protestant missions
were established in the district. In 1841, a Catholic priest, Father Marechal, arrived in Ka‘ū and
within a few months boasted of 900 converts. The following year, 1842, the Protestant minister
John Paris reached Ka‘alu‘alu (located at Ka Lae, approximately 19 miles southwest of the project area) by schooner where he found,
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The shore was lined with hundreds of natives as our little boat neared the shore.. . . Then came greetings from the multitude, some kissing my hands and some taking
hold of my feet. A joyful ‘Aloha ino!’ with a low wail, rose from the aged ones.
[Paris 1926:89]
Paris’ account illustrates the abundant resources available in the district:
. . . two strong men, tattooed from head to foot, came in bearing a huge whole hog, baked entire minus hair and entrails. These bearers were followed by others,
dressed in the same style bringing calabashes of various sizes filled with fish, poi,
potatoes, then came melons, bananas, and sugar cane, and little gourds filled with
goat’s milk. All was spread out in royal Hawaiian style, a dozen kukuis [nuts from the Candlenut tree, Aleutris moluccana] burning and kahilis [feather standards] waving to and fro. [Paris 1926:90]
Paris settled in Wai‘ōhinu where he founded a church and school. Later, in 1843, a stone church
was also built at Punalu‘u to the northeast. Cordy (1986:21) postulates that around this time a settlement shift was occurring from coastal to inland regions, the result of depopulation and of
efforts to gain access to the government road and to populate the economic center of Waiʻōhinu.
Mission station reports, censuses, and accounts by visitors to Ka‘ū during the mid-nineteenth
century document changes to the district brought about by natural forces and the pressures of an
increasing western presence. A visitor to Wai‘ōhinu and its environs in 1849 anonymously
published an account describing the devastating effects of a drought and fire that had occurred three years earlier:
[W]e noticed many a tall, stately trunk, branchless and lifeless standing monument-
like, all over the country. On enquiry we ascertained that they were the remains of
a noble forest, which, with the whole surrounding country, were burnt in 1846. In
that year a severe drought visited the Island, the streams dried up, the grass
withered, and fire swept over the whole district. [Sailor in Kelly 1980:89]
The author also describes an area above the settlement at Wai‘ōhinu that, apparently undamaged
by the 1846 fire, probably represents the idyllic setting that had drawn the Ka‘ū ali‘i to the
ahupua‘a:
[W]e ascended the hills back of the mission, and when we had reached an elevation
of about 5,000 feet were repaid with one of the richest scenes it was our privilege to look upon. Below us lay, fashioned by the hand of nature, within a range of ten
miles, six lovely terraces, on which one thousand dwellings might be placed, each
of which should have a prospect of the sea, the rocky shore, the lava and the verdant
upland. . . . On this land we saw some noble upland kalo, and a number of very
large banana trees. Several crystal springs take their rise on the summit, and might send, if rightly directed, a portion of their treasures through every man’s fields.
Behind this noble series of hills, timber abounds. So that there is to be found every
thing desirable to make a rich farming country, and in a circuit of some fifteen
miles, might be abundantly grown the best products of the temperate, with the rich
and varied fruits of the tropic zones. But alas the farmers are wanting, the land lies in all the wild luxuriance of nature desolate, there are no passable roads, except foot
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paths, to it, and no harbor at which vessels could lie in safety, is found within many miles. [Sailor in Kelly 1980:89]
Noticeably missing from this account is mention of any Hawaiians occupying and utilizing this
verdant land “now lying utterly waste.” An 1831-1832 census of Ka‘ū, the first taken within the
district, records a total population of 5,800. In 1835 the total population is counted as 4,766. The
first official government census, taken in 1847, records the population as having dropped to 3,010. Reverend John Paris would write in an 1848 mission station report (Paris 1848:3), “Since the year
1845 the work of depopulation of Kau has gone on with fearful rapidity.” He notes, during the
years 1845 and 1846 (Paris 1848:3), a “distressing famine and fire which overran the country,” the
same disasters the anonymous visitor of 1849 mentioned. By the time of the 1853 government
census only 2,210 people are recorded in Ka‘ū.
3.1.3 The Māhele and the Kuleana Act
In the mid-nineteenth century, during the time of Kamehameha III, a series of legal and
legislative changes were brought about in the name of land reform (see the works of Jon Chinen
1958, 1971 for a thorough and well-written explanation). Previous to the Māhele, all land belonged to the akua (gods), held in trust for them by the paramount chief, and managed by subordinate chiefs.
Following the enactment of a series of new laws from the mid-1840s to mid-1850s,
Kamehameha III divided the land into four categories: Crown Lands reserved for himself and the
royal house; Government Lands for the government; Konohiki Lands claimed by ali‘i and their konohiki (supervisors); and kuleana, small plots claimed by the maka‘āinana (commoners) (Chinen 1958:8–15). These claims are described in Land Commission Award (LCA) testimony
from the claimant and witnesses. A Royal Patent (RP), which quit-claimed the government’s
interest in the land, was issued on most Land Commission Awards (LCA) (Chinen 1958:14). In
some cases, more than one RP number was issued for an LCA, especially in cases where there
were several widely separated ‘āpana (lots), such as an award with agricultural land in one ahupua‘a and a house lot in another.
Ali‘i were required to pay a commutation fee to the government for their confirmed Konohiki
Land titles; this payment could be in cash or in the return of land to the government or crown. Many ali‘i elected to return substantial portions of their awarded lands to avoid the one-third
commutation cash fee. The Kuleana Act of 1850 allowed maka‘āinana, in principle, to own land parcels where they were currently and actively cultivating and/or residing. In 1851, certain
Government Lands became available for purchase in lots of 1 to 50 acres in fee simple; this new
category of land ownership became known as Royal Patent Grants or Land Grants. Unfortunately,
Land Grant records tend to offer far less insight into specific land use than LCA records.
According to Soehren (2010), Hionamoa, Pālima, and Pāʻauʻau were not named in the Māhele Book. However, a 1914 map (Figure 8) shows 1,950 acres in Hionamoa awarded to the aliʻi
William Pitt Leleiohoku as LCA 9971:12.
Waihona ‘Aina (2000) indicates Moses Keawe claimed five ʻapana in the vicinity of the project area as part of LCA 7312. Two of the five lots were awarded. LCA 7312:1 comprised 1.5 acres located in Pāʻauʻau 2, approximately 750 m north of the project area along the “Kau-Volcano Road” (present Kaʻalaʻiki Road). LCA 7312:2 comprised 11.7 acres in Hionamoa, located
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Figure 8. Portion of R.F. Pierce’s 1914 map of Kalaala and Moaula-Kopu-Makaka Makai Government Tracts, showing the project area in relation to roads, trails, and the plantation railroad
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approximately 350 m northwest of the project area along the “Kau-Volcano Road”/Kaʻalaʻiki Road. Both of the awarded ʻapana were house lots. The three ʻapana not awarded comprised taro
fields.
LCA 10248 to Mahi was also awarded in Pāʻauʻau 2. This award comprised 13 acres straddling the “Kau-Volcano Road”/Kaʻalaʻiki Road adjacent to LCA 7312:1, approximately 750 m north of
the project area. Unfortunately, the testimony for this award does not provide information about land use. No kuleana are indicated within Pāʻauʻau 1 or Pālima.
Waihona ʻAina (2000) lists four land grants in Pālima-Pāʻauʻau: Land Grant 01370 to Nahala,
02446 to Kamalo (overlapped by the project area), 02655 to Nahala, and 02727 to F.S. Lyman. In
addition to these, Pāʻauʻau also contained Land Grant 03533 made to the trustees of the Bernice
Pauahi Bishop Estate; this grant is also overlapped by the project area. Soehren (2010) notes that Grant 03533, which also included lands at Kaunakakai on Molokaʻi and Honolulu and
Kaʻakaukukaui on Oʻahu, was made “in exchange for quitclaim deed to certain lands in Hilo.”
Grants 01370 and 02655 are located mauka (inland) of the “Kau-Volcano Road”/Kaʻalaʻiki Road.
Grants 02446, 02727, and 03533 are depicted on the 1914 map (see Figure 8) in relation to the
project area. Figure 8 also indicates a fifth grant in upland Pālima: Land Grant 01374 to Keawe. This grant, comprising two separate ʻapana, is listed on Waihona ʻAina (2000) as being located in
Kopu-Moaula a short distance east of Pālima. Figure 8 indicates the portion of Land Grant 01374
north of the project area is ‘Apana 2. No Land Grants are indicated within Hionamoa.
3.1.4 Mid- to Late 1800s
By the middle of the nineteenth century, imported livestock roaming freely throughout pasturelands of Ka‘ū were creating new aggravations. Ka‘alu‘alu had become a focus of activity
as the export of agriculture and livestock began to dominate the Ka‘ū economy; at the same time,
about 1852, an improved, 7-mile-long cart road was constructed between the bay and Wai‘ōhinu.
In the 1850s, Rev. Henry Kinney (cited in Kelly 1980) commented on the “hundreds of goats salted
and dried” as well as “upland taro, potatoes and onions” which previously had to be hauled “on the backs of men” overland to Hilo and which could now be taken to the harbor and shipped.
Ranching activity in Ka‘ū commenced sometime after the middle of the century when Princess
Ruth Ke‘elikolani started Ka‘alu‘alu Ranch with cattle brought from Waimea. Cattle continued to
be shipped out of Ka‘alu‘alu at least until the 1920s. Organized cattle ranching was focused at Ka‘alu‘alu, Kahuku, and Kapāpala (located northeast of present Pāhala Town).
While cattle and other livestock were significant elements of the new western economic focus
imposed upon Ka‘ū during the nineteenth century, it was agriculture that had the most extensive
impact on the land and people. Among new agricultural pursuits attempted in Ka‘ū was wheat growing:
But it proved difficult to co-ordinate the size of the wheat crop with the requirements of the flour mills; difficult also to coordinate the output of the mills
with the demands of the market, domestic and foreign. The business did not become
a permanent one. [Kuykendall 1966:150]
Contributing to the failure of wheat production was the harvesting of pulu, a soft, flossy, yellow wool on the base of tree-fern leaf stalks (Cibotium spp.) used for stuffing mattresses and pillows. During the 1860s pulu constituted the major export crop from Ka‘ū. A mission station report
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written in 1860 by W.C. Shipman relates the ruinous effect upon the native population of participation in the pulu trade:
The effect—on them is not good; not that the pulu is not a source from which they
might secure comfort to themselves and families, but the actual result is the reverse.
They are offered goods to almost any amount, to be paid for in pulu; this to a native
is a strong temptation to go into debt. Consequently many of them are deeply in debt and almost all to some extent. The policy of the traders is to get them in debt
and to keep them there so long as possible . . . [T]hey are almost entirely under the
control of their creditors, and are compelled to live in the pulu regions, at the peril
of losing their houses and lots, and whatever other property they may possess. Thus their homes are almost in reality deserted, ground uncultivated. [Shipman 1860:4]
Life in Ka‘ū during the 1860s was further disrupted and devastated by the forces of nature. A
sequence of major earthquakes and eruptions of Mauna Loa beginning in March 1868 resulted in
many deaths and losses of property and livestock. Then an earthquake in early April precipitated a tidal wave that destroyed coastal villages, dislodged a cliff side at Kapāpala blanketing the land
below and burying a village, and opened the Great Crack at Kīlauea (located approximately 2.5 miles east of Pāhala), emptying the crater’s lava lake into Punalu‘u and Keauhou. A subsequent
lava flow, this time in western Ka‘ū, buried all of Wai‘ahukini Valley west of the great pali.
Apparently great natural disasters could not hinder the pace of foreign business interests in
Ka‘ū. In 1868, the same year as the great earthquake, Alexander Hutchinson established the
Naalehu Sugar Company and built a mill at Nā‘ālehu just east of Wai‘ōhinu. More enduring commercially than either wheat or pulu, sugar cultivation beaome the major industry within Ka‘ū,
appropriating the focus of life in the district.
During the mid-1870s Waiohinu Plantation was established by John Nott and Company. This
operation was bought out in 1877 by Alexander Hutchinson who at the same time founded Hilea
Plantation. By the end of the 1870s, sugar mills were operating at Nā‘ālehu, Hīlea, and Honu‘apo. Though Hutchinson died in 1879, his name survived in the Hutchinson Sugar Company which
during the remainder of the nineteenth century continued to expand and consolidate existing
plantation operations in Ka‘ū.
Another plantation operation, the Hawaiian Agricultural Company, was established in Pāhala
in 1876 by a consortium of Honolulu businessmen. An 1877 map of the Hawaiian Agricultural Company sugarcane lands (Figure 9) shows the Pāhala Mill located just east of the project area,
overlapping lands indicated as already planted in cane, as well as unplanted areas labeled as “Good,
Stony land.” No roads or trails are indicated. An 1886 map (Figure 10) also depicts the location of
the mill at the “Pahala Plantation,” as well as the Hutchinson Sugar Company mills at Hīlea,
Honuʻapo, and Nāʻāleahu to the southwest and the associated wharves at Honu‘apo and Punalu‘u. Dorrance and Morgan (2000:110) note that Pāhala’s “steam driven mill was the most modern and
largest in the islands.” Figure 10 curiously depicts the project area overlapping land divisions
called “Nakumu” and “Makaka;” no information about these places names was found. Figure 10
also illustrates three travel routes extending though the Pāhala vicinity: two routes extend from
Nāʻālehu northeast, one along the coast and one mauka, joining and continuing northeast above Pāhala Mill. Another route is shown extending northeast from Nīnole/Punaluʻu through Pāhala,
parallel and makai of the Nāʻālehu route.
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Figure 9. F.S. Lyman 1877 map of Hawaiian Agricultural Company sugarcane lands, showing the project area in relation to the Pāhala Mill and developed cane lots
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Figure 10. Portion of W.A. Wall’s 1886 map of Hawai‘i Island, showing the project area in
relation to sugar mills and harbors in windward Kaʻū
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By the end of the nineteenth century the Hawaiian Agricultural Company controlled almost 10,000 acres of cane land and constituted the largest plantation in the Hawaiian Islands. The
extensive agricultural endeavors taking place in Ka‘ū at this time were also altering the social
landscape. During the 1870s, Chinese laborers were brought in by Alexander Hutchinson. By the time of the 1884 government census there were 568 Chinese in the district. Japanese laborers were
imported beginning in the latter 1880s and Filipinos began arriving during the first decade of the twentieth century. Ethnic workers’ camps surrounded the mill at Pāhala. As the town around the
mill developed, a school was established at Pāhala in 1881 to serve the children of the plantation
workers.
3.1.5 1900s
Life in the early twentieth century continued to center around the activities of the two sugar operations, Hutchinson Sugar Plantation and the Hawaiian Agricultural Company. Pāhala
continued to develop as a town. A 1906 map (Figure 11) depicts the location of a school
approximately 0.5 miles north of the current Kaʻū High and Pāhala Elementary School (KHPES)
campus location, and a post office in the vicinity of the project area. Figure 11 also illustrates the
approximated boundaries of sugar plantation lands (in red) in relation to the forest lands mauka (in blue) and grazing lands east associated with Kapapala Ranch. The continued development of
roadways in the vicinity of Pāhala Town is also depicted, with the addition of mauka-makai
andlateral routes between the mills at Honuʻapo and Pāhala (see Figure 11). The portions of these
roadways in closest proximity to Pāhala are shown in more detail on the 1914 map (see Figure 8);
the uppermost road shown is labeled “Kau-Volcano Road.” The lower roadway extending through Pāhala plantation is not named.
The 1914 map (see Figure 8) includes some additional details about the Pāhala vicinity. A trail
is depicted with a dashed line, crossing the northern portion of the current project area and
continuing off the map to the east and west. It is unlikely that any portion of this trail remains within the town vicinity, which has been completely altered by agricultural and residential development. Furthermore, a meandering “Plantation Railroad” is shown, extending southwest
roughly parallel to the 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 mills; this was the main method of transporting cane at the time.
Railway development continued, with the establishment of lines running from Nā‘ālehu and
Hīlea to Honu‘apo and from Punalu‘u to Pāhala. A 1929 map of Hawaiian Agricultural Co. cane fields (Figure 12) depicts the route of the rail line extending from the mill across through the
narrow central portion of the project area and to the west; also shown are the major roadways of the time merging along the present Maile Street corridor. The 1930 USGS topographic map (Figure
13) shows the Pāhala area in better detail, including the narrow-gauge rail line running to Pāhala
parallel the coastal road from Punaluʻu. The expansion of the town is evident on this map, 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 through Pāhala Town, labeled
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Background Research
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
26
Figure 11. Portion of J.M. Donn’s 1906 map of Hawai‘i Island, showing the project area in
relation to Pāhala Mill, school, post office, and areas of different land use
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Background Research
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
27
Figure 12. 1929 map of Hawaiian Agricultural Co. cane fields, showing the location of the project area
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Background Research
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
28
Figure 13. Portion of the 1930 Palima Point USGS 7.5-minute topographic quadrangle showing
the project area in relation to the mill, school, church, roads, and railroad in the Pāhala vicinity
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Background Research
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
29
“Volcano Road,” utilizes a new eastward extension, with the portion of the older alignment that extended north from the town is now labeled “Wood Valley Road.”
The flumes and railroads in Ka‘ū were abandoned by the 1940s with the advent of trucking. In
the 1940s the Belt Road or Māmalahoa Highway (Route 11) was constructed through Kaʻū, running just makai of Pāhala Town. A 1967 USGS map (Figure 14) shows this new route and the
continued development of the town. By this time the school had moved 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 not as major roadways, with the exception of a Route 15 looping
off the Belt Road along present Maile Street and Kamani Street. During this latter half of the twentieth century the residential side-streets within Pāhala were also improved with paving and installation of the culvert at the Huapala and Ilima Streets intersection.
The 1940s Belt Road alignment appears on an undated Olson Trust map (Figure 15) reprinted
in Cleghorn (2016:13). Hand drawn annotations indicate some land uses in the area dating to the
1960s and 1970s. This map indicates the WWTP site and adjacent areas were under pasture; the
easement extending to Maile Street also crosses through a rectangular area labeled “Cane Area
Planted Aug. 1966” and a fence line “Plotted Oct. 1961.” Also significant are the locations of a “Cesspool” (LCC 1), and a concrete flume and lava tube located east of the proposed WWTP site.
This map appears to depict a portion of the former narrow-gauge railroad following a “1.8 %”
grade west of the easement extending south from Maile Street; this 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.
A 1977 aerial photo (Figure 16) indicates further expansion of the town to the east amidst large
agricultural plots. Note that the proposed WWTP plant site portion of the project area is not cultivated in sugarcane at this time; instead, these former cane fields were being readied for
planting of the macadamia orchard that is now fully matured.
The Hawaii Agricultural Company operated until 1972 when it merged with the Hutchinson
Sugar Company to form the Kau Sugar Company, which was renamed as the Kau Agribusiness
Company in 1986 (Dorrance and Morgan 2000:112). Following the demise of the sugar industry
in other parts of the island, Kau Agribusiness Company ceased its sugar operations in 1996
(Dorrance and Morgan 2000:112).
3.1.6 Contemporary Land Use
Pāhala continues to serve a small rural population supported by predominately agricultural and
livestock economies. The town is also used as a stop-over for tourists visiting Punaluʻu Beach located 5 miles southwest and/or travelling between Hilo and Kailua-Kona.
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Background Research
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
30
Figure 14. Portion of the 1967 Pahala USGS 7.5-minute topographic quadrangle showing the
project area and development within Pāhala Town
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Background Research
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
31
Figure 15. Portion of an undated field map of the Pahala Mill and Camp reprinted in Cleghorn
(2016:13) showing the project area in relation to plantation features
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Background Research
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
32
Figure 16. Portion of the 1977 USGS orthophotoquad aerial photo, Pahala Quadrangle, showing
the project area and continued development of Pāhala Town
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Background Research
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
33
Previous Archaeological Research
3.2.1 Previous Archaeological Studies
Eight previous archaeological studies have been conducted in the vicinity of the current project
area in Pāhala. These previous archaeological studies are presented in Table 1 and shown in Figure 17.
In 1981, Hamilton Ahlo undertook an archaeological reconnaissance for the U.S. Army Corps
of Engineers Pāʻauʻau Stream Flood Control project, located east of the current project area along
the Pāʻauʻau 2 and ʻIliokoloa Ahupuaʻa boundary (Ahlo 1981; see Figure 17). The study examined
an approximately 4,000-ft (1.2-km) section of Pāʻauʻau Stream just mauka of the Hawaiʻi Belt Road (Route 11) and the adjacent embankments. Extensive prior disturbance was noted along both
sides of the stream; no archaeological features were documented, and no further work was
recommended.
In 2001, Haun and Associates conducted an archaeological assessment (no finds AIS) for an
emergency replacement of the Pāʻauʻau Bridge, situated east of the current project area along the Hawaiʻi Belt Road in Pāʻauʻau 2 and ʻIliokoloa (Haun 2001; see Figure 17). The 5.256-acre project
area included the bridge over Pāʻauʻau Gulch, the approaches 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.
In 2004, Haun and Associates conducted an AIS on 255.7 acres in Palima and Pāʻauʻau Ahupuaʻa,
northwest of the current project area (Haun and Henry 2004; see Figure 17). The study confirmed
extensive 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 # -24119, a 105-m-long section of a historic irrigation flume associated with the former sugar plantation (Figure 18). No traditional sites were identified, and no further work was recommended.
In 2006, T. S. Dye & Colleagues, Archaeologists, Inc. conducted an archaeological assessment
of a proposed cellular site within a 1,600-sq-ft portion of TMK: [3] 9-6-005:018, northwest of the
current project area in Pālima and Pā‘au‘au 1 Ahupuaʻa (Jourdane and Dye 2006; see Figure 17). Prior disturbance associated with commercial agriculture were noted. No archaeological features were observed.
As part of a state-wide Department of Education (DOE) wastewater systems improvement
project, CSH undertook a literature review and field inspection (LRFI) for two Kaʻū District schools, including KHPES located between the northern portions of the project area (Hammatt and Shideler 2006; see Figure 17). The LFRI included background research for the Pāhala area including LCA data and previous archaeological studies in the vicinity and noted that the school
is listed on the HRHP under the thematic group “Public Schools on the Island of Hawaiʻi” (SIHP
# -07522; see Figure 18). Hammatt and Shideler (2006:27) recommended on-site archaeological
monitoring for the project.
In 2009 CSH monitored the DOE wastewater systems improvements project at KHPES (Wilkinson et al. 2010; see Figure 17). The project involved the installation of a new leach field,
eight septic tanks, and associated sewer lines. While no subsurface cultural deposits were located
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Background Research
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
34
Table 1. Previous archaeological studies in the vicinity of the project area
Reference Type of Study Location Results (SIHP # 50-10-69****)
Ahlo 1981 Archaeological reconnaissance Pāʻauʻau Stream between
Māmalahoa Hwy (Route 11) and Wood Valley Rd, Pāʻauʻau 2 and ʻIliokoloa
Ahupuaʻa; TMK not listed
No historic properties or cultural materials identified
Haun 2001 Archaeological
inventory survey (recorded as an archaeological assessment)
Pāʻauʻau Bridge, Pāʻauʻau 2
and ʻIliokoloa Ahupuaʻa,
portions TMKs: [3] 9-6-
002:047, 9-6-012:012, 9-6-013:005, 9-6-023:043
No historic properties or cultural
materials identified
Haun and Henry 2004 Archaeological inventory survey Pālima and Pāʻauʻau 1 Ahupuaʻa, TMKs: [3] 9-6-005:017, 018 and 9-6-
006:004
One historic property documented: SIHP # -24119, historic irrigation flume
associated with sugarcane cultivation
Dye and Jourdane 2006
Archaeological inventory survey (recorded as an archaeological assessment)
Pālima and Pāʻauʻau 1
Ahupuaʻa, TMK: [3] 9–6–
005:018 por.
No historic properties or cultural materials identified
Hammatt and
Shideler 2006
Literature review
and field
inspection
Two DOE schools in Kaʻū
District, TMKs: [3] 9-6-
005:008, 039; 9-5-009:006,
015
Noted listing of KHPES on the
HRHP; on-site archaeological
monitoring recommended
Wilkinson et
al. 2010 Archaeological monitoring Ka‘ū High and Pāhala Elementary School,
Pāʻauʻau Ahupuaʻa, TMKs: [3] 9-6-005:008, 039
Noted listing of KHPES on the HRHP; one other historic
property documented: SIHP # -27570, lava tube
Escott 2013 Archaeological inventory survey Ka‘ū High and Pāhala Elementary School, TMK: [3] 9-6-005:008 por.
Explored and mapped previously recorded SIHP # -27570 (lava tube system),
documenting three new features; documented one new historic
property, a historic-era burial (SIHP # -29501) within the SIHP # -27570 lava tube
Cleghorn
2016
Archaeological
field inspection
Pa‘au‘au 1 Ahupuaʻa, TMK:
[3] 9-6-002:018
Documented scattered surface
artifacts and a lava tube within
former plantation land; AIS recommended
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Background Research
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
35
Figure 17. Portion of the 1995 Pahala USGS 7.5-minute topographic quadrangles showing
previous archaeological studies in the vicinity of the project area
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Background Research
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
36
Figure 18. Portion of the 1995 Pahala USGS 7.5-minute topographic quadrangles showing
locations of sites documented in previous archaeological studies in the vicinity of the
project area
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Background Research
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
37
during excavation, a lava tube system was breached and assigned a site number (SIHP # 50-10-69-27570) despite an absence of cultural modifications to the breached portion of the tube system.
The location of SIHP # -27570 is shown on Figure 18.
In 2012, Scientific Consultant Services, Inc., conducted an AIS for a proposed gymnasium and
disaster relief shelter within a 4.5-acre portion of the KHPES campus, adjacent to but outside the
northeastern portion of the current project area (Escott 2013; see Figure 17). The SIHP # -27570 lava tube system was also explored and mapped. A burial site was found within the tube and
designated SIHP # 50-10-69-29501 (see Figure 18). This burial is located away from the limits of
the current project area. Escott (2013) describes the lava tube system as follows:
The lava tube system containing Site 27570 and Site 29501 has three main branches
converging near the tube system opening under a modern storm drain grate [Figure 19]. The southern branch does not contain archaeological sites. Sites 27570 and
29501 are located 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 collapse at its western terminus. Site 29501 is located in the northern tube of the
western branch, roughly 35.0 meters in from the storm grate opening [Figure 20].
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 approximately 3.0
meters below the floor of the western branch tube . . . [Escott 2013:17]
No other archaeological features were located within the 4.5-acre project area. Escott (2013:36)
noted SIHP # -29501 would “be preserved in accordance with a Hawaiʻi Island Burial Council-
approved Burial Treatment Plan,” and recommended archaeological monitoring of any future
ground disturbing work “near the northern and western branches of the tube system.”
In 2016 Pacific Legacy, conducted archaeological field inspection of TMK: [3] 9-6-002:018, addressing an earlier and larger version of the WWTP project (Cleghorn 2016; see Figure 17).
Extensive disturbance associated with 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 18). These artifacts included a single traditional hammerstone and fragmental historic glass and ceramics. The report also discussed a lava tube known to exist between the vicinity of the present Royal Hawaiian Orchards processing plant and
KHPES; an opening to the tube on the processing plant property was filled in sometime in the past
to prevent access. Pacific Legacy recommended discussion with SHPD regarding project historic
preservation requirements, noting that an AIS would likely be required. It was also recommended
that the vicinity of the lava tube entrance known to exist near the processing plant be excluded from the project area (Cleghorn 2016:7).
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Background Research
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
38
Figure 19. Aerial photo showing the Escott (2013) project area and site locations (Escott 2013:18)
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Background Research
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
39
Figure 20. Survey map of SIHP # -29501 burial and SIHP # -27570 lava tube ceiling thicknesses (Escott 2013:19); note the tube is set back from Kamani Street and Puahala Street
where a portion of the current project area is located
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Background Research
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
40
National Register-Eligible Historic Properties in the Vicinity
Two historic properties near the project APE have been evaluated as eligible for listing on the
National Register: Kaʻū High and Pāhala Elementary School and the Māmalahoa Highway.
Neither of these sites are within the project APE.
3.3.1 Kaʻū High and Pāhala Elementary School
Kaʻū High and Pāhala Elementary School, located north of and between portions of the project
APE (see Figure 18), is part of the thematic grouping “Public Schools on the Island of Hawaiʻi” (SIHP # 50-10-69-07522). SIHP # -07522 is listed on the Hawaiʻi Register. The school was
nominated to the National Register in May 2002 under the name “Kaʻu High and Pahala Elementary School.” The nomination form lists the period of significance as 1935-1950 and areas
of significance as Criteria A (education/social history value) and C (architecture value). This
historic property has not been listed on the National Register.
3.3.2 Māmalahoa Highway
SIHP # 50-10-47-30187 comprises the former and present alignments of the Māmalahoa Highway (Highway 11/Hawaiʻi Belt Road); an actively used and contemporary portion of this
roadway is located adjacent to the southern boundary of the proposed WWTP site (see Figure 18).
Under a prior study (Clark et al. 2014:81) this historic property was evaluated as eligible for inclusion on the National Register under Criteria A and D for its importance in and information about “late nineteenth and early twentieth events in establishing a regional transportation network that has its roots in antiquity.” The portion of the roadway adjacent to the project area was
constructed in the 1940s. This historic property has not been nominated for listing on the Hawaiʻi
Register or National Register.
Background Summary and Predictive Model
Kaʻū is a large district known for its dynamic natural environment and fierce people. Despite
the impressions of early visitors that the district was a barren wasteland, its abundant and varied
resources supported a substantial population. However, in pre-Contract times Pāhala was not a habitation center. Villages were located at the coast or in places like Waiʻōhinu to the southwest where water and other resources were more abundant.
In the first 50 years after Contact, the population of Kaʻū declined dramatically due to
introduced disease, natural disasters, and outmigration to developing economic centers. Missions
were established in Waiʻōhinu and Punaluʻu. In the Māhele, a handful of kuleana claims in the Pāhala vicinity indicate land use associated with residence and small-scale farming. The vast majority of Hionamoa Ahupuaʻa was awarded as LCA 9971:12 to the aliʻi William Pitt
Leleiohoku; this award overlaps the proposed WWTP site. A number of Land Grants were also
made in the Pāhala vicinity, including Land Grant 02446 to Kamalo overlapping the northern
portion of the project area.
The historic era in Kaʻū was dominated by the development of the livestock and commercial agriculture industries. Several large ranching outfits were established in Kaʻū in the mid-1800s,
including Kapāpala Ranch located a relatively short distance east of present Pāhala Town.
However, it was sugar plantations that produced the most widespread and lasting impact on the
physical and social landscape of Kaʻū. The Hawaiian Agricultural Company was established in
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Background Research
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
41
the Pāhala vicinity in 1876 and quickly grew. A mill was established and the village of Pāhala began to develop with the influx of plantation workers and their families. The majority of the
project area was under cane at some point in time.
Previous archaeological research in the vicinity has documented very little evidence of pre-Contact land use, partially due to widespread land alteration for the sugar plantation. Historic
plantation remnants such as cane flumes have been documented in the area. Lava tubes are also known to be present in and around Pāhala. A lava tube system (SIHP # -27570) has been
documented to the north and east of the project area; the lava tube contains a historic to modern
refuse dump and a historic burial site (SIHP # -29501) located on the KHPES campus. The school
itself is on the HRHP as part of a thematic group of historic Hawaiʻi Island schools (SIHP # -07522). The Māmalahoa Highway (SIHP # 50-10-47-30187) located just south of the project area has been evaluated as eligible for inclusion on the NRHP but has not been nominated. The current
project area does not encroach on any previously documented portions of the lava tube system, the
school campus, or the Māmalahoa Highway.
Given the known traditional land use in this area and the impacts of continued agricultural and
residential development, surface pre-Contact sites are not expected within the project area. The modern development of the macadamia nut orchard has likely also obliterated any plantation-era
sites once present in that portion of the project area; surface features associated with the former
plantation village and/or historic transportation routes may be present in other portions of the
project area. Subsurface historic features related to sugar cultivation could be present throughout the project area. Furthermore, additional lava tubes may be present and have the potential to contain pre- and/or post-Contact archaeological features, including human burials.
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
42
Section 4 Results of Fieldwork
CSH completed the fieldwork component of this archaeological inventory survey under
archaeological fieldwork permit number 17-08, issued by the SHPD pursuant to HAR §13-282.
Fieldwork was conducted on 18 September 2018, 1–4 October 2018, and 10 January 2019. This work required approximately 8 person-days to complete.
The fieldwork comprised a 100% pedestrian inspection of the project area and a program of
subsurface testing. The results of the pedestrian inspection are provided in Section 4.1 and the subsurface testing results are provided in Section 4.2.
Two historic properties characterized as historic-era transportation routes (SIHP #s 50-10-69-31088 and -31089) were documented within the project area (Figure 21; see Section 5 for full site
descriptions). No pre-Contact features or lava tubes were encountered within the project area.
Pedestrian Inspection Results
A 100% pedestrian inspection was undertaken with the field crew spaced 3-5 m apart depending
upon the density of the vegetation. Ground visibility was very good throughout most of the
inspection area.
The pedestrian inspection began along the easement located within TMK: [3] 9-6-005:036. This
area has been completely disturbed by prior development. From Maile Street, the easement extends northwest along an existing paved driveway to an open, asphalted area located along the southern
side of the private roadway used to access Kaʻalaʻiki Road (Figure 22). This asphalt area is
surrounded by previously graded land presently overgrown with California grass. The easement crosses the roadway, entering the former sugar plantation maintenance yard. The easement extends along a dirt driveway between two large, old maintenance buildings that are still in use (Figure 23). These buildings are located outside the easement and project area. North of these structures is
a graded, grassy parking area; the easement crosses this parking area and through a previously
disturbed, heavily vegetated area containing scrap metal and miscellaneous trash located along the
makai side of Ilima Street (Figure 24). An earthen storm water drainage channel extends along the makai side of Ilima Street southwest from a culvert at Huapala Street and contains scattered modern household trash (Figure 25).
Upon exiting the proposed easement within TMK: [3] 9-6-005:036, the survey continued along
various residential streets within the project area, including Pikake Street, Kamani Street, Puahala
Street, Huapala Street, Hala Street, Hinano Street, and Ilima Street (Figure 26 through Figure 29). These streets consist of one-to-two-lane asphalt travel ways with no curbing or sidewalks. These streets employ variable use of standard signage and center and outer lane striping. A four-way
crosswalk is located at the Pikake Street and Kamani Street intersection near the KHPES campus
(Figure 30). Kamani Street dead ends at the school and the project area does not cross onto the
campus. The homes lining these residential streets outside the project area are of variable age but are commonly of post-and-pier “plantation style” design with corrugated metal roofing. Slight linear depressions are typically present along one side of each street within the asphalt or grassy
shoulder, providing drainage for runoff; these drainages are also outside the asphalt travel ways
comprising the project area. A single culvert constructed in the 1960s was observed running under
the modern Huapala Street surface adjacent to the Ilima Street intersection (Figure 31); this culvert
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
43
Figure 21. Aerial photo of the project area (Google Earth 2013) showing the locations of newly
documented historic properties
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
44
Figure 22. Photo showing the portion of the easement in TMK: [3] 9-6-005:036 that extends from Maile Street along an existing asphalt driveway; view northwest
Figure 23. Photo showing the portion of the easement in TMK: [3] 9-6-005:036 that passes
through the old plantation maintenance yard; the structures present to either side are outside the project area; view to northwest
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
45
Figure 24. Photo showing the forested area between the maintenance yard and Ilima Street at the northern end of the easement in TMK: [3] 9-6-005:036; view to northwest
Figure 25. Photo showing the location where the easement in TMK: [3] 9-6-005:036 exits at Ilima Street (frame right); the earthen drainage channel extending from the Huapala Street culvert is beneath the grass to the left of the road; view to southwest
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
46
Figure 26. Photo looking down Huapala Street; note linear drainage in grassy lawn on left side of photo; view to southeast
Figure 27. Photo looking up Ilima Street; note drainage in grassy shoulder on right side of photo;
view to northwest
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
47
Figure 28. Photo looking up Hinano Street from the eastern Huapala Street intersection; view to northwest
Figure 29. Photo looking up Hala Street from the Hinano Street intersection; view to north
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
48
Figure 30. Photo of the intersection of Pikake and Puahala streets; view to northwest
Figure 31. Photo of the culvert located at the Huapala Street and Ilima Street intersection; view
to northeast
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
49
diverts runoff into the channel located along the makai side of Ilima Street (see Figure 25).
Pikake Street is an arterial route in Pāhala lined with commercial establishments in addition to
residences. Research has indicated this present roadway is a portion of a historic road alignment
(SIHP # -31088, Wood Valley Road/Coastal Road; see Figure 21 and Section 5.1). A commercial
center at the Pikake Street and Kamani Street intersection includes a bank, drugstore, post office,
and the Mizuno Superette (Figure 32). The southern portion of Pikake Street approaching its terminus at Maile Street is technically a private roadway located within TMK: [3] 9-6-005:044.
Pikake Street at the Maile Street intersection includes turn lanes (Figure 33). A broad asphalt
parking area is located along the northeastern side of the intersection, fronting the offices of Olson Trust. On the western side of this intersection are the offices of Kau Agribusiness Company,
comprising two plantation-era buildings (see Figure 33). Within the grassy yard fronting these buildings is an old Corliss steam engine once used by the sugar mill. These structures and the
engine are located outside the project area.
The inspection proceeded southwest down Maile Street from the Pikake Street intersection. The
project area includes an approximately 0.25-mile portion of Maile Street located between the old
mill camp road and the Lower Moaula Road intersection (Figure 34 and Figure 35). Research has indicated this present roadway is a portion of a historic road alignment (SIHP # -31089, Volcano
Road; see Figure 21 and Section 5.2). Along the makai side of Maile Street in this area are an old
plantation house (which has been subsequently used as a store) and visible remnants of the mill and theater; all these features are located outside the project area. Along the mauka side of Maile Street in this area are a Hawaiian Telcom building (see Figure 34), a few old plantation homes serving as residences, and the asphalt parking area noted previously, as well as a section of concrete
sidewalk. Both sides of Maile Street exhibit extensive prior disturbance. No remnants of the old
plantation railroad were observed.
From the vicinity of the Maile Street/Lower Moaula Road intersection, the inspection continued
southeast along the proposed utility easement within TMK: [3] 9-6-002:018. Closest to Maile Street the easement briefly crosses a previously graded area overgrown in California grass and
other weeds, before entering the macadamia orchard. This easement extends through the orchard
to the proposed WWTP plant site. The orchard contains linear rows of mature trees watered via surface irrigation lines (Figure 36). Fallen macadamia nuts, leaf litter, and relatively few small stones are present on the ground surface. Signs of surface water runoff were observed throughout the orchard. An asphalt road accessing the processing plant from Maile Street forms the mauka
border of the proposed plant site (Figure 37). Bulldozer push piles were observed along the Belt
Road edge and down the center of the orchard (Figure 38 and Figure 39), and bulldozer blade scars
are frequently visible on small exposures of lava bedrock throughout the orchard. During the
survey fieldwork CSH crew observed operation of a machine in an adjacent orchard used to harvest macadamia nuts off the ground; this machine was observed to scatter small rocks and other natural
materials around.
A few scattered pieces of highly fragmental glass and ceramics were observed in the vicinity
of the proposed Test Excavation (TE) 2 location in the northern-central portion of the proposed site; testing at this location did not uncover any subsurface cultural materials (see Section 4.2.2). The nature and density of the fragmental cultural materials observed on the surface within the
macadamia orchard were not sufficient to comprise a significant cultural deposit. These materials
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
50
Figure 32. Photo looking up Pikake toward the Kamani Street intersection; commercial center is visible to the right; view to north
Figure 33. Photo showing the Pikake Street terminus at Maile Street; Hawaiian Telcom building
is on opposite corner; view to southwest
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
51
Figure 34. Photo of a portion of Maile Street within the project area, showing the Pikake Street intersection in the background and the HELCO building (left frame); view to northeast
Figure 35. Photo of a portion of Maile Street in the project area, showing the Lower Moaula
Road fork in the far background; view to southwest
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
52
Figure 36. Representative photo of the macadamia orchard; note the surface irrigation lines between the trees; view to southwest
Figure 37. Photo of the paved road that passes through the macadamia orchard between Maile
Street and the macadamia nut husking plant; this road forms the mauka boundary of
the proposed WWTP site portion of the project area; view to northeast
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
53
Figure 38. Photo showing the margin of the macadamia orchard at the southeastern corner of the
proposed WWTP site portion of the project area; a dozer push pile is present beneath
the grass along the left side of the photo; view to southwest
Figure 39. Photo showing a portion of the linear push pile/berm located along the wind break
bisecting the macadamia orchard; view to southwest
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
54
were similar in nature to those scattered historic artifacts encountered by Cleghorn (2016) in the portion of the orchard north of the current project area. No traditional artifacts like the
hammerstone recorded by Cleghorn (2016) were encountered within the current project area.
The last portion of the project area to be inspected was the location of existing LCC 1 and associated sewer easement in TMK: [3] 9-6-002:016. The sewer line easement was recently cleared from an area just below Maile Street; the areas surrounding the cleared easement are fallow with overhead California grass. Ground visibility was excellent along the maintained easement,
allowing for relocation of a sewer manhole (Figure 40) and cleanout along the existing sewer line.
The LCC 1 location at the makai end of the maintained easement is not marked on the ground surface; a low dirt mound is believed to indicate its location (Figure 41). No remnants of the old
plantation railroad were observed.
Subsurface Testing Results
Subsurface testing was conducted within the proposed WWTP site portion of the project area, to determine the nature of the sediments and the potential for subsurface archaeological features including but not limited to buried cultural deposits and/or culturally modified lava tubes. This
area is a mature macadamia nut orchard. The subsurface testing program involved mechanical
excavation of seven test trenches measuring approximately 5 m (16.5 ft) long and 1 m (3.2 ft)
wide, with an average depth of 1.6 m (5.2 ft). All seven test excavations terminated at bedrock.
The locations of the excavation trenches are depicted on Figure 42 and Figure 43. An archaeologist was present to monitor the excavations and document the exposed stratigraphy, which was
recorded upon completion of each trench. No subsurface features or deposits were exposed during
excavation, which is consistent with known prior disturbance from sugarcane cultivation and the
present macadamia orchard. The stratigraphic information, profile drawings, and photographs
taken at each trench follow.
The subsurface testing program generally revealed two distinct natural sedimentary layers
located atop decomposing bedrock: a dark, rich silty loam A horizon overlying a dusky red silty
clay loam B horizon. These findings are consistent with the USGS Soil Survey (Sato et al. 1973) sediment types depicted in Figure 7 and with past and present agricultural land use. The exception was in TE 1, which contained three stratigraphic layers. Here, the two natural sediment layers are interposed by a layer of ash deposit. The ash was deposited and subsequently covered up at some
point in time. Of all the test excavations, TE 1 is in closest proximity to the macadamia but
processing plant (see Figure 42) and may be the result of some activity at the former plantation.
No charcoal or cultural materials were present within the ash layer.
4.2.1 Test Excavation 1 (TE 1)
Test Excavation 1 (TE 1) was located in the northern corner of the proposed WWTP site portion
of the project area, where a lagoon is planned for development (see Figure 42 and Figure 43).
Figure 44 shows TE 1 marked out with orange flagging tape prior to excavation. TE 1 measured
approximately 5 m long and 1 m wide. TE 1 was excavated to a depth of up to 230 cm below surface (cmbs) through two layers of natural Waiaha series sediment (Strata I and III) interposed by a layer of deposited ash (Stratum II), and terminated at basalt bedrock (Figure 44 through Figure
46 and Table 2). No charcoal or cultural materials were observed within TE 1.
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
55
Figure 40. Photo of the sewer manhole located along the existing, maintained sewer easement within TMK: [3] 9-6-002:016; view to southwest
Figure 41. Photo showing the LCC 1 location at the makai terminus of the existing, maintained sewer easement within TMK: [3] 9-6-002:016; view to south
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
56
Figure 42. Aerial photograph showing the locations of the seven test excavation trenches within the proposed WWTP site portion of the project area (TE 1 through TE 7) (Google Earth 2013)
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
57
Figure 43. Preliminary WWTP site plan, overlain with locations of the seven test excavation trenches within the proposed WWTP site portion of the project area (TE 1 through TE 7) (site plan courtesy of client, with Google Earth 2013 overlay added)
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
58
Figure 44. Photo of TE 1 marked out with flagging tape prior to excavation; view to southwest
Figure 45. Photo of TE 1 northwest sidewall profile; view to northwest
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
59
Figure 46. Profile of TE 1 northwest sidewall
Table 2. TE 1 stratigraphic description
Stratum Depth (cmbs) Description
I 0–72 A horizon; 7.5YR 2.5/3, very dark brown; silty loam; weak, fine, granular structure; dry, loose, weak cementation consistence; slightly
plastic; terrigenous sediment origin; clear, smooth lower boundary; roots
common; no cultural material present; natural Waiaha series sediment
II 72–123 Ash; 5Y 7/1, light gray; ash; structureless (single-grain); dry, loose, no
cementation consistence; non-plastic; unknown origin; diffuse, wavy lower boundary; few roots; no charcoal or cultural material present; ash
deposit possibly associated with former plantation
III 123–230 B horizon; 2.5YR 3/4, dusky red; silty clay loam; moderate, medium,
subangular blocky structure; dry, weakly coherent, weak cementation consistence; slightly plastic; terrigenous sediment origin; abrupt, wavy lower boundary, terminated at bedrock; few roots; no cultural material
present; natural Waiaha series sediment
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
60
4.2.2 Test Excavation 2 (TE 2)
Test Excavation 2 (TE 2) was located within the northern-central section of the proposed
WWTP site portion of the project area, where a wetland is planned for development (see Figure
42 and Figure 43). Figure 47 shows TE 2 marked out with orange flagging tape prior to excavation. TE 2 measured approximately 5 m long and 1 m wide. TE 2 was excavated to a depth of up to
120 cmbs through two layers of natural Waiaha series sediment (Strata I and II) and terminated at basalt bedrock (Figure 48, Figure 49, and Table 3). Despite the presence of a few small pieces of
highly fragmental historic materials on the ground surface in the TE 2 locale (see Section 4.1), no
cultural materials were observed within TE 2.
4.2.3 Test Excavation 3 (TE 3)
Test Excavation 3 (TE 3) was located near the center of the proposed WWTP site portion of the project area, where a lagoon is planned for development (see Figure 42 and Figure 43). Figure 50
shows TE 3 marked with orange flagging tape prior to excavation. TE 3 measured approximately
5 m long and 1 m wide. TE 3 was excavated to a depth of up to 180 cmbs through two layers of natural Waiaha series sediment (Strata I and II) and terminated at basalt bedrock (Figure 51, Figure 52, and Table 4). No cultural materials were observed within TE 3.
4.2.4 Test Excavation 4 (TE 4)
Test Excavation 4 (TE 4) was located along the eastern boundary of the proposed WWTP site
portion of the project area, where a grove is planned for development (see Figure 42 and Figure
43). Figure 53 shows TE 4 marked with orange flagging tape prior to excavation. TE 4 measured
approximately 5 m long and 1 m wide. TE 4 was excavated to a depth of up to 155 cmbs through two layers of natural Waiaha series sediment (Strata I and II) and terminated at basalt bedrock
(Figure 54, Figure 55, and Table 5). No cultural materials were observed within the TE 4.
4.2.5 Test Excavation 5 (TE 5)
Test Excavation 5 (TE 5) was located in the southeastern section of the proposed WWTP site
portion of the project area, where a grove is planned for development (see Figure 42 and Figure 43). Figure 56 shows TE 5 marked with orange flagging tape prior to excavation. TE 5 measured
approximately 5 m long and 1 m wide. TE 5 was excavated to a depth of up to 162 cmbs through
two layers of natural Waiaha series sediment (Strata I and II) and terminated at basalt bedrock (Figure 57, Figure 58, and Table 6). No cultural materials were observed within TE 5.
4.2.6 Test Excavation 6 (TE 6)
Test Excavation 6 (TE 6) was located along the western boundary of the proposed WWTP site
portion of the project area, where a grove is planned for development (see Figure 42 and Figure
43). Figure 59 shows TE 6 marked with orange flagging tape prior to excavation. TE 6 measured
approximately 5 m long and 1 m wide. TE 6 was excavated to a depth of up to 160 cmbs through two layers of natural Naalehu series sediment (Strata I and II) and terminated at basalt bedrock (Figure 60, Figure 61, and Table 7). No cultural materials were observed within TE 6.
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
61
Figure 47. Photo of TE 2 marked out with flagging tape prior to excavation; view to southeast
Figure 48. Photo of TE 2 southwest sidewall; view to northeast
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
62
Figure 49. Stratigraphic profile of TE 2 southwest sidewall
Table 3. TE 2 stratigraphic description
Stratum Depth (cmbs) Description
I 0–45 A horizon; 7.5YR 2.5/3, very dark brown; silty loam, weak, fine, granular structure; dry, loose, weak cementation consistence; slightly
plastic; terrigenous sediment origin; diffuse, smooth lower boundary;
roots common; no cultural material present; natural Waiaha series sediment
II 45–120 B horizon; 2.5YR 3/4, dusky red; silty clay loam; moderate, medium,
subangular blocky structure; dry, weakly coherent, weak cementation
consistence; slightly plastic; terrigenous sediment origin; abrupt, smooth lower boundary, terminated at bedrock; few roots; no cultural material
present; natural Waiaha series sediment
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
63
Figure 50. Photo of TE 3 marked out with flagging tape prior to excavation; view to southeast
Figure 51. Photo of TE 3 west sidewall; view to northeast
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
64
Figure 52. Stratigraphic profile of TE 3 northeast sidewall
Table 4. TE 3 stratigraphic description
Stratum Depth (cmbs) Description
I 0–82 A horizon; 7.5YR 2.5/3, very dark brown; silty loam; weak, fine, granular structure; dry, loose, weak cementation consistence; slightly
plastic; terrigenous sediment origin; diffuse, smooth lower boundary;
roots common; no cultural material present; natural Waiaha series sediment
II 82–180 B horizon, Natural; 2.5YR 3/4, dusky red; silty clay loam; moderate,
medium, subangular blocky structure; dry, weakly coherent, weak
cementation consistence; slightly plastic; terrigenous sediment origin; abrupt, smooth lower boundary, terminated at bedrock; few roots; no
cultural material present; natural Waiaha series sediment
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
65
Figure 53. Photo of TE 4 marked out with flagging tape prior to excavation; view to south
Figure 54. Photo of TE 4 northwest sidewall; view to northwest
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
66
Figure 55. Stratigraphic profile of TE 4 northwest sidewall
Table 5. TE 4 stratigraphic description
Stratum Depth (cmbs) Description
I 0–60 A horizon; 7.5YR 2.5/3, very dark brown; weak, fine, granular structure; dry, loose, weak cementation consistence; slightly plastic; terrigenous
sediment origin; clear, smooth lower boundary; roots common; no
cultural material present; natural Waiaha series sediment
II 60–155 B horizon; 2.5YR 3/4, dusky red; silty clay loam; moderate, medium,
subangular blocky structure; dry, weakly coherent, weak cementation
consistence; slightly plastic; terrigenous sediment origin; abrupt, wavy lower boundary, terminated at bedrock; few roots; no cultural material present; natural Waiaha series sediment
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
67
Figure 56. Photo of TE 5 marked out with flagging tape prior to excavation; view to southwest
Figure 57. Photo of TE 5 southwest sidewall; view to south
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
68
Figure 58. Stratigraphic profile of TE 5 southwest sidewall
Table 6. TE 5 stratigraphic description
Stratum Depth (cmbs) Description
I 0–95 A horizon; 7.5YR 2.5/3, very dark brown; silty loam, weak, fine, granular structure; dry, loose, weak cementation consistence; slightly
plastic; terrigenous sediment origin; clear, smooth lower boundary; roots
common; no cultural material present; natural Waiaha series sediment
II 95–162 B horizon, Natural; 2.5YR 3/4, dusky red; silty clay loam; moderate,
medium, subangular blocky structure; dry, weakly coherent, weak
cementation consistence; slightly plastic; terrigenous sediment origin;
abrupt, smooth lower boundary, terminated at bedrock; few roots; no cultural material present; natural Waiaha series sediment
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
69
Figure 59. Photo of TE 6 marked out with flagging tape prior to excavation; view to southwest
Figure 60. Photo of TE 6 southeast sidewall; view to southeast
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
70
Figure 61. Stratigraphic profile of TE 6 southeast sidewall
Table 7. TE 6 stratigraphic description
Stratum Depth
(cmbs) Description
I 0–70 A horizon; 7.5YR 2.5/3, very dark brown; weak, fine, granular structure;
dry, loose, weak cementation consistence; slightly plastic; terrigenous sediment origin; clear, smooth lower boundary; roots common; no cultural material present; natural Naalehu series sediment
II 70–160 B horizon, Natural; 2.5YR 3/4, dusky red; silty clay loam; moderate,
medium, subangular blocky structure; dry, weakly coherent, weak cementation consistence; slightly plastic; terrigenous sediment origin;
abrupt, smooth lower boundary, terminated at bedrock; few roots; no
cultural material present; natural Naalehu series sediment
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
71
4.2.7 Test Excavation 7 (TE 7)
Test Excavation 7 (TE 7) was located in the western corner of the proposed WWTP site portion
of the project area, where a grove is planned for development (see Figure 42 and Figure 43). Figure
62 shows TE 7 marked with orange flagging tape prior to excavation. TE 7 measured
approximately 5 m long and 1 m wide. TE 7 was excavated to a depth of up to 175 cmbs through two layers of natural Naalehu series sediment (Strata I and II) and terminated at basalt bedrock (Figure 63, Figure 64, and Table 8). No cultural materials were observed within TE 7.
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
72
Figure 62. Photo of TE 7 marked out with flagging tape prior to excavation; view to southwest
Figure 63. Photo of TE 7 south sidewall; view to southeast
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Results of Fieldwork
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
73
Figure 64. Stratigraphic profile of TE 7 southeast sidewall
Table 8. TE 7 stratigraphic description
Stratum Depth
(cmbs) Description
I 0–90 A horizon; 7.5YR 2.5/3, very dark brown; weak, fine, granular structure;
dry, loose, weak cementation consistence; slightly plastic; terrigenous sediment origin; clear, smooth lower boundary; roots common; no
cultural material present; natural Naalehu series sediment
II 90–175 B horizon; 2.5YR 3/4, dusky red; silty clay loam; moderate, medium,
subangular blocky structure; dry, weakly coherent, weak cementation consistence; slightly plastic; terrigenous sediment origin; abrupt, wavy
lower boundary, terminated at bedrock; few roots; no cultural material
present; natural Naalehu series sediment
Cultural Surveys Hawai‘i Job Code: HINAMOA 2 Historic Property Descriptions
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
74
Section 5 Historic Property Descriptions
Two historic properties (historic-era road alignments) were identified within the project area during this AIS. They are summarized in Table 9 and their distributions are depicted on Figure 21.
Table 9. Sites identified within the current project area
SIHP # (50-10-69) Formal Type Function
-31088 Road alignment (Volcano Road) Transportation
-31089 Road alignment (Wood Valley Road/Coastal Road) Transportation
SIHP # 50-10-69-31088
FORMAL TYPE: Road (Wood Valley Road/Coastal Road)
FUNCTION: Transportation
NUMBER OF FEATURES: 1
AGE: Late 1800s-1920s
TAX MAP KEY: [3] 9-6-005:999 (county right-of-way)
LAND JURISDICTION: County of Hawaiʻi
PREVIOUS DOCUMENTATION: None
SIHP # 50-10-69-31088 consists of a 1.16-km (0.72-mile) section of the historic Wood Valley
Road/Coastal Road alignment located within the current project area (see Figure 21). The section
of this alignment within the project area follows the present Maile Street and Pikake Street
alignments located between the Lower Moaula Road fork and Pakalana Street on the west and
northern edges of Pāhala Town, respectively (see Figure 4). Construction of the modern Maile Street and Pikake Street roadways, which are approximately 5-10 m (16.5-33 ft) wide, has impacted all the constructed elements of the corresponding portions of the former Wood Valley
Road/Coastal Road roadway (see Figure 32 through Figure 35).
Background research, particularly examination of historic maps from the Pāhala and greater
Kaʻū areas, indicate a coastal route extending from Nāʻālehu to the Punaluʻu vicinity and then east and north through Pāhala Town, where it merged with the original (late 1800s) “Volcano Road” alignment further upslope (see Figure 8, Figure 10, Figure 11, Figure 65, and Figure 66). With the
construction of the new Volcano Road (SIHP # -31089) in the 1920s the Wood Valley Road/Coastal Road alignment became obsolete as a primary route (see Section 5.2), and the central
portion of the stretch between Pāhala and Nāʻālehu was abandoned after the development of SIHP # -31089 (see Figure 65). Above Pāhala Town the route is still called Wood Valley Road, but it is used by residents of Wood Valley located approximately 5 miles to the northeast and not as a
primary route to Kīlauea.
SIHP -31088 (Wood Valley Road/Coastal Road) is a primary transportation route that linked
Kīlauea with Nāʻālehu from the late 1800s–1920s. Pursuant to HAR §13-275-6, SIHP # -31088 is assessed as significant under Criterion d for the information it has yielded about primary transportation routes in the Pāhala vicinity during the late nineteenth and early twentieth centuries.
Cultural Surveys Hawai‘i Job Code: HINAMOA 2 Historic Property Descriptions
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
75
Figure 65. Portions of the 1995 Wood Valley, Pahala, Punaluu, and Naalehu USGS 7.5-minute topographic quadrangles showing the location of the project area in relation to historic
roadways
Cultural Surveys Hawai‘i Job Code: HINAMOA 2 Historic Property Descriptions
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
76
Figure 66. Portions of the 1995 Pahala and Punaluu USGS 7.5-minute topographic quadrangles showing the location of the project area in relation to historic roadways
Cultural Surveys Hawai‘i Job Code: HINAMOA 2 Historic Property Descriptions
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
77
SIHP # 50-10-69-31089
FORMAL TYPE: Road alignment (Volcano Road)
FUNCTION: Transportation
NUMBER OF FEATURES: 1
AGE: 1920s-1930s
TAX MAP KEY: [3] 9-6-005:999 (county right-of-way)
LAND JURISDICTION: County of Hawaiʻi
PREVIOUS
DOCUMENTATION: None
SIHP # 50-10-69-31089 consists of a 0.47-km (0.29-mile) section of the historic Volcano Road alignment located with the current project area (see Figure 21). 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 # -31088 alignment.
Additional portions of these two historic routes also overlapped further west toward Nāʻālehu (see Figure 65). Construction of the modern Maile Street roadway, which is approximately 10 m (33 ft) wide, has impacted all the constructed elements of the corresponding portions of the former Volcano Road roadway (see Figure 33 through Figure 35).
Background research, particularly examination of historic maps from the Pāhala and greater
Kaʻū areas, indicate a route extending from Kīlauea Crater to Nāʻālehu called “Volcano Road,”
replacing the similarly named route located more mauka on maps from the late 1800s and early 1900s (see Figure 12, Figure 13, Figure 65, and Figure 66). With the construction of the Māmalahoa Highway (SIHP # 50-10-47-30187) in the 1940s the Volcano Road alignment became
obsolete as a primary route; the 1967 USGS map (see Figure 14) shows the portion of the Volcano
Road alignment along present Maile Street as part of a “Route 15” looping through Pāhala from the Belt Road, while the current USGS map (see Figure 1) does not label the route at all.
SIHP -31089 (Volcano Road) is a primary 1920s-1930s transportation route that linked Kīlauea with Nāʻālehu.
Pursuant to HAR §13-275-6, SIHP # -31089 is assessed as significant under Criterion d for the
information it has yielded about primary transportation routes in the Pāhala vicinity during the late nineteenth and early twentieth centuries.
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Significance Assessments
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
78
Section 6 Significance Assessments and Register Eligibility
This AIS identified two newly documented historic properties: SIHP #s 50-10-69-31088 and -
31089, overlapping historic-era roadways crossing through the project area and APE. Section 6.1
provides significance assessments for these historic properties under HRS §6E, while Section 6.2 provides National Register and Hawai‘i Register eligibility determinations.
Significance Assessments under HRS §6E
Under HRS §6E, for a historic property to be significant under HAR §13-275-6 (applicable to government projects), the historic property should possess integrity of location, design, setting,
materials, workmanship, feeling, and/or association, and meet one or more of the following
significance criteria:
a Be associated with events that have made an important contribution to the
broad patterns of our history;
b Be associated with the lives of persons important in our past;
c Embody the distinctive characteristics of a type, period, or method of
construction, represent the work of a master, or possess high artistic value;
d Have yielded, or is likely to yield, information important for research on
prehistory or history; or
e Have an important value to the native Hawaiian people or to another ethnic
group of the state due to associations with cultural practices once carried
out, or still carried out, at the property or due to associations with traditional beliefs, events or oral accounts—these associations being important to the
group’s history and cultural identity.
The segments of SIHP #s -31088 and -31089 within the current project area only maintain
integrity of location as all the constructed elements of the original roadways are no longer present
today. While the corridors remain active roadways, they no longer function as the primary routes
they once were; furthermore, the plantation setting has been altered to one based more on residential and commercial use, and the route names themselves have also changed. Pursuant to HAR §13-275-6, SIHP # s -31088 and -31089 are assessed as significant under Criterion d for the
information they have yielded about primary transportation routes in the Pāhala vicinity during the
late nineteenth and early twentieth centuries.
National Register and Hawai‘i Register Eligibility Determination
Under Section 106, historic property significance is evaluated as eligibility for listing on the
National Register pursuant to 36 CFR 60.4. An evaluation of eligibility for listing on the Hawai‘i Register pursuant to HAR §13-198-8 is also included in this section. To be considered eligible for
listing on the National Register and/or Hawai‘i Register, a historic property should possess integrity as described in Section 6.1 above, and meet one or more of the following broad
significance criteria:
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Significance Assessments
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
79
A That are associated with events that have made a significant contribution to the broad patterns of our history;
B That are associated with the lives of persons significant in our past;
C That embody the distinctive characteristics of a type, period, or method of
construction, or that represent that work of a master, or that possess high
artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction;
D That have yielded, or may be likely to yield, information important in
prehistory or history.
As discussed in Section 6.1, none of the constructed elements of the subject portions of the original SIHP #s -31088 and -31089 roadways are evident today, and these portions of the historic properties lack integrity apart from their location (determined in consultation with SHPD; see
Appendix D). These segments of these historic properties have limited relevance and importance
in illustrating the historic context of vehicular transportation systems on Hawai‘i island. Therefore, SIHP #s -31088 and -31089 are evaluated as not eligible for inclusion on the National Register or Hawai‘i Register.
Cultural Surveys Hawai‘i Job Code: HINAMOA 2 Summary and Interpretation
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
80
Section 7 Summary and Interpretation
The entire project area was covered in close pedestrian sweeps. Except for a couple small areas of dense vegetation, access and visibility were good during the survey. The project area has been
completely altered by past agricultural and residential/town development. Historic remnants of the sugar plantation are present throughout Pāhala Town and surrounding the project area, but these
remnants are all located outside the limits of the project area.
No significant artifacts or cultural deposits were observed on the ground surface within the
proposed WWTP site portion of the project area; this area experiences ongoing disturbance by
storm water runoff and macadamia harvesting operations. No lava tube openings were encountered within the project area.
A program of subsurface testing was conducted within the proposed WWTP site and consisted
of mechanical excavation of seven test trenches. The subsurface testing generally revealed two
distinct natural stratigraphic layers atop decomposing bedrock; these sediments are consistent with
known sediment types in the area and with past and present agricultural land use. In one trench (TE 1) the two natural sediment layers are interposed by a layer of culturally sterile ash deposit,
likely associated with activity at former sugar plantation. No cultural deposits or lava tubes were
encountered during the testing.
Two historic properties were newly documented within the project area based on a review of
historic maps. These include SIHP #s -31088 and -31089, overlapping historic-era road corridors which functioned as primary transportation routes throughout the greater Pāhala/eastern Kaʻū area.
None of the constructed elements of the subject portions of the original SIHP #s -31088 or -31089
roadways are evident today, and these portions of the historic properties lack integrity apart from their location. While the project would involve ground disturbance within the existing
corresponding road corridors (Maile Street and Pikake Street), it would not create new impacts to the historic corridors nor change their present characteristics.
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Project Effect and Mitigation Recommendations
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
81
Section 8 Project Effect and Mitigation Recommendations
Project Effect
Following consultation among EPA, DOH, DEM, and SHPD regarding the project effect for
the segments of the Wood Valley/Coastal Road (SIHP # 50-10-69-31088) and Volcano Road
(SIHP # 50-10-69-31089) within the project area under HRS §6E-8, per HAR § 13-275-7(a)(1)
the County of Hawaiʻi DEM’s project effect determination is “no historic properties affected.” In
accordance with federal regulations (36 CFR 800.5), the AIS results support a determination of “no historic properties affected.”
Mitigation Recommendations
No mitigation commitments are recommended for the portions of SIHP #s 50-10-69-31088 or -31089 within the project area. The portions of these historic properties within the project area only maintain integrity of location as all the constructed elements of the original Wood
Valley/Coastal road and Volcano road are no longer evident today.
While this project will have no effect on historic properties, archaeological monitoring during
construction for identification and/or cautionary measures is proposed. This is based on the location of the project being within the “Pahala Historic District” (SIHP # 50-10-69-07362), as well as the presence near the project area of three historic properties as follows:
• a lava tube system (SIHP # 50-10-69-27570) with some cultural modifications beneath Pahala town;
• Kaʻū High and Pāhala Elementary School (SIHP # 50-10-69-07522), a National
Register-eligible historic property; and
• the Hawaiʻi Belt Road, (SIHP # 50-10-47-30187), a National Register-eligible historic
property south of the project area.
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 References Cited
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
82
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TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
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AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
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Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 References Cited
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
85
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Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Appendix A
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
86
Appendix A APE Land Jurisdiction
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Appendix A
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
87
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Appendix B
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
88
Appendix B County of Hawaiʻi
Correspondence to SHPD
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Appendix B
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
89
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Appendix B
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
90
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Appendix B
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
91
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Appendix B
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
92
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Appendix B
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
93
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Appendix B
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
94
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Appendix B
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
95
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Appendix B
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
96
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Appendix B
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
97
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Appendix B
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
98
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Appendix B
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
99
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Appendix B
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
100
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Appendix B
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
101
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Appendix C
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
102
Appendix C SHPD Correspondence
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Appendix C
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
103
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Appendix D
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
104
Appendix D SHPD Meeting Notes
Cultural Surveys Hawai‘i Job Code: HIONAMOA 2 Appendix D
AISR for the Pāhala WWTP Project, Hionamoa, Pālima, and Pāʻauʻau 1 and 2, Ka‘ū, Hawaiʻi
TMKs: [3] 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County Right-of-Ways
105
Harry Kim
Mayor
Wilfred M. Okabe
Managing Director
Qlouufy of�afuai'i
DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
October 9, 2019
345 KekOanao'a Street, Suite 41 • Hilo, Hawai'i 96720
Ph: (808) 961-8083 · Fax: (808) 961-8086
Email: cohdem@hawaiicounty.gov
Via email (alan.s.downer@hawaii.gov) and U.S. Mail
Alan S. Downer, Ph.D., Administrator
Hawai'i State Historic Preservation Division
Department of land and Natural Resources
601 Kam6kila Boulevard, Suite 555
Kapolei, Hawai'i 96707
RE: Pahala Wastewater Treatment Plant and Sewer System Project
William A. Kucharski
Director
Diane A. Noda
Deputy Director
Hionamoa, Palima, and Pa'au'au 1 and 2 Ahupua'a, Ka'u District, Hawai'i Island
TMKs: (3) 9-6-002:016 por. and 018 por., 9-6-005:036 por. and 044, and County
of Hawai'i Right-of Ways (Bautista et al. 2019)
Acceptance of Archaeological Inventory Survey Report (LOG No. 2018.000722)
Dear Dr. Downer:
The County of Hawai'i (COH) is proposing to undertake construction of the Paha la Large
Capacity Cesspool Replacement Project in Pahala, Pa'au'au 1, Ka'u District, Hawai'i Island. The
project includes a new collection system and treatment and disposal facility to service the
Paha la community as well as closure of two Large Capacity Cesspools (LCCs). The collection
system will be located primarily on County streets. The treatment and disposal facility will
occupy 14.9 acres and is located on a portion of a 42.5-acre parcel, TMK (3) 9-6-002:018, near
the southern edge of Pahala Town. A Final Environmental Assessment is currently being
prepared for this project. This project will use funds from a U.S. EPA Grant (EPA Grant XP-
96942401-7) and from the State Revolving Funds (C150090-05, C150090-08) which includes
federal and state monies.
On March 11, 2019, the County submitted to SHPD a Draft Archaeological Inventory Survey
(AIS) for the Pahala Wastewater Treatment Plant and Sewer System Project, Hionamoa, Palima,
and Pa'au'au 1 and 2 Ahupua'a, Ka'u District, Hawai'i Island (Log No. 2018.000722). In May
2019, the EPA contacted Sean Naleimaile of your staff and confirmed that SHPD was reviewing
the Draft AIS for both NHPA Section 106 consultation and HRS 6E-8 concurrence purposes.
County of Hawai'i is an Equal Opportunity Provider and Employer
Alan S. Downer, Ph.D., Administrator
October 9, 2019
Page 2
On September 26, 2019, the EPA confirmed by letter that the EPA has determined that no
historic properties will be affected by the undertaking. The basis for this determination was
explained further in the Draft AIS submitted to SHPD in March 2019 by the County of Hawai'i,
EPA's NHPA Section 106 designee. The two enclosed figures from the Draft AIS show the Area
of Potential Effect (APE) and the treatment and disposal facility project site.
Based on the findings of the March 11, 2019, Draft AIS and the EPA's September 26, 2019,
determination letter, we respectfully request that you review and accept the findings in the
Draft AIS. Your acceptance of the Draft AIS is necessary so that needed final environmental
assessment, design work, and eventually construction can proceed for the Paha la Community
large Capacity Cesspool Replacement Project.
If you have any questions or desire additional information, please contact Dora Beck at (808)
961-8513 or dora.beck@hawaiicounty.gov
Sincerely,
Director
Encs: Draft AIS APE
Draft AIS Treatment and Disposal Facility
cc: Craig lekven, Brown & Caldwell
Kate Rao, EPA
WK:mef
Dora Beck, Wastewater Division Chief
S.Wilkinson, CSH
{·
Figure 1. Aerial photo (Google Earth 2013) showing the project area and existing Large Capacity
Cesspools (LCC)
(Note: this is Figure 5 in the AIS)
Figure 2. Pahala WWTP Preliminary Site Plan showing AIS test excavation locations
(Note: this is Figure 43 in the AIS)
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
February 2020
Appendix D-1
National Historic Preservation Act Section 106 Consultation
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
February 2020
THIS PAGE INTENTIONALLY LEFT BLANK
i~D
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IX
75 Hawthorne Street
San Francisco,CA 94105-3901
Certified Mail No.:7008 1830 0002 6279 3093
Return Receipt Requested
September 26,2019
Alan Downer,Ph.D.,Administrator
Hawai’i State Historic Preservation Division
Department of Land and Natural Resources
601 Kamokila Blvd.,Suite 555
Kapolei,Hawai’i 96707
RE:National Historic Preservation Act (NHPA)Section 106 Consultation for the Pãhala
Community Large Capacity Cesspool Replacement Project (EPA Grant XP-9694240l)
Dear Dr.Downer:
The U.S.Environmental Protection Agency Region 9 (EPA)authorized our grantee,the County
of Hawai’i (County),to initiate the NHPA Section 106 consultation process with the Hawai’i
State Historic Preservation Division (SHPD)pursuant to 36 C.F.R.§800.2(c)(4)for the above-
referenced project in correspondence to you dated February 28,2018.
On March 11,2019,the County submitted to SHPD a Draft Archaeological Inventory Survey
(AIS)for the Pähala Wastewater Treatment Plant and Sewer System Project,Hionamoa,Pälima,
and Pä’au’au 1 and 2 Ahupua’a,Ka’ü District,Hawai’i Island (Log No.20 18.000722).In May
2019,EPA contacted Sean Naleimaile of your staff and confirmed that SHPD was reviewing the
Draft AIS for both NHPA Section 106 consultation and HRS 6E-8 concurrence purposes.
However,Mr.Naleimaile recently contacted my staff seeking EPA’s effect determination to
complete the Section 106 process.While it was EPA’s understanding that the County’s March
2019 submission would be sufficient to convey EPA’s effect determination,I am sending this
letter to confirm that EPA has determined that no historic properties will be affected by the
undertaking.The basis for this determination is summarized below and explained further in the
Draft AIS submitted to SHPD in March 2019 by EPA’s NHPA Section 106 designee.
Description of the Undertaking
The proposed undertaking involves construction of an improved wastewater system to replace
two large capacity cesspools (LCCs)in the community of Pähala,in the Ka’ü District,Island of
Hawai’i.See Figure 1 for an overview of the existing LCCs,new collection system,and new
treatment and disposal facility locations.Under the proposed undertaking,the County will
perform the following actions:
Printed on Recycled Paper
1)Acquire,or otherwise obtain the right to develop and use,a portion of a 42.5-acre
parcel,identified as Site 7,that is currently owned by Kamehameha Schools,then
construct a new secondary wastewater treatment and disposal facility within a portion
of the parcel (see Figure 2);
2)Construct a wastewater collection system,primarily within the public right-of-way
and two short segments within easements in the Pähala community,to collect and
convey sanitary waste from the residential lots to the new treatment and disposal
facility;
3)Close and abandon two LCCs,according to Hawai’i Department of Health (DOH)
closure procedures;and
4)Abandon the existing wastewater collection system in place.
The new secondary wastewater treatment and disposal facility will be located on a 14.9-acre
portion of the 42.5-acre parcel identified as Site 7.This 42.5-acre parcel (Tax Map Key (TMK):
3-9-6-002:0 18),located adjacent to LCC 1 about 0.5 miles (2,600 feet) south of the developed
area of the community,is owned by Kamehameha Schools and used as a macadamia nut orchard.
See Figure 2 for a preliminary site plan showing the proposed location of the treatment and
disposal facility within the southeast portion of Site 7.
The new wastewater treatment and disposal facility will consist of a headworks and an odor
control unit,an operations building,four lined aerated lagoons,a subsurface flow constructed
wetland to remove nitrogen,an adjacent disinfection system to remove pathogens,and four slow-
rate land treatment basins for disposal of the treated effluent. Construction will involve grading,
excavating,and fill activities at Site 7.Excavation to depths of approximately 4 to 10 feet will be
required to provide necessary capacity for the lagoons,constructed wetlands,and planted groves.
An approximately 4-foot tall berm will be constructed on all four sides of the groves to contain
rainfall from a 100-year,24-hour storm event.
The proposed wastewater collection system will be located within 8 public streets:Maile Street;
‘ilima Street;Huapala Street;Hinano Street;Hala Street (all located in the southern portion of
the community)and Puahala Street;Kaimani Street and Pikake Street (located on the eastern end
of the community).These streets serve the residential areas and have two travel lanes with
unpaved shoulders and no improved sidewalks. The new collection system will consist of a total
of approximately 12,150 linear feet (2.3 miles)of corrosion-resistant polyvinyl chloride (PVC)
piping,ranging in size from 8-inch diameter to 16-inch diameter.Construction of the new
wastewater collection system will require trenching in locations throughout the Pähala
community,primarily within the right-of-way of public streets plus two short segments within
easements.Trenches will typically be about 3 feet wide and at least 6 feet deep.Once the line is
placed in the trench,the affected area will be backfihled to restore the existing topography.
The two LCCs in Pãhala are readily accessible for closure activities.LCC 1 is located in a parcel
that has been previously cleared and is currently overgrown with tall grasses.It may be necessary
to clear a path for construction vehicles and equipment to access LCC 1.Clearing an access road
(or other similar work)will not be necessary to access LCC 2,which is located in the backyard
2
of a residential lot with access via the house driveway.The specific methods to be used for
closure of the LCCs have not yet been determined but will be compliant with DOH requirements.
Abandonment and closure of the two LCCs and the existing wastewater collection system will
likely require minor earthwork.The area of potential effects (APE)described below is designed
to encompass all potential closure activities.
Area of Potential Effects
In accordance with 36 C.F.R.§800.4(a)(1),EPA has defined the APE as the entire project area
that will potentially experience ground disturbance due to excavation,trenching,grading,filling,
vegetation removal,construction vehicle use,establishment and use of staging and laydown
areas,and other similar activities.The APE encompasses the wastewater treatment plant
development parcel,the entire length of the new wastewater collection system,utility and sewer
line easements, the sites of the two existing LCCs,and properties with existing sewer laterals
(see Figure 1).
Identification of Historic Properties
The County conducted a search for historic properties within the APE for this undertaking and
two road segments were identified and documented as historic features in the Draft AIS.
However,after further review and evaluation,the County determined that they were not eligible
for inclusion on the National Register of Historic Places due to the lack of integrity apart from
their location.
If potential artifacts or archeological resources are discovered during construction activities,the
contractor will stop work immediately at that location and take all reasonable steps to secure the
preservation of those features.
Native Hawaiian Organization Consultation
In accordance with the requirements of the National Historic Preservation Act,numerous
stakeholders were consulted during the development of the Draft Environmental Assessment for
the Pahala Community Large Capacity Cesspool Replacement Project (Draft EA),including 14
Native Hawaiian Organizations that may attach religious or cultural significance to properties
affected by the undertaking.On March 29,2018,each of the following organizations was sent a
copy of a project summary and a request for their written comments on the undertaking.
Attachment A provides an example of the correspondence that was sent to all 14 organizations
listed below.As of the date of this letter,no responses have been submifted to the County.
•Hawai’i Island Burial Council e Maku’u Farmers Association
•Association of Hawaiian Civic Clubs e Na Koa Ikaika Ka Lãhui Hawai’i
•Charles Pelenui Mahi ‘Ohana •Office of Hawaiian Affairs
•Friends of ‘lolani Palace o Pacific Agricultural Land Management
o Hawaiian Civic Club of Rib Systems
•Kamehameha Schools •Partners in Development Foundation
•Kanu o ka’Aina Learning ‘Ohana o Pi’ihonua Hawaiian Homestead
•Ko’olau Foundation Community Association
3
Outreach
During the public comment period for the Draft EA (September 23,2018 —December 10,2018),
EPA and the County received public comments expressing concern regarding impacts to “a
burial cave with human skeletal remains and or shelving”that is “in the area where the County
wants to put a Sewage wastewater treatment plant.”Based on the available information,EPA and
the County believe that these comments refer to the filled lava tube opening identified in the
2016 archaeological field inspection report that is described in Section 1.2 of the Draft AIS.To
ensure that the undertaking does not affect this cultural resource, the County configured the site
plan for the proposed wastewater treatment and disposal facility to ensure that the location of this
lava tube opening would be outside the APE for this undertaking.
Finding of No Historic Properties Affected
In accordance with 36 C.F.R.§800.4(d),EPA has reached a finding of no historic properties
affected for this undertaking.Since there are no known historic or archeological sites within the
APE,and since appropriate preservation measures will be taken should archeological resources
be discovered during construction, this undertaking will have no effect on any historic or cultural
resources or on any traditional and customary practices.In addition,the potential for
encountering unexpected archeological resources within the site of the proposed treatment and
disposal facility is low due to historical ground modifications and ongoing harvesting activities.
I am requesting your concurrence with the APE and the determination of no historic properties
affected within 30 days of receipt of this letter.If I do not receive a response within 30 days of
receipt,I will assume concurrence from your office and EPA will authorize the grant recipient to
proceed with the project in accordance with 36 C.F.R.§800.4(d)(1)(i).
If you require additional information or have questions regarding this request,please contact
Kate Rao,Groundwater Protection Section,at (415) 972-3533 or via email at rao.kate@epa.gov.
Sincerely,
Manager,Groundwater Protection Section
Water Division
cc:
William Kucharski,County of Hawai’i
Dora Beck,County of Hawai’i
Attachments:
Figure 1 --Area of Potential Affect and AIS ProjectArea for the Pãhala Community LCC
Replacement Project
Figure 2 --Preliminary site plan showing the 14.9-acre Pãhala WWTP within the southeast
portion of Site 7.
Attachment A —Native Hawaiian Organizations Correspondence
5
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PRELIMINARY SITE PLAN
SCALEINFEET
Harry Kim William A.Kucharski
Mayor Director
Wilfred M.Okabe Diane A.Noda
Managing Director Deputy Director
(g~~f~nf~~rn~
DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
345 Kekuan~o’a Street,Suite 41 Hilo, Hawai’i 96720
Ph:(808) 961-8083 Fax:(808)961-8086
cohdem@co.hawaii.hi.us
ht~pj//~yw.hawaiicounty.goy/envjronrnentaj-nianaoernentJ
March 29,2018
Ms.Mililani B.Trask,Convenor
Na Koa Ikaika o Ka Lãhui Hawai’i
P.O.Box 6377
Rib,1-11 96720
Subject:PAhala Community Large Capacity Cesspool Replacement
PA’au’au,Ka’u, Hawai’i
Consultation Under U.S.C.§302706
Dear Ms.Trask:
The County of Hawai’i Department of Environmental Management (DEM)is undertaking the
Pähala Community Large Capacity Cesspool Replacement,Pä’au’au,Ka’U,Hawai’i project.
This project would be funded by a U.S.Environmental Protection Agency (EPA)Region 9
Special Appropriation Grant and by the State of Hawai’i Clean Water State Revolving Fund
(SRF)loan program.The proposed project will utilize federal funds;as such it is considered a
federal action and undertaking,as defined by the National Historic Preservation Act (NHPA)of
1966,as amended (2006),and as Set forth in 54 U.S.C.§300320.Therefore,the EPA must
consider the effects of the project on historic properties and must also consult with organizations
that attach religious or cultural significance to properties affected by the project.
By letter dated March 8,2018, the EPA Region 9 reached out to participants to be consulted on
this project pursuant to U.S.C.§302706,also called Section 106 ofthe NHPA (see enclosure).
The letter also stated that the EPA had authorized the DEM to initiate consultation. Therefore,
on behalf of the EPA Region 9,the DEM invites you to participate in consultation for the
proposed Pãhala Community Large Capacity Cesspool Replacement project,which is located
about 52 miles south of Rib and west (mauka)of Mämalahoa Highway (Route 11)within the
community of P~hala.
Overview of the Undertaking
The purpose of the project is to construct wastewater system improvements to replace the
County’s existing system servicing Pãhala.The wastewater system improvements will allow the
County of Hawai’i is an Equal Opportunity Provider and Employer
County to comply with EPA regulations requiring closure of large capacity cesspools (LCCs)
and to construct a system meeting current State of Hawaici Department of Bealth (DOT—I)and
DEM design guidelines for the collection,treatment and disposal of the treated effluent.The
Pähala Community Large Capacity Cesspool Replacement Project improvements would be
owned,operated and maintained by the County.A project summary sheet and location map are
enclosed for your information.
The new wastewater collection system will be located within public rights-of-way,and the new
treatment and disposal system will be located on a currently privately owned parcel (TMK:9-6-
002:0 18)which will be acquired by the County.The wastewater collection system would be
located within 7 public streets;Maile Street,‘Ilima Street,Huapala Street,1—Ilnano Street,and
Hala Street,all located in the southern portion of the community and Puabala Street;and Pikake
Street located on the eastern end.The collection system would consist of approximately 11,000
linear feet of gravity flow piping ranging from 8 to 12 inches in diameter, The collection system
is not anticipated to include County pump stations,nor will the system collect stormwater runoff
The County’s sewer standards show the trenches for sewer lines would require at least 4 -feet of
cover from the top of the pipe to grade and 12 inches of cushion material on both sides of the line
and 6 inches below the line.Therefore,the typical sewer trenches will be about 3 feet wide and
at least 6 feet deep.
The proposed treatment and disposal system would occupy about 14 acres and consist of a
headworks with screens to remove debris and an odor control unit,-four lined aerated lagoons of
about 0.3 acres each,an operations building with adjacent disinfection system to remove
pathogens,a subsurface flow constructed polishing wetland to remove nitrogen and four slow
rate (SR)land treatment basins planted with native Hawaiian trees that will be surrounded by
berms on all four sides.SR land treatment involves irrigation of land and vegetation with the
treated effluent.Significant additional treatment is provided as the water percolates through the
soil.The vegetation uptakes the nutrients in the effluent as fertilizer,and transpires a portion of
the applied water.A security fence will be constructed along the perimeter of the site.
An archaeological inventory survey,including the excavation of trenches,will be conducted
within the treatment and disposal project site to identif~’the presence of historic properties as
defined in U.S.C §300308.
Consultations
We welcome any comments you have on this Project’s proposed improvements.We are
particularly interested in any information you may have on the historic and cultural sites that
have been recorded in the area or any other historic or cultural sites about which you may have
knowledge.
Section 106 consultation letters have also been sent to other organizations or individuals that
might attach significance to this area and inviting them to participate in the process.The attached
list shows the organizations that are also being consulted as part of this Section 106 consultation.
In addition,if you are acquainted with any persons or organization that are knowledgeable about
the proposed project area,or any descendants with ancestral lineal or cultural ties to or cultural
knowledge or concerns for,and cultural or religious attachment to the proposed project area,we
would appreciate receiving their names and contact information.
We would appreciate a written response within 30 days from date of receipt of this letter to Dora
Beck,RE,,Project Manager,County of Hawai’i Department of Environmental Management,by
U.S.Postal Service to County of Hawai’i Department of Environmental Management,108
Railroad Avenue,Rib,Hawai’i 96720.
Please feel free to contact Dora Beck by telephone at (808)961-8513 if you have any questions.
We look forward to working with you and the State Historic Preservation Division on these
needed improvements.
Very truly yours
~charski~
Director
WKIDB :rnef
Attachment and enclosures
Pãhala Community Large Capacity Cesspool Replacement Project
Palau’au,Ka’u,Hawai’i
Native Hawaiian Organizations Consultation List
Hawai’i Island Burial Council
Association of Hawaiian Civic Clubs
Charles Pelenui Mahi ‘Ohana
Friends of ‘lolani Palace
Hawaiian Civic Club of Hilo
Karnehameha Schools
Kanu o ka’Aina Learning ‘Ohana
Ko’olau Foundation
Maku’u Farmers Association
Na Koa Ikaika Ka Laliui Hawai’i
Office of Hawaiian Affairs
Pacific Agricultural Land Management Systems
Partners in Development Foundation
Pi ‘ihouna Hawaiian Homestead Community Association
PROJECT SUMMARY
Pãhala Community Large Capacity Cesspool Closure
Pã~au’au,K&u,Island of Hawai’i
Tax Map Key:9-6~002:O18
1,Introduction
The community of Pãhala is located about 52 mites southeast of Hilo,in the Kau District, Island of
Hawaii.Pãhala is located west (mauka) of Mãmalahoa Highway (State Route 11)about 3.8 miles
from the shoreline with most of the community tying between 980 feet mean sea level (msl)on the
western end and approximately 800 feet msl on the eastern end.See Figure 1.The Pähala
community had its start in 1876 with establishment of the Hawaiian Agricultural Company to develop
the sugar industry in Hawaii.For the next 120 years or so,Pãhala was a major sugar producing area.
However,by the early 1 990s there was a major downturn in the sugar market.Thus,beginning in
1994,the sugar mill in the town was shut down and dismantled.By 1996,the Ka’u Sugar Company,
the successor to the Hawaiian Agricultural Company,closed and,subsequently,the sugar cane fields
were cleared and the lands now grow macadamia nut and coffee trees The population in Pãhala was
approximately 1,405 persons in 2016,the most current estimate.
Founded in 1826,C.Brewer was both the oldest company in Hawai’i and a major developer of the
sugar industry in Pãhala.For about the last 60 years,approximately 50 percent of the residential
units in Pãhala have been serviced by a wastewater collection and disposal system constructed,
operated and maintained by C.Brewer The collection system consisted of sewer lines,some of
which were located in the streets and others routed in the backyards of private parcels.The disposal
system consisted of two large capacity cesspools (LCCs) within the community.
In 1998,the US Environmental Protection Agency (EPA)issued regulations (40 CFR 144.14)requiring
the elimination or closure of all large capacity cesspools used for wastewater disposal by April 5,
2005.In 2003,C.Brewer requested assistance from the County to close their LCCs.Subsequently,
the County held a community meeting to present sewer system replacement alternatives.Voting took
place by mail to choose the preferred sewer improvement alternative,resulting in 87 percent of
returned ballots in favor of installing a new sewer collection, treatment and disposal system to be
operated and maintained by the County.
In 2006,in anticipation of its dissolution,C,Brewer requested the County construct and maintain a
new community sewer system.The County subsequently agreed by way of a County Council
Resolution,to enter into a formal agreement to assume ownership of the C.Brewer constructed
collection system and the two LCCs by April 30,2010 and to construct and maintain a new community
sewer system.As part of the County’s agreement,C.Brewer agreed to install laterals to certain of the
residential properties.
In 2007,the County proposed a new collection system and a wastewater treatment system,consisting
of large capacity septic tanks and converting the existing LCCs into seepage pits for disposal of the
treated effluent.In 2008,the combination of the LCCs being in poor and failing condition and the poor
results from soil percolation tests influenced the County to consider acquiring a larger land area to
construct a secondary treatment system.Such a system could allow a higher level of wastewater
treatment and disposal,as well as accommodate existing Pãhala properties not currently served by
the LCC system in addition to expanding the system to accommodate possible community growth.
2.Project Description
The County of Hawai’i.Department of Environmental Management (DEM)is proposing to construct
wastewater system improvements to replace the current system servicing Pãhala,now owned by the
County.The wastewater system improvements would allow the County to comply with EPA
PROJECT SUM MARY
Pähala Community Large Capacity Cesspool Closure
Pã’aWau,Ka’u,Island of Hawaii
Tax Map Key:9~.6-002:0l8
regulations requiring closure of the LCCs and to construct a system meeting current State of Hawaii
Department of Health (DOH)and DEM design guidelines for the collection,treatment and disposal of
the treated effluent.The Pãhala Community Large Capacity Cesspool Closure project improvements
would consist of a new wastewater collection system located within the public right-of-way and a
treatment and disposal system located on a currently privately-owned parcel (TM K:9-6-002:018)
which will be acquired by the County.The Pãhala Community Large Capacity Cesspool Closure
project would be funded by an EPA Special Appropriation Grant and by the State of Hawai’i Clean
Water State Revolving Fund (SRF)loan program.
The wastewater collection system would be located within 7 public streets;Maile Street;‘Ilima Street;
Huapala Street;HTnano Street;Hala Street;all located in the southern portion of the community and
Puahala Street;and Pikake Street located on the eastern end.These streets serve the residential
areas and have two travel lanes with unpaved shoulders and no improved sidewalks.The collection
system would consist of approximately 11,000 linear feet of gravity flow piping ranging from 8 to 12
inches in diameter.The collection system is not anticipated to include pump stations,nor will the
system collect stormwater runoff.The number of manholes in the system will be determined during
the detail design phase. The County’s sewer standards show the trenches for sewer lines would
require at least 4 feet of cover from the top of the pipe to grade and 12 inches of cushion material on
both sides of the line and 6 inches below the line.Therefore,the typical sewer trenches will be 3 feet
wide and at least 6 feet deep.
The treatment and disposal system would be a land-based system located southeast of the developed
community and would be designed to treat flows of approximately 190,000 gallons per day.The EPA
defines land treatment as “the application of appropriately pre-treated municipal and industrial
wastewater to the land at a controlled rate in a designed and engineered setting. The purpose of
the activity is to obtain beneficial use of these materials,to improve environmental quality,and to
achieve treatment goals in a cost-effective and environmentally sound manner”.
The proposed treatment and disposal system would occupy about 14 acres and consist of a
headworks with screens to remove debris and an odor control unit,four lined aerated lagoons of
about 0.3 acres each,an operations building with adjacent disinfection system to remove pathogens,
a subsurface flow constructed polishing wetland to remove nitrogen and four slow rate (SR)land
treatment basins which will be surrounded by berms on all four sides.SR land treatment involves
irrigation of land and vegetation with the treated effluent.Significant additional treatment is
provided as the water percolates through the soil.The vegetation uptakes the nutrients in the
effluent as fertilizer,and transpires a portion of the applied water.A security fence will be
constructed along the perimeter of the site.
3.Anticipated Impacts
Project impacts would be primarily related to construction of the trenches for placement of the
collection system lines and construction of the land-based treatment and disposal system.These
activities would create dust and noise while work occurs in the streets and in the area of the land
treatment and disposal system,which will include removal of existing macadamia nut trees within the
14 acre project site. As the collection system is constructed,the streets will be restored for vehicle
travel.Upon completion of the treatment and disposal facilities, the project will operate without the
need for DEM employees to be on-site.Weekly monitoring visits will be sufficient to insure routine
proper operation,and a telemetry system will alert DEM employees of abnormal conditions to allow
timely response when they occur.
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FIGURE 1
PROJECT LOCAIION MAP
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PAHALA COMMUNITY LARGE CAPACITY CESSPOOL CLOSURE PROJECT
COLJNTYOFHA WAIl DEPARTMENT OF ENViRONMENTAL MANAGMENT
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REG1ON~X
75 Hawthorne Street\c~San Francisco,CA 94105-39011.PRO~
MAR 0 8 2016
Mililani B.Trask,Convenor
Na Koa Ikaika Ka Lahui Hawaii
P0 Box 6377
Hilo,HI 96720
RE:U.S.Environmental Protection Agency Region 9 authorization to allow the County of
Hawaii to initiate consultation with the State Historic Preservation Officer and Native
Hawaiian organizations for the Pahala Community Large Capacity Cesspool Replacement
Project
Dear Ms.Trask:
The U.S.Enviromnental Protection Agency Region 9 (EPA)awarded a Special Appropriation Act
project grant to the County of Hawaii for the Pahala Community Large Capacity Cesspool (LCC)
Replacement Project.This project may have effects on properties included in,or eligible for
inclusion in,the National Register of Historic Properties.The National Historic Preservation Act
(NHPA),54 U.S.C.§300101 et seq.,and its implementing regulations,36 CFR Part 800,require
federal agencies to consider the effects of their undertakings on historic properties,
Pursuant to 36 CFR §800.2(c)(4),a Federal agency may authorize an applicant for federal
assistance to initiate consultation with the State Historic Preservation Officer (SHPO)or Native
Hawaiian organizations provided that: (1)the Federal agency remains legally responsible for all
findings and determinations charged to the agency official;and (2)the Federal agency notifies the
SHPO or Native Hawaiian organizations when an applicant is so authorized.
In accordance with 36 CFR §800.2(c)(4),EPA hereby authorizes the County of Hawaii to act on
EPA’s behalf when initiating the NHPA consultation process in connection with the Pahala
Community LCC Replacement Project.Effective immediately,the County of Hawaii may consult
with the SHPO and Native Hawaiian organizations (see enclosed list)to initiate the review
process under 36 CFR Part 800 including identifying and evaluating historic properties,assessing
effects,and proposing mitigation measures where necessary.However,EPA Region 9 will remain
responsible for participating in the consultation process if:
the County of Hawaii determines that the c~Criteria of Adverse Effect”under 36 CFR
§800.5 applies to this project;or
~there is disagreement between the County of Hawaii and the SHPO or Native Hawaiian
organizations regarding the scope of the area ofpotential effects,identification of historic
properties,or evaluation of effects;or
Printed on 100%Postconswner Recycled Paper P,VCCSS chlorine Free.
there is an objection from consulting parties or the public regarding findings or
determinations or the implementation of agreed provisions;or
~there is potential for a foreclosure situation or intentional adverse effects as described
under 36 CFR §800.9(b)and (c).
In accordance with 36 CFR §800.2(c)(2),EPA shall ensure that all consultations with Native
Hawaiian organizations are conducted in a sensitive manner concerning the needs of such
organizations.
If you have any questions,please contact Kate Rao,Drinking Water Protection Section,at (415)
972-3533 or via email at ~1cate~p~ov.
Td~más Torres
Water Division Director
End.:Pahala Large Capacity Cesspool Replacement Project
Native Hawaiian Organizations Consultation List
cc:William Kurcharski,County of Hawaii
Dora Beck,County of Hawaii
Craig Levken,Brown and Caldwell
Earl Matsukawa,Wilson Okamoto Corporation
John Sakaguchi,Wilson Okarnoto Corporation
David Shideler,Cultural Surveys Hawaii,Inc
9
Ca aci C ess 0ol Re lacement Pro ~e et
Native ~
Hawaii Island Burial Council
Association of Hawaiian Civic Clubs
Charles Pelenui Mali Ohana
Friends of lolani Palace
Hawaiian Civic Club of Hilo
Kamehameha Schools
Kanu o ka ‘Ama Learning ‘Ohana
Koolau Foundation
Maku’u Farmers Association
Na Koa Ikaika Ka Lahui Hawaii
Office of Hawaiian Affairs
Pacific Agricultural Land Management Systems
Partners in Development Foundation
Piihonua Hawaiian Homestead Community Association
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka‘ū District, Hawai‘i
February 2020
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Final EA, Pāhala LCC Replacement Project
Pāhala, Ka’ū District, Hawai‘i
February 2020
Appendix E
EPA and County of Hawai‘i Responses to Comments on the Draft EA
Final EA, Pāhala LCC Replacement Project
Pāhala, Ka’ū District, Hawai‘i
February 2020
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Appendix E:
U.S. Environmental Protection Agency
and County of Hawaiʻi
Response to Comments on the Draft
Environmental Assessment
for the
Pāhala Large Capacity Cesspool (LCC)
Replacement Project
EPA Grant XP-96942401
Pāhala, District of Ka‘u, County of Hawai‘i, Hawai‘i
TMK: 9-6-002:018
Final EA, Pāhala LCC Replacement Project – Appendix E
Pāhala, Ka‘ū District, Hawai‘i
February 2020 i
Contents
1 Index of Comments Received on the Pāhala Large Capacity Cesspool Replacement Project Draft EA ............................................................................................................... 1
2 EPA Response to Comments .......................................................................................... 3
2.1 Resource Area Impacts........................................................................................3
2.1.1 Flood Risk ................................................................................................ 3
2.1.2 Public Services ......................................................................................... 6
2.1.3 Visual Characteristics ............................................................................... 7
2.1.4 Socioeconomic ......................................................................................... 7
2.1.5 Archeological and Cultural Resources .................................................... 11
2.1.6 Air Quality ............................................................................................... 13
2.1.7 Other Impacts ......................................................................................... 14
2.2 NEPA Processes ...............................................................................................16
2.2.1 Purpose and Need ................................................................................. 16
2.2.2 Scope of the Proposed Action ................................................................ 17
2.2.3 Cumulative Effects ................................................................................. 19
2.2.4 Federal and State Consultations ............................................................ 20
2.2.5 NEPA Procedures .................................................................................. 22
2.3 Public Involvement and Outreach ......................................................................24
2.3.1 Outreach ................................................................................................ 24
2.3.2 Accessing the Draft EA ........................................................................... 28
2.3.3 Public Information Meeting ..................................................................... 28
2.3.4 Nāʻālehu and Pāhala LCC Conversion Project – 2007 Final EA ............. 30
2.3.5 State and Local Agencies ....................................................................... 31
2.4 State and Local Processes ................................................................................31
2.4.1 State of Hawaiʻi Office of Planning.......................................................... 32
2.4.2 Hawaiʻi Environmental Policy Act (HEPA) ............................................... 32
2.4.3 Hawaiʻi Department of Business, Economic Development and Tourism, Land Use Commission (LUC) ................................................................. 33
2.4.4 Ka‘ū Community Development Plan (CDP) ............................................ 34
2.5 Project Location and Design ..............................................................................34
2.5.1 Proximity to Schools ............................................................................... 34
2.5.2 Location of Preferred Alternative ............................................................ 35
2.5.3 Extent of Collection System .................................................................... 36
2.5.4 Treatment Alternatives ........................................................................... 37
2.5.5 Technical Design .................................................................................... 38
2.6 Other Comments................................................................................................41
2.6.1 Miscellaneous and Other Comments ...................................................... 41
2.6.2 Nāʻālehu Large Capacity Cesspools Closure Project .............................. 43
2.7 Comments Not Related to NEPA .......................................................................44
3 County of Hawaiʻi Response to Comments .................................................................... 46
Final EA, Pāhala LCC Replacement Project – Appendix E
Pāhala, Ka‘ū District, Hawai‘i
February 2020 1
1 Index of Comments Received on the Pāhala Large
Capacity Cesspool Replacement Project Draft EA
A Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool (LCC) Replacement Project1 was released for public comment on September 23, 2018. Initially, a 30-day public comment period was planned; however, due to requests from the public for additional time, the U.S. Environmental Protection Agency (EPA) and the County of Hawaiʻi (County) agreed
to republish the Draft EA on November 8, 2018 which extended the comment period. The comment period closed on December 10, 2018. Table 1 lists the comments received, including the names of the commenters and a comment number assigned to each comment. In total, 77
comment letters were received, some of which included multiple individual comments.
Table 1
Index of Comments Received on the Pāhala LCC Replacement Project Draft EA
Number Commenter Date
1 S. Demoruelle 9/24/2018
2 S. Demoruelle 9/24/2018
3 S. Demoruelle 9/24/2018
4 S. Demoruelle 9/24/2018
5 S. Demoruelle 9/25/2018
6 S. Demoruelle 9/25/2018
7 S. Demoruelle 9/25/2018
8 S. Demoruelle 9/25/2018
9 S. Demoruelle 9/28/2018
10 S. Demoruelle 9/28/2018
11 S. Demoruelle 9/28/2018
12 S. Demoruelle 9/28/2018
13 S. Demoruelle 9/29/2018
14 S. Demoruelle 10/1/2018
15 S. Demoruelle 10/1/2018
16 S. Demoruelle 10/3/2018
17 S. Demoruelle 10/6/2018
18 S. Demoruelle 10/10/2018
19 S. Demoruelle 10/12/2018
20 S. Demoruelle 10/13/2018
21 S. Demoruelle 10/21/2018
22 S. Demoruelle 10/24/2018
23a S. & J. Demoruelle 10/22/2018
23 [Comment combined in 23a]
24 [Comment combined in 23a]
25 [Comment combined in 23a]
26 T. Tuttle 10/10/2018
27 S. Demoruelle 10/10/2018
28 N. Hong 10/10/2018
29 N. Gilmour 10/17/2018
30 J. Warren 10/19/2018
31 N. Gilmour 10/20/2018
1 Preconsultation letters and other materials related to this project may use a slightly different project title (e.g., Pāhala Community Large Capacity Cesspool Replacement Project).
Final EA, Pāhala LCC Replacement Project – Appendix E
Pāhala, Ka‘ū District, Hawai‘i
February 2020 2
Table 1
Index of Comments Received on the Pāhala LCC Replacement Project Draft EA
32 State of Hawaiʻi Office of Planning 10/17/2018
33 E. Andrade Jr. 10/19/2018
34 C. & T. Tuttle 10/22/2018
35 State of Hawaiʻi Department of Hawaiian Home Lands 9/27/2018
36 County of Hawaiʻi Police Department 10/2/2018
37 R. Javar 10/10/2018
38 L. Lopes 10/22/2018
39 S. Demoruelle 10/23/2018
40 Pāhala Residents per Pele Defense Fund 10/23/2018
41 S. Hanoa 10/23/2018
42 J. Moses 10/24/2018
43 A. & A. McDowell 10/22/2018
44 D. Loper 9/29/2018
45 S. Demoruelle 10/31/2018
46 S. Demoruelle 10/31/2018
47 S. Demoruelle 10/31/2018
48 S. Demoruelle 10/31/2018
49 S. Demoruelle 10/26/2018
50 S. Demoruelle 11/2/2018
51 S. Demoruelle 11/5/2018
52 S. Demoruelle 11/6/2018
53 S. Demoruelle 11/8/2018
54 S. Demoruelle 11/13/2018
55 A. & M. Ibarra 11/13/2018
56 W. & D. Wong Yuen 11/14/2018
57 S. Demoruelle 11/16/2018
58 S. Demoruelle 11/2/2018
59 L. Navarro 11/19/2018
60 L. Gollin 11/19/2018
61 T. Ibarra 12/1/2018
62 P. Fuerte 10/10/2018
63 G. Sorensen 11/2/2018
64 S. Demoruelle 12/10/2018
65 S. Demoruelle 12/10/2018
66 S. Demoruelle 12/10/2018
67 T. Napeahi, Pele Defense Fund 12/10/2018
68 D. Kalua 12/4/2018
69 T. Napeahi, Pele Defense Fund [Duplicate of Comment 67] 12/10/2018
70 T. Napeahi, Pele Defense Fund [Duplicate of Comment 67] 12/10/2018
71 State of Hawaiʻi Department of Land and Natural Resources 12/7/2018
72 State of Hawaiʻi Department of Education 12/7/2018
73 N. Gilmour 12/10/2018
74 K. Fox 12/10/2018
75 S. Demoruelle 12/10/2018
76 N. Hong 10/28/2018
77 State of Hawaiʻi Department of Land and Natural Resources 10/22/2018
Final EA, Pāhala LCC Replacement Project – Appendix E
Pāhala, Ka‘ū District, Hawai‘i
February 2020 3
2 EPA Response to Comments
EPA’s responses to comments received are detailed below. Due to the number of comments received, comments and responses are grouped by subject matter. Each section contains a
summary of comments received, followed by EPA’s responses.
As explained in the Preface of the Final EA, EPA and the County elected to prepare a joint EA in order to promote consistency and avoid duplication of efforts. Due to the fact that it is a joint document, the Final EA contains information related not only to compliance with the National
Environmental Policy Act (NEPA) and federal cross-cutting authorities, but also information
related to compliance with state and local requirements, such as the Hawaiʻi Environmental Policy
Act (HEPA), otherwise referred to as Hawaiʻi Revised Statutes (HRS) Chapter 343. EPA is only
responsible for addressing compliance with NEPA and federal cross-cutting authorities, and thus,
EPA’s responses to comments are focused on these issues. The County is responsible for complying with additional state and local requirements and has prepared separate responses to
individual comments that are included in Section 3 of this Appendix. The County responses use the same numbering system as Table 1 (see Section 1).
2.1 Resource Area Impacts
Responses to comments received regarding the impacts to the resource areas as described in the Draft EA associated with the proposed project have been arranged into the following categories:
• Flood Risk
• Public Services
• Visual Characteristics
• Socioeconomic
• Archeological and Cultural Resources
• Air Quality
• Other Impacts
2.1.1 Flood Risk
Comment
• I am concerned about the flooding potential of the WWTP, specifically relating to the culvert that carries water beneath the highway from the macadamia nut orchard.
(Comments 22, 41)
• What will prevent the "lagoon style treatment plant" from overflowing in the event of heavy rains and flooding due to tropical storms and hurricanes, which may be more frequent with climate changes? (Comments 28, 33, 56)
• There has been historical flooding that is a major concern to the community, to the proposed area. (Comment 40)
• Flooding at the sewage treatment plant site will cause health and safety issues.
(Comments 63, 76)
Final EA, Pāhala LCC Replacement Project – Appendix E
Pāhala, Ka‘ū District, Hawai‘i
February 2020 4
• Flooding at the site will create hazardous and dangerous scenarios. Flooding will impact emergency routes, may impact travel to hospitals or emergency facilities and could isolate emergency first responders, fire and EMS vehicles and equipment. (Comments 41, 67, 68)
• The location of the plant should be reconsidered because of the history of flooding in the area. Overflow of the reservoirs could transport toxins, bacteria, and chemicals over
Highway 11, through conservation and preservation areas, and into the ocean. (Comments 55, 76)
Response
Due to the nature of the comments received, the responses to flooding-related comments were broken into two response categories:
a) Flood Risk: Response addressing concerns regarding the potential for the location of
the wastewater treatment and disposal facility and collection system to flood; and
b) Overflow of Wastewater Treatment and Disposal Facility: Response addressing concerns regarding the design of the facility and concerns related to overflow inside the facility.
a) Flood Risk
As stated in the Draft EA Section 3.9.1 (Flood Risk – Existing Conditions), the Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM), Community Panel No. 155166 1800F, effective date September 29, 2017, shows 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. The County of Hawai‘i Department of Public Works (in its April 16, 2018 response to the pre-assessment notification) confirmed that the proposed
wastewater treatment and disposal facility site is outside the 500-year floodplain. As such, the site is not considered to be in a high flood risk area. The wastewater treatment and disposal facility would not result in construction of new facilities 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. No impacts to the existing floodplain are expected.
The wastewater treatment and disposal facility would be designed to minimize the creation of new stormwater flow and to avoid disrupting existing stormwater flow patterns. Current drainage
patterns are influenced by two existing culverts that allow stormwater to flow across the Māmalahoa Highway in the vicinity of the proposed wastewater treatment and disposal facility. The first is a box culvert located at the intersection with Maile Street that conveys stormwater under the highway. The second culvert is located approximately 600 feet east of the Maile Street intersection and was used to convey sugar mill flume water across the highway for disposal. Please see the Final EA Section 3.23.1 (Infrastructure – Drainage System) for a map showing the location of the two culverts.
The proposed wastewater treatment and disposal facility would include an on-site drainage system to address stormwater surface runoff created by new impervious surfaces within the facility. The site would include a system to collect runoff via grated inlets or swales, and flows would be conveyed to on-site drainage detention systems, such as subsurface linear infiltration or depressed detention basins (see Draft EA Section 3.23.2).
Final EA, Pāhala LCC Replacement Project – Appendix E
Pāhala, Ka‘ū District, Hawai‘i
February 2020 5
The Pāhala LCC Replacement Project would have minimal impact on existing stormwater flows. The Site 7 parcel, including the proposed site of the wastewater treatment and disposal facility,
slopes from approximately north to south (mauka to makai) such that, during rain events, surface flows drain through the existing orchard to the southern (makai) end where the flows eventually drain through the culvert located at the Maile Street - Māmalahoa Highway intersection to the areas below the highway. Stormwater drainage flows generated upstream of the wastewater treatment and disposal facility project site would be directed around the perimeter via diversion swales that would convey flow back to the existing drainage pattern to the culvert at Maile Street. During heavy rain events, stormwater may temporarily back up behind the culvert. However, these ponding events are typical and expected at any culvert and would not be exacerbated as a result of the Proposed Action because there would be no net increase in runoff or drainage flows from the site up to and including design storm events. Due to the topography of Site 7, stormwater drainage flows from onsite are not anticipated to flow through the second culvert mentioned above
due to its elevation and location to the east which means it is generally upgradient from the onsite drainage patterns.
As a result, the Pāhala LCC Replacement Project is not anticipated to contribute to any increased
risk of flooding of Māmalahoa Highway, Maile Street, or downstream properties. The State of Hawai‘i Department of Transportation (DOT) Hawai‘i District office was contacted to discuss the historical roadway flooding concerns expressed by the community at the wastewater treatment
and disposal facility project site and the culvert at the Maile Street - Māmalahoa Highway intersection. The District office indicated the DOT owns and maintains the culvert at the Maile Street intersection, and that they have no record of the roadway being inundated by stormwater drainage at that location during precipitation events.
Furthermore, the Pāhala LCC Replacement Project would be constructed in accordance with all applicable design criteria related to minimizing flood risk. As stated in the Draft EA Section 3.23 (Infrastructure – Drainage System), the on-site stormwater management system would meet the requirements of Hawai‘i County Code (HCC) § 27-20(e) (Standards for subdivisions and other developments), which mandates a site drainage plan to “comply with sections 27-20(a) and (b) and section 27-24, and shall include a storm water disposal system to contain runoff caused by the proposed development, within the site boundaries, up to the expected one-hour, ten year
storm event as shown in the department of public works ‘Storm Drainage Standards’ unless those standards specify a greater interval.” To act as secondary containment in the event of a large storm event, landscape buffers with dirt berms may also be constructed around most of the
perimeter of the facility; these berms would be subject to a geotechnical engineering assessment of berm stability during the design process.
In addition, to meet the requirements of HCC § 27-20(f), the wastewater treatment and disposal
facility would be designed to not alter the general drainage pattern above or below the development. Thus, no increase in flow amount for HCC design storm events would be directed to either of the culverts at the highway as a result of the site development. HCC § 27-20 requires an on-site drainage plan to accommodate any runoff caused by a proposed development. Therefore, a drainage study would be prepared during the design process to evaluate the improvements that are needed to comply with the County Code requirements. These additional
requirements and impact avoidance measures are stated in the Final EA Sections 2.3.1 and 3.23.
Finally, the Pāhala LCC Replacement Project is not anticipated to impact emergency routes. The Draft EA Section 2.3 (Proposed Action – Site 7 Alternative) Figure 2.2 showed that the Pāʻauʻau Gulch near the hospital is located about 0.735 miles north of the wastewater treatment and disposal facility site and lies at approximately 780 feet above mean sea level (about 140 to 200
feet above the site), which means surface flows at the site would not affect the gulch. Similarly,
the Kaimani Street and Māmalahoa Highway intersection lies about 0.72 miles north of the
Final EA, Pāhala LCC Replacement Project – Appendix E
Pāhala, Ka‘ū District, Hawai‘i
February 2020 6
wastewater treatment and disposal facility site and at about 780 feet above mean sea level, which means surface flows at the site would also not affect that intersection. As stated above, the project
would not increase the risk of flooding of Māmalahoa Highway or Maile Street as it would not increase the amount of runoff. Emergency access to Ka‘ū Hospital would not be impacted as a result of the Proposed Action because flooding of the roads due to stormwater and surface flow is not expected to increase as a result of the Proposed Action. The entrance to the Ka‘ū Hospital on Kamani Street is about 3/4 mile northeast of the proposed wastewater treatment and disposal facility site.
b) Overflow of Wastewater Treatment and Disposal Facility
The wastewater treatment and disposal facility and collection system would be designed to accommodate the peak flows during design wet weather flow events, including precipitation on the area occupied by the lagoon treatment system. In the Draft EA Appendix B (Preliminary Engineering Report), Section 2.2, the anticipated peak wastewater flows from the community
provided are based on the applicable design standards. The Draft EA Section 2.3.1 (Acquire Site 7 and Construct New Secondary Wastewater Treatment and Disposal Facility) stated the lagoons would be lined with high density polyethylene liners to prevent water seepage through the bottom
and sides of the lagoons. The Draft EA Appendix B Section 5.3 showed the lagoons would have sufficient operational freeboard to contain and to equalize design flows during peak weather events. In addition, the slow-rate land application groves would be designed to completely contain
both anticipated peak wet weather effluent flows and on-site captured precipitation from a 100-year, 24-hour storm event. This would be accomplished by constructing berms around the land application tree groves. The tree groves would be designed in accordance with the EPA’s “Process Design Manual, Land Treatment of Municipal Wastewater Effluents.” Effluent would be applied at a hydraulic loading rate that is a small percentage of the percolation rate of the soil, ensuring sufficient capacity for assimilation of peak effluent flow rates and precipitation from the design storm event. Thus, the collection system, the lagoons themselves, and the land application groves would be designed to include sufficient extra capacity to limit overflows during design storm events. Due to these flood mitigation measures, no overflows would occur for storms up to
the 100-year, 24-hour storm event.
Additional information concerning the flood risk of the proposed treatment and disposal facility
and collection system has been added to the Final EA Section 2.3.1 (Acquire Site 7 and Construct New Secondary Wastewater Treatment and Disposal Facility) and 3.23 (Infrastructure – Drainage System).
2.1.2 Public Services
Comment
• Maile Street is an emergency route in and out of Pāhala. If the county fences the property, will the road be closed if there is an emergency? Will Māmalahoa Highway be closed too? (Comment 41)
Response
The fencing of the wastewater treatment and disposal facility (Site 7) would not affect emergency routes. As discussed in the Draft EA Section 3.17 (Traffic), the Proposed Action is “outside the
Māmalahoa Highway ROW and would not require any disturbance or other impacts within the Māmalahoa Highway ROW.” Maile Street would be impacted only to the extent needed for typical traffic control operations and no permanent or temporary fencing would be constructed in a way that impacts Maile Street or Māmalahoa Highway. This is also depicted in the Draft EA Figure 2.3, which shows no project elements affecting Maile Street or Māmalahoa Highway. Prior to implementing the Proposed Action, traffic control plans would be developed and approved by the
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County which would include measures to allow for emergency access during project construction. As stated in the Draft EA Section 3.17.2, the traffic control plans would provide directions to
temporarily divert traffic or close travel lanes during the construction period. Normally, such plans call for these diversions or closures during non-peak travel times to minimize disruptions to traffic flow. No long-term road closures would be needed for the Proposed Action. This information has
been repeated and clarified in the Final EA.
2.1.3 Visual Characteristics
Comment
• Why should people here in Pāhala have to see a sewage plant when entering our town? (Comment 41)
• The treatment plant will be visible during times of high winds, as the surrounding trees and foliage bend and sway. (Comment 56)
• The plant will be an eyesore at the entrance to our community. (Comments 63, 67)
Response
As discussed in the Draft EA Section 3.19 (Visual Considerations and Light Pollution), the Proposed Action is not expected to adversely affect the views or viewsheds identified in the County General Plan. Above grade structures, such as the operations building and, headworks
cover structure, would be screened by existing Cook pine trees along Maile Street, most of which would remain. The wastewater collection system would be installed below the streets and therefore would not impact views. Visual impacts would also be mitigated by the 8.0 acres of
planted trees in the disposal groves, and by the rise in elevation between the highway and the facility. Exterior lighting at the proposed wastewater treatment and disposal facility would be
designed in accordance with HCC § 14-50 and would be limited to manually switched lights under the roof overhang at the entrance to the operations/electrical building and at the headworks area. Lights would be installed with down-shielding to prevent excess light pollution. When an operator or maintenance staff are not present on-site, lights would not be on. The Final EA Section 3.19 has been revised to include that the maximum height of the wastewater treatment and disposal facility above-grade structures would not exceed 25 feet. For more information, please refer to the County responses provided to the above comments.
2.1.4 Socioeconomic
Cost of the Project
Comment
• The costs of the project are excessive and will cause economic harm of the county into
the future. The cost will be over $250,000 per LCC household. (Comment 45)
• The Pāhala project cost is excessive ($40.5 million). The cost of the project should be kept under $10 million. (Comments 45, 46)
• The cost estimates for the Pāhala WWTP Project are inaccurate. The project will cost
approximately $40 million. (Comment 51)
• The combined costs of both WWTP projects in the County are excessive. (Comment 51)
• These Wastewater Projects have become a total boondoggle. Please stop this waste of tax dollars and set a firm budget of under $10 million! (Comment 52)
• The costs of the project have skyrocketed. (Comment 61)
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• The County and Ka‘ū taxpayers cannot afford to spend $81 million the two projects. (Comment 66)
• The cost of the project is grossly underestimated. (Comment 23a)
Response
NEPA does not require a monetary cost-benefit analysis of a project, particularly where there are important qualitative considerations. See 40 CFR § 1502.23.2 In this case, the “No-Action
Alternative” would not satisfy the intended purpose and need for the Proposed Action as outlined in the Draft EA Section 2.2 (Purpose and Need for Action), which is to provide the infrastructure necessary to enable the County to comply with the Safe Drinking Water Act (SDWA) and fulfill the compliance provisions of the Administrative Order on Consent (AOC) between EPA and the County with respect to closure of the Pāhala LCCs by April 2023.3
Though not required under NEPA, planning-level cost comparisons for the Pāhala LCC Replacement Project were summarized in the Preliminary Engineering Report (see Appendix B of both the Draft EA and Final EA). The capital cost of an aerated lagoon/constructed wetland/land application treatment and disposal facility is estimated at $16 million (plus $2 million for concrete lagoon lining if required) and has an estimated annual operations and maintenance cost of $227,000. The capital cost of closure of two community LCCs and a new collection system is estimated at $14 million. These numbers represent a conceptual planning-level construction cost
estimate and do not include planning, design, land acquisition, or past project costs. Of the treatment alternatives that were deemed feasible and compared in Appendix B, the proposed
wastewater treatment and disposal facility design has the lowest estimated capital cost and estimated annual operations and maintenance cost. Thus, even if a cost-benefit analysis were performed (which is not required under NEPA), it would likely support the Proposed Action.
Information on anticipated project costs has been added to the Final EA Section 2.1.2 (Project Funding).
County Financial Capacity
Comment
• I am concerned about the impact of the Pāhala project on the credit capacity of the county
of Hawaiʻi given the diminishing tax base. Why wasn't the financial standing and debt burden of the county discussed in the DEA? (Comment 12)
• The Draft EA did not consider the economic impact of CWSRF loans on the County. (Comment 23a)
• The Draft EA has no cost analysis for borrowing funds to pay for the Pāhala project.
(Comment 27)
Response
The federal action triggering NEPA review of this project is the award of a federal earmark grant (not a loan), which would not require repayment. The County has proposed to finance the remainder of the project using funds from the Hawai‘i Clean Water State Revolving Fund (SRF),
which provides low-interest loans for the construction of publicly owned wastewater treatment
2 While the above-cited regulation applies specifically to the preparation of an EIS, the rationale behind it applies equally to the preparation of an EA. 3 In September 2019, EPA accepted the County’s request to extend the Pahala LCC closure date from June 2021 to April 2023.
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works. The SRF loan process is managed by the State of Hawaiʻi Department of Health and is outside of the scope of this NEPA analysis.
Economic Impacts on the Community
Comment
• The Draft EA did not consider the economic impact of costs on Pāhala households. (Comment 23a)
• The costs of connecting newly accessible properties will fall on many elderly residents with fixed incomes. (Comment 41)
• Pāhala is an economically depressed community with a high percentage of people on welfare, social security, pension, or other fixed income. How are they going to afford any hook up fees, maintenance fees, or any other fees that will likely come with this wastewater
treatment plant? (Comment 56)
• The county or state needs to find alternate sources of funding to cover hook-up costs for all lots within the planned project area. The expense of joining the new sewer system will
place a burden on the sensitive populations of Pāhala. (Comment 73)
• The cost of connecting the "newly accessible lots" to the new system will have a devastating financial impact on the community and could result in the loss of community support for the project. (Comment 31)
• Why are some residents paying hookup fees and others are not? Should not discriminate. (Comment 67)
• What is the cost to be on the county sewer? Residents who are not on the LCC will be penalized with enormous fees, which is a large burden to older residents on fixed incomes. (Comment 55)
• I am really upset that lots that were not hooked up to the C. Brewer system will have to pay a lot of money to hook up to the new system. Many of these lots are owned by low income or elderly people who cannot afford to hook up to the new system on their own. (Comment 42)
• Including the whole community of Pāhala in the new system places an unnecessary financial burden on both the homeowners and the County. (Comment 61)
• I have no money to hook up to the sewage plant. (Comment 37)
• The community is being divided because the County is covering costs for certain houses to be hooked up to the new system and requiring other homeowners to pay to hook up. (Comment 42)
• The costs of the two Ka‘ū projects far exceeds the taxable value of the lots to be disconnected from the LCCs. (Comment 65)
• Funding should be available for the entire project. Pāhala is a poor and poverty district, with 85% of residents retired or living on fixed incomes, limited employment opportunities. (Comment 40)
Response
The purpose of the Proposed Action is to bring the County into compliance with the SDWA by constructing an alternative means of wastewater disposal that would allow the County to close
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the existing LCCs. NEPA does not require consideration of socioeconomic impacts that are unrelated to an impact on the physical environment. See 40 CFR § 1508.14.
The Proposed Action is expected to result in the connection of 111 existing connected lots to the new collection system and wastewater treatment and disposal facility. In addition, due to their proximity to the new collection system, 65 to 66 additional lots would become accessible to the sewer. Sewer laterals to the property line would be installed as a part of this project. Under the Proposed Action, the design of the new collection system would include sewer service stub-outs to the lot lines of adjacent properties, including the newly accessible, to accommodate their eventual connection. Accordingly, to close the existing LCCs, there would be additional properties
in Pāhala that would be required to connect to the new wastewater collection system, at their expense, after it becomes operational. Such properties are near the existing service area but are presently connected to individual wastewater systems. To conform to the HCC, the respective newly-accessible property owners would be responsible for the design, permitting, and completion
of sewer service connections between the County stub-outs and improvements for stated uses on their property, as well as for the proper closure of their individual wastewater systems. It is not accurate that the whole community of Pāhala would be included in the new sewer system.
The Draft EA Section 3.16 (Socioeconomic Characteristics) provided information regarding the
socioeconomic characteristics of the Pāhala community in comparison to the County of Hawai‘i. The information for the 2012-2016 period shows the median age for Pāhala is 42.4 years,
compared to 41.8 years for the County. By age group, Pāhala shows a total of 65.7 percent less than 60 years old, compared to 74.2 percent for the County. The median household income for
Pāhala is $47,625, compared to $53,936 for the County. For Pāhala, 85.1 percent of households have an income less than $99,999, compared to 77.6 percent for the County. Overall, the Proposed Action is expected to benefit residents by providing a cleaner and longer-lasting wastewater treatment system. This information has been repeated and updated in the Final EA. The Final EA Sections 3.16 (Socioeconomic Characteristics) and 5.7 (Environmental Justice Executive Order 12898) have been updated to clarify that, despite the relatively high proportions of low-income, minority, and children residents in Pāhala compared to the County overall, the Proposed Action would not result in disproportionately high and adverse human health or environmental effects on these sensitive populations.
EPA acknowledges commenters’ concerns over hook-up fees, maintenance fees, and other potential fees. However, it is the responsibility of the County to determine how to finance their portion of the Proposed Action. Additional research and outreach regarding financing options for
residents was provided by the County in response to comments from the community. On March 21, 2019, the County held a meeting in Pāhala which included a presentation to provide information on financing options available to residents whose lots would become accessible to
the new collection system. The purpose of the meeting was to fulfill a County commitment made in October 2018 to research financing options available to the newly accessible residents of the
Pāhala community by March 2019. This information has been included in the Final EA Section 7 (Public Participation).
Sources of Funding
Comment
• Did C Brewer give the County funding? (Comment 67)
• No consideration has been given of other funding types for the project. (Comment 23a)
• Should the County of Hawai‘i fund the whole project, including hook ups? (Comment 67)
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Response
The Draft EA Section 2.1.2 (Project Funding) discussed the two funding sources that would be
used to support the Pāhala LCC Replacement Project: an EPA Special Appropriations Act Project (SAAP) grant and Clean Water State Revolving Funds. An EPA SAAP grant was awarded to the County in 2005, and subsequently amended. The total amount of the award is $1.842 million.
The second source of funding for the project is the Hawai‘i Clean Water State Revolving Fund. The Hawai‘i Clean Water State Revolving Fund receives annual funding from the EPA, which the State of Hawai‘i Department of Health is then responsible for allocating among eligible projects. The Final EA Section 2.1.2 has been updated to include additional information about this source of funds.
As stated previously, the proposed project is expected to result in some costs to owners of lots that become accessible to the new wastewater collection system. A discussion of the County’s efforts to identify additional financing options for homeowners to pursue can be found in the
section above (Economic Impacts on the Community). The Final EA Section 3.16 (Socioeconomic Characteristics) has been updated with this information.
Please refer to the Draft EA Section 2.1.4 (History of Wastewater Management in Pāhala) for a
discussion of C. Brewer’s involvement. Additional information has been added to the Final EA Section 2.1.4 for clarity.
2.1.5 Archeological and Cultural Resources
Comment
• The proposed plant may be located in proximity to an archeological or burial site.
(Comment 33)
• There are burials and caves within the proximity of proposed site. Community members
have witnessed seeing the caves and burials. It was deemed a site not to be used by the County back in 2008. (Comment 41)
• There are cultural and historic resources, including caves and bones, at the site.
(Comment 42)
• There are many caves and unrecorded burial sites in Pāhala. There needs to be a thorough EIS, and in-depth testing, not just surface testing that was done, to document any archeological findings. (Comment 56)
• Lava tubes and burials were identified during previous development projects in Pāhala. No subsurface testing for these resources was completed on the site, and these areas could be affected during development or flooding of the site. (Comment 67)
• Possible burial sites are suspected to be present on or near the site. (Comment 68)
• Concerned about use of the current site due to the presence of historically sensitive areas. Elders should be consulted about these resources. (Comment 73)
• The location of the burial cave (believed to be in the southeastern corner of the site) should be ascertained and this area protected. Once the location of the cave has been identified,
consultation with descendants, SHPD, and the Hawaiʻi Island Burial Council can be
completed to determine appropriate physical buffers for the facility. It is very important to ascertain that the burial cave is located at a higher elevation than the proposed facility to ensure that the cave is not subjected to contact with treated or untreated wastewater. (Comment 74)
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Response
As discussed in the Draft EA Section 3.15.1(a) (Archeological and Cultural Resources – Existing
Conditions), after consultation with the State Historic Preservation Division (SHPD), the County initiated an Archeological Inventory Survey (AIS) to “fully document, map, date and collect [any] surface artifacts” located at the proposed site. An AIS plan was approved by the SHPD on August
20, 2018.
Since the publication of the Draft EA, the Draft AIS for the Pāhala Wastewater Treatment Plant and Sewer System Project was completed and submitted to the SHPD on March 11, 2019, for review. The AIS was generated based on a literature review and research, pedestrian surveys, and subsurface testing. The AIS report did not identify any pre-Contact features or lava tubes within the project area. The AIS report referenced the findings of a November 2016 survey which did identify a known lava tube access within former plantation land to the east of and outside of the treatment and disposal facility project site, and just north of Māmalahoa Highway that has
been blocked. No impacts to this lava tube are expected since it is located outside of the treatment and disposal facility project site. The Draft EA Section 2.3.1 (Acquire Site 7 and Construct New Secondary Wastewater Treatment and Disposal Facility) stated the aerated lagoons would be
lined with high density polyethylene liners to prevent water seepage through the bottom and sides of the lagoons. Thus, untreated wastewater would not enter the ground beneath the wastewater treatment and disposal facility.
To determine the location of the lava tube that may be what is referenced by commenters, the County sent a follow-up letter to Commenter 40, the Pele Defense Fund, requesting information about the known lava tubes in the project area via email to the address from which the comment was submitted and via certified mail on November 14, 2018 but received no response.
Overall, the AIS results supported a determination of “no historic properties affected” by the proposed project. This information is updated in the Final EA Section 3.15 and the Draft AIS report
has been included as an Appendix to the Final EA.
Consultation regarding historic properties has been completed according to applicable laws and regulations. The Draft AIS report was provided to SHPD in accordance with the requirements of the National Historic Preservation Act (NHPA) and was made available to the public by the EPA on June 5, 2019 through a publicly available web posting on the project page for the Pāhala
project (see: https://www.epa.gov/uic/proposed-Pāhala-community-large-capacity-cesspool-replacement-project-draft-environmental). In the AIS, the area of potential effect was determined to be 57.7 acres and includes the following:
1. The 14.9-acre wastewater treatment plant (WWTP) site, within which all project-related staging, including for the collection system and the treatment and disposal facility, will be located;
2. An approximately 1,500-foot (ft) long by 25-ft wide utility easement (about 0.94 acres) located entirely within Tax Map Key (TMK) [3] 9- 6-002:018 to connect the collection system line and other utilities to the WWTP;
3. The path of the new sewer collection lines, to be located within the 22- to 24-ft wide travel surface of select county streets;
4. Sewer line easements of similar width (22-24 ft) through TMKs [3] 9-6-005:036 and 044
connecting the collection lines to the proposed Pāhala WWTP site;
5. The existing LCC 1 and 2 locales (located in TMKs [3] 9-6-002:016 and 9-6-016:041, respectively), and an approximately 100-m (328-ft) long by 15-m (49-ft) wide corridor along
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the existing sewer line easement in TMK [3] 9-6-002:016 between Maile Street and LCC 1; and
6. Numerous single-family residential/other properties with existing sewer laterals, some of which may need to be replaced/repaired/rehabilitated by the County.
In accordance with the NHPA (36 CFR § 800.4(d)), EPA reached a finding of no historic properties affected for this undertaking and requested SHPD concurrence with this determination on September 26, 2019. No response from SHPD has been provided to date. In accordance with 36 CFR § 800.4(d)(1)(i) and as specified in the September 26 letter, because no response was received within 30 days of SHPD receipt of the adequately documented finding, EPA has fulfilled their Section 106 responsibilities for this undertaking. However, construction would not proceed until SHPD has approved the Draft AIS.
Though pedestrian surveys were conducted throughout the APE to identify potential lava tubes and none were visually observed at the site, the AIS was not able to conclusively establish that
lava tubes are not present within the area surveyed as part of the AIS. Therefore, in addition to the field methodology presented in the AIS, and to limit ground disturbance, the County is in the process of performing Ground Penetrating Radar and soil resistivity surveys as part of the project
design phase, and would adjust the final design of the Proposed Action as needed to mitigate impacts to any potential lava tubes identified as a result of these surveys. The discussion in the Final EA Section 3.3 (Geology) has been updated to reflect this.
The Hawaiʻi Island Burial Council was consulted as part of the Draft EA preparation process. As stated in the Draft EA Section 3.15 (Archeological and Cultural Resources), on March 29, 2018, the County also conducted outreach to Native Hawaiian Organizations as part of the Section 106 consultation for this project. Consultation letters were delivered to invite comments from organizations that may attach religious or cultural significance to properties affected by the Proposed Action. A total of 14 letters were mailed to various Native Hawaiian Organizations requesting comments (see the Draft EA Section 10); no responses have been submitted to the County. In addition, outreach for the Draft EA included talk story sessions that were open to all members of the public, including elders.
On September 26, 2018, a public notice was published in the Hawaii Tribune Herald and West Hawaii Today newspapers to advertise that on October 10, 2018, a public information meeting
was to be conducted by the County in Pāhala at the Ka‘ū Gym Multi-Purpose Conference Room to discuss the Draft EA and that a second part of the meeting would also address Section 106 of NHPA. Although eight persons signed in to comment on Section 106, no comments or information
were forthcoming regrading Section 106 during the October 10th meeting. This information is included in the Final EA Section 7 (Public Participation) and Section 3.15.
It is not true that the site of the Preferred Alternative (Site 7) was “deemed a site not to be used
by the County back in 2008.” It appears that the commenter is referring to the 2007 Nāʻālehu and
Pāhala LCC Conversion project Final EA (the “2007 Final EA”), which evaluated a proposed project to install septic tanks to replace the existing LCCs. The 2007 Final EA did not evaluate
Site 7 as an alternative location for the septic tank project and did not identify it as a site “not to be used by the County.”
2.1.6 Air Quality
Comment
• Residents of Pāhala have a high rate of asthma and studies have shown that there are
negative impacts on residents who live next to a sewage plant. Not only do we have the
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chemicals left in the ground by C, Brewer, we have the dust and chemicals from the Macadamia Nut Co. and the vog from Tutu Pele. (Comment 41)
• The smell of the facility is a concern. (Comments 33, 56, 67, 68)
• The treatment plant could cause an increase in harmful airborne bacteria. (Comment 67)
Response
Odor and smell impacts were addressed in the Draft EA Section 3.14.2(a) (Air Quality – Impacts
and Mitigation Measures) which stated “to mitigate potential nuisance odors, the headworks [of the wastewater treatment and disposal facility] would be equipped with an odor control system with a GAC scrubber to remove odor […] the treatment lagoons would be equipped with
mechanical aerators capable of maintaining sufficiently aerobic (with oxygen) conditions within the water column, which would prevent nuisance odor conditions from occurring” under normal operating conditions. This information has been repeated in the Final EA.
For other air quality impacts, the design and operation characteristics of the new wastewater treatment and disposal facility would limit pathways for off-site migration of aerosols. As stated in the Draft EA Section 2.3.1 (Acquire Site 7 and Construct New Secondary Wastewater Treatment and Disposal Facility), the lagoons would be equipped with high-speed floating aerators. The plant design would not result in migration of aerosols outside of the site boundaries. The land application system would use a piping system with slots at ground level to distribute treated and disinfected wastewater; because this process distributes disinfected water and does not create an aerosol, risk of exposure to pathogens through inhalation is minimal.
Furthermore, the wastewater treatment and disposal facility would be located at least 0.5 miles away from the developed area of the community, which provides a buffer to mitigate potential concerns associated with nuisance odors or aerosol migration that could arise outside of normal
operating conditions.
2.1.7 Other Impacts
Comment
• Is this project going to affect the whole community? (Comment 62)
• Will outside community waste be transported into Pāhala? (Comment 67)
Response
In the Pāhala community, between 176 and 177 lots would be affected directly by the new collection system of the Proposed Action (111 lots on the existing LCC system and 65 to 66 newly accessible lots). This information has been revised in the Final EA Section 2.3.2 (Construct New Wastewater Collection System). The collection system and the treatment and disposal facility are
to serve only the Pāhala community.
Comment
• The sewer will attract pests. (Comment 67)
Response
The existing wastewater collection system is an aging system that has flaws and cracks that can
provide access to pests such as rats and cockroaches. When the new collection system is installed, the existing system would be abandoned, and the subsequent lack of use would reduce available habitat and pest food sources. The new collection system would be more resistant to
Final EA, Pāhala LCC Replacement Project – Appendix E
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developing cracks and openings, resulting in fewer opportunities for pests to access the sewer as compared to existing system.
Closure and abandonment of the existing LCCs would eliminate potential pest attractants. In addition, the wastewater treatment and disposal facility would be located farther from the Pāhala community than the existing LCCs, thus conveying sewage to a facility that would incorporate design elements and operation practices to reduce attractiveness to pests. These design elements and operation practices would include features such as appropriate removal and management of waste from screening mechanisms to reduce food sources; use of aerators in lagoons to agitate water sources that otherwise could attract mosquitoes; and intermittent dosing of effluent to avoid standing water in groves. The Proposed Action would not be expected to contribute to pest-related concerns in Pāhala. This information is included in the Final EA Section
3.13 (Fauna).
Comment
• The current site location causes concerns about impacts in the event of a natural disaster. Topics to be addressed include developing a hazard plan, response to fires and spills resulting from pump failure, and assuring sources of power and water at the site. (Comment 67)
Response
As stated in the Draft EA Section 3.4 (Seismic Hazard), the wastewater treatment and disposal facility would be designed and constructed to meet the requirements of the International Building Code, 2006 Edition (IBC) as specified in 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, emergency generator diesel fuel, or disinfection chemicals from the facility during a seismic event. Hazards related to hurricanes, such as wind, rain, and flood loads, would be taken into account during detailed design. In addition, the treatment processes would be appropriately designed to have capacity to accommodate upset conditions, including pump and other equipment failures by use of back-up generator for power
as described below, alarm conditions for operators and a communication system.
Information pertaining to fire systems, water supply, and electrical systems is located in the Final EA Sections 3.21 (Public Services – Fire Protection), 3.22 (Infrastructure – Water System), and
3.24 (Infrastructure – Electrical and Communication Systems), respectively. As explained there, fire protection and related services would be provided to the treatment facility from a fire station
located in Pāhala, and the treatment and disposal facility would include a fire protection line sized as required during design to be used in the event of a fire. Department of Water Supply and the Fire Department would have an opportunity to review construction plans for the Proposed Action
during the project design phase. All alternatives would be designed according to 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 Site 7 would be designed to comply with Chapter 18 of NFPA 2006 Uniform Fire Code as amended by the County of Hawai‘i. This information is included in the Final EA Sections 2.3.1 (Acquire Site 7 and Construct New Secondary Wastewater Treatment and Disposal Facility) and
3.22.
Water service does not currently exist at Site 7. Water for the proposed wastewater treatment and disposal facility would be provided by extending the existing water main operated by the County of Hawaiʻi DWS (located approximately 2,000 feet northeast of the proposed wastewater treatment and disposal facility) and by installing a service line to connect the new facility to that extended water main. The proposed site (Site 7) was deemed preferable to two other sites
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considered (Sites 8 and 9) because, among other reasons, potable water and fire protection lines would need to be extended further to reach the latter two sites. Operation of the sewer system
would not require a water source external to the proposed treatment and disposal facility. As stated in the Draft EA Section 3.22.2, construction plans would show the estimated maximum daily water usage calculations prepared by a professional engineer licensed in the State of
Hawaiʻi. After review of the calculations, DWS would determine if enough water is available and a water commitment could be issued.
It is anticipated that electrical power would be provided by Hawaiʻi Electric and Light Company (HELCO) overhead power lines and a pole-mounted transformer. Backup power would be provided by a diesel generator and aboveground fuel tank with capacity to support three consecutive days of operation. In addition, the electrical service panel would support a connection to a portable trailer-mounted generator in the event of a power outage lasting longer than three days. This information has been repeated in the Final EA Section 3.24.
2.2 NEPA Processes
Responses to comments regarding the federal NEPA process for the Proposed Action have been arranged into the following categories:
• Purpose and Need
• Scope of Proposed Action
• Cumulative Effects
• Federal and State Consultations
• NEPA Procedures
2.2.1 Purpose and Need
Comment
• Why does the small community of Pāhala need a wastewater treatment plant (WWTP)
when other communities have larger populations and are growing in size? (Comment 56)
• Why was the Pāhala community chosen to have the cesspool conversion done by 2021 when the rest of the state has until 2050? (Comment 67)
• If this is truly a means for Hawai‘i County to avoid fines from the federal government for
the LCC violations, then that is what the focus of the proposal should be about. (Comment 61)
Response
As described in the Draft EA Section 2.1.3 (Large Capacity Cesspools), the two cesspools serving
Pāhala community meet the criteria of being LCCs under federal law since they each serve multiple dwellings. These LCCs are in violation of the SDWA as long as they continue to operate. The SDWA Underground Injection Control (UIC) Program prohibited the construction of new LCCs as of April 2000 and required the closure of all existing LCCs by April 5, 2005 (see 40 CFR
§ 144.88). In order to close the LCCs serving the Pāhala community and comply with federal law, the County needs to develop an alternate means of wastewater treatment for those homes and buildings that are currently connected to the LCCs.
It is not true that the rest of the state has until 2050 to close LCCs—all LCCs across the nation, including those in the Pāhala community, were required under federal law to be closed by 2005. In referencing 2050, it appears that the commenter is referring to a Hawaiʻi state law that was
Final EA, Pāhala LCC Replacement Project – Appendix E
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passed in 2017 that requires the closure of all cesspools (LCCs and small capacity cesspools) by 2050. Unlike LCCs, which serve multiple dwellings and/or have the capacity to serve 20 persons
or more per day, small capacity cesspools typically serve individual homes and are not regulated under federal law. This information has been clarified in the Final EA Section 2.1.3.
EPA and the County entered into an AOC in June 2017 since the County continued to operate the Pāhala LCCs after the 2005 closure deadline and after assuming ownership of the system from C. Brewer in 2010. This Administrative Order included an enforceable schedule for the County to close the Pāhala LCCs in order to bring the County into compliance with federal law. Because the LCCs cannot be closed until an alternate means of wastewater disposal is constructed, the schedule for closure of the LCCs included in the Administrative Order was developed based on the County’s estimate of the amount of time required to design and build a
replacement means of wastewater disposal.
After careful review of different alternatives for wastewater treatment and disposal (see Section
2.5.4 (Treatment Alternatives) of this Appendix and the Final EA Section 2.8 (Alternatives Considered but Not Carried Forward)), the County identified the most appropriate solution given the community requirements as well as applicable Federal, State, and County regulations
governing wastewater disposal systems. The wastewater treatment and disposal facility would be sized appropriately for the Pāhala community, based on the number of lots that would be connected to the new facility through the Proposed Action (anticipated to be approximately 176
to 177 lots), and wastewater flow projections for these lots, as determined by code. The size is also determined by the use and zoning of the lots and includes a standard allowance for industrial lots. For more information on the sizing of the proposed wastewater treatment and disposal facility, see Section 2.4.3 (Hawaiʻi Department of Business, Economic Development and Tourism, Land Use Commission (LUC)) of this Appendix.
Comment
• There is no data to prove Pāhala community at status quo shows an impact in ground water contamination. (Comment 67)
Response
The purpose of, and need for, the project is to close the LCCs serving the Pāhala community in order to bring the County into compliance with federal law, and to prevent potential impacts to
public health and the environment that may be caused by discharging untreated sewage into the ground in a residential neighborhood. Regulations promulgated under the SDWA required the closure of all LCCs nationwide by no later than April 2005. There is no requirement under these regulations to show actual impacts to groundwater. This is because the SDWA is designed to prevent endangerment of drinking water before it occurs—thus, to comply with the SDWA, the
regulations require closure of all LCCs. The Draft EA Section 3.8.2 (Ground Water – Impacts and Mitigation Measures) stated that while use of the two 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 and bring the facility into compliance with the SDWA. Abandonment of the existing wastewater collection system would not affect groundwater within the affected areas. This information is repeated in the Final EA Section 3.8.2.
2.2.2 Scope of the Proposed Action
Comment
• The failure to consider aggregated and cumulative effects of the Pāhala and Nāʻālehu projects is legally unacceptable. These two projects should be analyzed in a single impact
Final EA, Pāhala LCC Replacement Project – Appendix E
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statement because of the connected nature and possible cumulative impacts of the projects. (Comment 4)
• The Pāhala and Nāʻālehu projects should be considered together. (Comment 16)
• The Pāhala and Nāʻālehu projects were separated to evade NEPA review. The Pāhala project is violating NEPA procedural requirements. (Comment 23a)
• NHPA Section 106 consultation should have been conducted for both the Pāhala and
Nāʻālehu projects together. (Comment 65)
• Demoruelle v. Beck evidence of misconduct in following NEPA/HEPA. (Comment 75)
Response
NEPA defines actions as connected if they satisfy any of the following criteria:
i. Automatically trigger other actions which may require environmental impact statements
(EISs).
ii. Cannot or will not proceed unless other actions are taken previously or simultaneously.
iii. Are interdependent parts of a larger action and depend on the larger action for their justification. [40 CFR § 1508.25]
The proposed Pāhala LCC Replacement Project does not meet any of the above criteria. The
proposed Pāhala LCC Replacement Project does not automatically trigger other actions which may require an EIS and is a stand-alone project which does not rely or depend on any other project. Therefore, the proposed Pāhala LCC Replacement Project is not considered connected
to the Nāʻālehu Large Capacity Cesspools Closure Project (Nāʻālehu Project) for purposes of NEPA.
As stated in the Final EA Section 2.9 (Relationship to 2007 Final Environmental Assessment), in 2007 the County elected to evaluate the two projects in a single environmental review document under HRS 343 because at that time, both projects were expected to proceed along the same timeline and both were expected to be funded under the EPA SAAP grant. The County decided to not move forward with the proposed project as evaluated under that process for several reasons which are also described in the Draft EA Section 2.9.
Since then, the grant workplan for the EPA SAAP grant has been amended to include only the Pāhala community - LCCs Replacement Project. This decision was made based on two points: 1) the federal grant funds would only cover a portion of one of the projects and 2) it was expected
that the Pāhala LCC Replacement Project could be completed faster than the Nāʻālehu Project, and there was therefore a lesser likelihood that funds associated with the grant would be de-obligated before they could be spent. Consequently, the Nāʻālehu Project will not receive any
funding under the EPA SAAP grant.4
The funding of the Pāhala LCC Replacement Project under the SAAP grant is considered a federal action that requires environmental review under NEPA. Because funding from the EPA
SAAP grant is allocated to the Pāhala LCC Replacement Project, and because the Nāʻālehu Project is not a connected action, it is not appropriate to include the Nāʻālehu Project as part of the Proposed Action examined in the Pāhala LCC Replacement Project EA. The EPA did consider the potential cumulative effects of other past, present, and reasonably foreseeable actions
4 In 2011, EPA reimbursed the County for approximately $113,000 for preliminary designs for the
Nāʻālehu Project. The Nāʻālehu Project will be completed with County and State funds and will not receive any additional EPA SAAP grant funds.
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(including the Nāʻālehu Project) as required by NEPA in the Draft EA Section 4 (Cumulative Effects) and additional information is included in Section 2.2.3 (Cumulative Effects) of this
Appendix.
The two projects are also considered separate for purposes of the National Historic Preservation Act (NHPA). Section 106 of the NHPA requires federal agencies to take into account the effects of federal undertakings on historic properties (see 40 CFR § 800.1(a)). Specifically, agency officials must assess whether historic properties occur within the “area of potential effect” for the project, and if so, whether they would be impacted by the project. NHPA regulations provide that agency officials should engage in consultation with the appropriate state historic preservation officer and consulting parties in order to determine whether the proposed project is expected to result in impacts to historic properties.
EPA and the County engaged in the NHPA Section 106 consultation process for the Pāhala LCC Replacement Project and determined the area of potential effect for the project did not extend
outside the Pāhala area as described in Section 2.1.5 (Archeological and Cultural Resources) of this Appendix. Because Nāʻālehu is located 11 miles from Pāhala and is well outside of any area expected to be affected by the Pāhala LCC Replacement Project, the Nāʻālehu Project was not
considered as part of the Pāhala LCC Replacement Project Section 106 consultation process. The Final EA Section 3.15 (Archeological and Cultural Resources) has been updated with additional information regarding the NHPA Section 106 Consultation process.
In accordance with state requirements, the Nāʻālehu Project would undergo a similar consultation process to assess potential impacts on historic properties as part of the separate environmental review for that project.
2.2.3 Cumulative Effects
Comment
• The project is evading NEPA requirements by not considering the cumulative impacts (including economic impacts on county with decreasing tax base) of both the Pāhala and
Nāʻālehu projects. (Comment 1)
• The project is evading NEPA and crosscutting environmental review requirements by not considering the cumulative impact of both the Pāhala and Nāʻālehu projects. (Comment
2)
• The failure to consider aggregated and cumulative effects of the Pāhala and Nāʻālehu
projects is legally unacceptable. These two projects should be analyzed in a single impact statement because of the connected nature and possible cumulative impacts of the projects. (Comment 4)
• The Pāhala and Nāʻālehu projects should be considered together. (Comment 16)
• The cumulative impacts of the Pāhala and Nāʻālehu projects need to be considered together in one EIS. (Comment 23a)
• The cumulative impacts of the Pāhala and Nāʻālehu WWTPs need to be considered. (Comment 27)
• The County and EPA have avoided consideration of the impacts of the Nāʻālehu Project
on the Pāhala WWTP. (Comment 43)
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Response
The community of Nāʻālehu is located approximately 11 miles from Pāhala. As stated in the Draft
EA Section 4 (Cumulative Effects), “due to its distance from Pāhala, the effects of [the Nāʻālehu Project] are not expected to have a significant cause-and-effect relationship with the direct and indirect effects of the Proposed Action.” The Nāʻālehu Project is undergoing separate community outreach and environmental review processes that have not yet been completed and therefore very little information regarding the impacts of that project is publicly available. However, information has been added to the Final EA Section 4 relating to the potential for cumulative effects between this project and similar construction projects within the Ka‘ū district. Please refer to Section 2.2.5 (NEPA Procedures) of this Appendix for a discussion of why an EA was prepared rather than an EIS for the Proposed Action. The Nāʻālehu Project is not the subject of this EA.
2.2.4 Federal and State Consultations
Section 7, Endangered Species Act (ESA)
Comment
• EPA has failed to comply with the Endangered Species Act (subject of attached legal documents). (Comment 4)
• The Project is in violation of the ESA and is causing concrete harm to the citizens of
Hawaiʻi. (Comment 14)
• The Project is in violation of environmental statutes and regulations including the Endangered Species Act. (Comment 14)
• COHDEM and its contractors are avoiding Section 7 consultation under the ESA for the
Pāhala project. (Comment 57)
Response
The EPA has fulfilled its consultation requirements under Section 7 of the Endangered Species Act. A biological field survey was performed in August 2018 for the proposed wastewater collection system and the preferred site (Site 7) for the wastewater treatment and disposal facility. The field study did not identify any species of plants or wildlife that are currently listed or proposed for listing as threatened or endangered species under Federal or State of Hawai‘i laws, and determined that Federally delineated Critical Habitat is not present in the Pāhala area. EPA initiated informal consultation with the U.S. Fish and Wildlife Service (USFWS) by letter dated
December 21, 2018. The EPA received concurrence from the USFWS on February 15, 2019 that the project is not likely to adversely affect federally listed threatened or endangered species. A full discussion of the Section 7 consultation efforts and actions is included in the Final EA Sections
3.12 (Flora), 3.13 (Fauna), and 5.6 (Endangered Species Act).
Section 106, National Historic Preservation Act (NHPA)
Comment
• The NHPA Section 106 consultation for the Pāhala project is not valid because the
Nāʻālehu project was not also considered. The consultation was also done hastily and
without proper publication of notice. (Comment 65)
• The federal Section 106 and the Cultural Assessment of the Draft EA are inadequate.
(Comment 40)
• Local Hawaiian groups and individuals were not pre-consulted before the Section 106. (Comment 65)
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• EPA failed to reach out to local Hawaiian organizations. The following should be consulted (list of suggested affected organizations attached). (Comment 7)
Response
On March 8, 2018, the EPA notified all Native Hawaiian Organizations (NHOs) in the Pāhala area that the County had been authorized to act in EPA’s behalf when initiating consultation under 54 U.S.C. § 300101 and 36 CFR §800.2(c)4 for the Pāhala Large Capacity Cesspool Replacement Project. The County conducted consultation outreach to NHOs by directly contacting the federally recognized Native Hawaiian organizations listed in the Draft EA Section 10 (Consulted Parties). As stated in the Draft EA Section 3.15 (Archeological and Cultural Resources), consultation letters were delivered to invite comments from organizations that may attach religious or cultural significance to properties affected by the Proposed Action. The selection of NHOs for this outreach was developed using the U.S. Department of the Interior, Office of Native Hawaiian Relations, Native Hawaiian Organization Notification List (Updated December 4, 2017). Letters
requesting comments under Section 106 Consultation (54 U.S.C. § 32706) were sent to a total of 14 NHOs on March 29, 2018. No responses were submitted to the County.
On September 26, 2018, a public notice was published in the Hawaii Tribune Herald and West
Hawaii Today newspapers. The public notice was to advertise the October 10, 2018 public information meeting that was to be conducted by the County in Pāhala at the Ka‘ū Gym Multi-
Purpose Conference Room to discuss the Draft EA. The notice stated the second part of the meeting would address Section 106 of the National Historic Preservation Act of 1966, as amended (2006). It was meant to involve consultation with NHOs and the Native Hawaiian descendants with ancestral lineal or cultural ties to, cultural knowledge or concerns for, and cultural religious attachment to the proposed project area. A Section 106 sign-in sheet was provided to those wishing to provide comments. No comments were made during the October 10, 2018 public
information meeting. This information is added to the Final EA Section 7 (Public Participation).
As explained in the Final EA, EPA has concluded Section 106 consultation with a determination of “no historic properties affected” by the Preferred Alternative. This information is updated in the
Final EA Sections 3.15 and 5.14 (National Historic Preservation Act).
The area of potential effect for the Pāhala LCC Replacement Project does not extend to Nāʻālehu, which is approximately 11 miles from Pāhala, meaning that there is no potential for the Pāhala
LCC Replacement Project to impact historic properties in Nāʻālehu. The Nāʻālehu Project would go through a separate consultation process for historic properties in accordance with state
requirements. Additional explanation for why these projects are considered separately is included in Section 2.2.2 (Scope of the Proposed Action) of this Appendix.
Please see Section 2.1.5 (Archeological and Cultural Resources) of this Appendix for further
details on the Section 106 consultation for the Pāhala LCC Replacement Project. The Final EA Sections 3.15 and 5.14 have been updated to include additional information on the NHPA Section 106 Consultation process.
Other Agency Coordination
Comment
• The Hawaiʻi Department of Education (HIDOE) requests consultation and coordination with the Facilities Development Branch, Public Works as early as possible to ensure a timely connection to the new collection system and closure of the on-site septic system.
(Comment 72)
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• The HIDOE requests consultation and coordination with the school and the HIDOE Transportation Services Branch Manager to minimize construction and traffic impacts to the school such as noise, fugitive dust and HIDOE transportation of students. (Comment 72)
Response
The Ka’ū High and Pāhala Elementary School, including the Ka’ū District Gym and Shelter, would become accessible to the proposed County sewer system with the installation of two new laterals at the property line on Hala Street and Kamani Street. While typically only a single lateral is provided for a lot, the additional lateral on Hala Street is being installed to accommodate the project and create a gravity flow connection. This information is included in the Final EA Section 2.3.2 (Construct New Wastewater Collection System). Impacts and mitigation measures for addressing construction-related dust, traffic, and noise are addressed in the Draft EA Sections 3.14 (Air Quality), 3.17 (Traffic), and 3.18 (Noise). The County would provide
information about the construction schedule for the treatment and disposal facility and the collection system to the Facilities Development Branch Public Works Administrator on request.
Further, the County would coordinate with the HIDOE Student Transportation Services Branch Manager and the School in order to minimize construction-related impacts to student transportation services. Please refer to the County response to Comment 72 for further
information.
Comment
• I request consulting party status under NEPA and Hawaiʻi Environmental Policy Act
(HEPA) and all cross-cutting statutes. (Comment 4)
• I was not allowed to be a consulting party. I could have advised EPA and COH on proper procedures, but was never asked for my opinion or assistance. (Comment 65)
Response
A “consulting party” is a defined term specific to the NHPA that does not otherwise have meaning under NEPA. On October 19, 2018, EPA sent a letter to the commenter (Comment 4) indicating that, based on the information provided, the commenter did not meet the criteria for a consulting
party under the NHPA. In addition, HRS 343 and HAR 11-200 have no requirements or definitions related to consulted party status for an EA.
All interested members of the public were invited to provide comments on the Draft EA and to
attend the public information meeting on October 10, 2018. The public information meeting was
conducted by the County in Pāhala at the Ka‘ū Gym Multi-Purpose Conference Room to discuss the Draft EA. This was immediately followed by a second meeting addressing Section 106 of the
NHPA. A Section 106 sign-in sheet was provided to those wishing to provide comments.
2.2.5 NEPA Procedures
Comment
• The two Ka‘ū WWTP projects are proceeding in violation of NEPA and HEPA. No EIS has been prepared or submitted for publication, and statutory and regulatory procedures for
public participation have not been followed. (Subject of forwarded legal documents) (Comment 16)
• All wastewater systems with treatment units in Hawaiʻi have had an EIS. The Pāhala project is intentionally evading this process. (Comments 15, 18, 53)
• A combined EIS for the Ka‘ū LCC Closure Project should be provided. (Comment 38)
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Response
EPA determined that an EA is the appropriate evaluation for the proposed Pāhala LCC
Replacement Project because this federal action is not expected to significantly affect the quality of the human environment within the meaning of NEPA. It is not accurate that an EIS is prepared for all wastewater systems or wastewater treatment units in Hawai‘i. As described in EPA NEPA implementing regulations, types of actions that normally require the preparation of an EA include “certain grants awarded for special projects authorized by Congress through the Agency’s annual Appropriations Act.” See 40 CFR § 6.205(b). An EIS, on the other hand, is normally prepared for new regional wastewater treatment facilities or water supply systems for a community with a population greater than 100,000 (See 40 CFR § 6.207). As stated in the Draft EA Table 3.1, the total population of Pāhala is 1,341. The Pāhala LCC Replacement Project does meet the definition of a project normally requiring preparation of an EA and does not meet the definition for a project normally requiring preparation of an EIS.
Moreover, as described in the Draft EA and the Preliminary Finding of No Significant Impact (FONSI), the Pāhala LCC Replacement Project is not expected to significantly affect the quality of the human environment. As such, an EA is the appropriate vehicle for environmental review of
this project, and no EIS is required.
Additional information concerning applicable public outreach requirements and EPA and County compliance with such requirements is available in Section 2.3.1 (Outreach) of this Appendix, and
in Final EA Section 7 (Public Participation). Information concerning the separation of the Nāʻālehu Project and Pāhala LCC Replacement Projects can be found in Section 2.2.2 (Scope of the Proposed Action) of this Appendix.
HRS § 343-5(a)(9)(A) states that “(a) Except as otherwise provided, an environmental assessment shall be required for actions that: (9) Propose any: (A) Wastewater treatment unit, except an individual wastewater system or a wastewater treatment unit serving fewer than fifty single-family dwellings or the equivalent…” For further discussion on the appropriateness of an EA for purposes of HRS 343, please refer to the County response to Comment 15.
Comment
• The EPA and County are making an "irrevocable commitment of resources" to build the
Pāhala and Nāʻālehu plants. (Comment 23a)
• The project has taken "irrevocable siting action" before the environmental review is complete. (Comment 23a)
• The two WWTP projects in Ka‘ū are costing Hawaiʻi taxpayers at least $23,340,000 because the meter is now running and COHDEM has their contracts already in place.
(Comment 52)
Response
Neither EPA nor the County has made an irrevocable commitment of resources to the Pāhala
LCC Replacement Project other than those required for planning and review of the project. As explained in both the Draft and Final EA, multiple sites and treatment technologies were evaluated for the Proposed Action, and a secondary wastewater treatment and land disposal system was deemed to satisfy the purpose and need for the Proposed Action (i.e., to close the LCCs in compliance with the SDWA by providing an alternate means of wastewater disposal). A
Preliminary Engineering Report was prepared in order to facilitate both a comparison of different wastewater treatment systems and a discussion of site selection considerations. Property has not yet been acquired for the project, however, and final design of the facility has not been completed.
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As such, there has been no irrevocable siting action or commitment of resources associated with the project.
Additional information on the County’s commitment of resources to this project is included in the County response to Comment 23a.
2.3 Public Involvement and Outreach
Responses to comments regarding public involvement and outreach have been arranged into the following categories:
• Outreach
• Accessing the Draft EA
• Public Information Meeting Comments
• Nāʻālehu - Pāhala Large Capacity Cesspool (LCC) Conversion Project – 2007 Final EA
Comments
• Public Agencies
2.3.1 Outreach
Comment
• The community is concerned about the condemnation of property. (Comment 67)
Response
The Preferred Alternative wastewater treatment and disposal facility site (Site 7) is currently
owned by B. P. Bishop Estate Trustees (commonly known as Kamehameha Schools). Kamehameha Schools has agreed to transfer a portion of the property for the purpose of building the wastewater treatment and disposal facility, and legally it can transfer the property to the County through a condemnation proceeding. Thus, while the Preferred Alternative would involve condemnation of property, it would only be used to acquire Site 7. The County intends to purchase easements necessary to close the LCCs and construct the collection system. Apart from this specific property, the Preferred Alternative is not anticipated to result in the condemnation of additional private property.
Comment
• The COHDEM refuses to provide Pāhala meeting records (attendees, agenda, outcomes)
or Pāhala environmental review records (except the PER and Draft EA) to the local libraries or online. (Comment 23a)
Response
EPA has fulfilled NEPA requirements for outreach and document availability/review by making the Draft EA available to the public for review and comment. The Draft EA Section 7 (Public Participation) included summaries of the talk story sessions and outcomes of these meetings. In
addition, though not required to do so, EPA has made key documents related to the project continuously available through its website (https://www.epa.gov/uic/proposed-pahala-community-large-capacity-cesspool-replacement-project-draft-environmental). Furthermore, there is no
requirement to publish notices of public meetings in the Office of Environmental Quality Control (OEQC) The Environmental Notice. OEQC may publish such notices on a space available basis. Finally, all project-related documents that have been released to any person under the Freedom
of Information Act (FOIA) are available through the centralized FOIA Online system.
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Comment
• Resident Edward Andrade should have been consulted as he was the manager of the C. Brewer Sewage system for years. (Comment 41)
Response
All members of the Pāhala community were welcome to attend the five talk story sessions held in December 2017 prior to the release of the Draft EA; to provide comments on the Draft EA; and to attend the October 10, 2018 public information meeting after the release of the Draft EA concerning the project. As a member of the public, Mr. Andrade has provided comments on the Draft EA which are addressed in this Appendix.
Comment
• The entire town was not notified about the three information meetings. (Comment 33)
• There was no disclosure of the proposed project to the residents of Pāhala. (Comment 40)
• There was no disclosure or consultation with the residents of Pāhala. Poor communication resulted in low turnout for all the meetings. (Comment 41)
• I own property in Pāhala, but do not reside there, and would like to be kept informed about the Project. (Comment 59)
• The county is fast tracking the project without input from the community. (Comment 41)
• Communication with residents was not done properly and with respect, so not everyone was informed about meetings. A lot of older people do not understand what is going on. (Comment 42)
• The County failed to thoroughly inform all Pāhala residents who will be affected by this
system. (Comment 55)
• The community needs more information about the project. Information was presented poorly in the community meetings. (Comment 63)
• More input by the county on how this project is going to be handled fairly to benefit the
community. (Comment 63)
• The Pāhala DEA notice failed to include the true purpose of project, which is to place a
secondary sewage treatment plant with four open sewage lagoons in remote Ka‘ū. (Comment 53)
• Residents were not given sufficient time to address concerns about the EA. (Comment 40)
Response
NEPA requires agencies to use “appropriate communication procedures to ensure meaningful public participation throughout the NEPA process,” and to “make reasonable efforts to involve potentially affected communities where the proposed action is expected to have environmental impacts.” See 40 CFR § 6.203(a)(5). For an EA, EPA’s NEPA regulations require that the EA and Preliminary FONSI be made available for review and comment at least thirty calendar days before making a decision on whether, and how, to proceed with a proposed action.
As described below, EPA has complied with these public participation requirements and guidelines throughout the scoping process and development of the Draft EA and Final EA. The
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Draft EA Section 7 (Public Participation) identifies the community public outreach efforts the County conducted to solicit input while preparing the Draft EA. Prior to the issuance of the Draft
EA, the County held five talk story sessions in December 2017 to solicit community input on reactions and perceived effects of the proposed project. Notice about the talk stories was provided to the Pāhala community through several means: direct mailing to properties currently connected to the LCCs, fliers were left at properties which are not currently connected to the LCCs but would have access to the proposed sewer (‘newly accessible properties’), fliers were provided to organizational leaders and posted in public venues in Pāhala, and several online announcements
were made.
After collecting information on the anticipated scope and impacts of the proposed project, a Draft EA was prepared and published in The Environmental Notice issued by OEQC on September 23, 2018. The Draft EA was made available through the OEQC website, as well as through EPA’s website, for public review and comment. EPA and the County initially solicited written comments
on the Draft EA during the 30-day period from September 23 - October 23, 2018. In response to a request for extension, EPA and the County extended the public comment period for the Draft EA to December 10, 2018.
The Draft EA was made available through the following public notices and methods of outreach:
• The EPA provided notice of the Draft EA on their website (https://www.epa.gov/uic/proposed-pahala-community-large-capacity-cesspool-replacement-project-draft-environmental);
• Notice of the publication of the Draft EA was published in West Hawaii Today and the
Hawaii Tribune Herald on September 26, 2018.
• A public notice was published in the October 1, 2018 print and online editions of the Ka‘ū
Calendar and made available on the Ka‘ū News Briefs web site http://kaunewsbriefs.blogspot.com;
• The Ka‛ū Calendar News Brief included an article on October 9, 10, and 11, 2018 with mention of an upcoming meeting (October 10, 2018 public information meeting); and
• Two notices for the Draft EA were published in The Environmental Notice:
o September 23, 2018 – notice for the statutory 30-day public review and comment period for the Draft EA; and
o November 8, 2018 – notice for republishing the Draft EA and extension of the public comment period for 30 days.
• Fliers were posted in public venues such as the community shopping center, realtor office,
grocery store, library, and the Pāhala Community Center.
• Letters were mailed on September 10, 2018 containing information on the availability of the Draft EA, the comment period, and the October 10, 2018 public information meeting to all property owners on record adjacent to the proposed collection system.
After the publication and distribution of the Draft EA, a public information meeting was held on
Wednesday, October 10, 2018 at the Ka‛ū Gym Multi-Purpose Conference Room. The County provided a presentation and display boards in an open-house format prior to the meeting to facilitate public understanding of the proposed project, and meeting facilitators were available to answer technical questions concerning the project and offer clarification where necessary.
On September 10, 2018, letters containing information on the availability of the Draft EA, the comment period, and the October 10, 2018 public information meeting were mailed to all property
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owners on record adjacent to the proposed collection system. This direct mailout included an invitation from DEM to workshops conducted prior to the October 10 public information meeting.
The workshop for owners served by C. Brewer lines was held on October 8, and the mailout for this meeting also included any non-owners currently receiving a wastewater bill. The workshop for owners of newly accessible properties was convened on October 9. In addition to the direct mailout, online announcements for the October 8 and 9 workshops were available on the Ka‘ū News Briefs website.
A summary of this public involvement and outreach following the issuance of the Draft EA is included in the Final EA Section 7 (Public Participation). These efforts for public outreach and involvement exceeded NEPA outreach requirements.
For responses to comments on outreach related specifically to the HEPA HRS 343 process,
please refer to the County’s individual responses to the above comments.
As explained at various points in the Draft EA, including in Draft EA Section 1 (Summary), and in
the coversheet accompanying the Draft EA published in The Environmental Notice, the Proposed Action is to construct “four lined aerated 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.”
Comment
• Why were residents who are not on the LCC system excluded from the decision-making process prior to December 2017? (Comment 55)
Response
On April 25, 2010, a community meeting sponsored by Councilman Guy Enriques was held at the
Pāhala Community Center to discuss the Nā‘ālehu and Pāhala Large Capacity Cesspool Replacement project. As part of the meeting, an informational handout prepared by the County’s Wastewater Division provided a brief history of the project documenting that, in 2004, Mayor Kim’s office used a ballot system to get input from property owners regarding different wastewater treatment/disposal alternatives for those properties connected to the LCCs who would no longer be served by the C. Brewer system after LCC closure. As reported in the Draft EA Section 2.1.4 (History of Wastewater Management in Pāhala), 87 percent of the returned ballots were in favor of the installation of a new sewer collection system and a treatment and disposal system to be
operated and maintained by the County. The handout indicated Mayor Kim’s office advised the property owners the County would move forward with a new system for Nā‘ālehu and Pāhala on November 5, 2004. Additionally, the handout stated public meetings were held in both Nā‘ālehu
and Pāhala in November 2006 to discuss the wastewater system alternatives. The handout included that adequate land for the treatment and disposal system had not been identified in
Pāhala. The Final EA Section 2.1.4 (History of Wastewater Management in Pāhala) has been updated with this information.
Subsequent to that, community outreach activities in the form of five talk story sessions took place
in 2017 for the current Pāhala LCC Replacement Project and contributed to the development of
the Draft EA. The community outreach program for the Pāhala LCC Replacement Project, as stated in the Draft EA Section 7 (Public Participation), began when the County held these five talk story sessions which were open to all residents and members of the public. This information is repeated in the Final EA.
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2.3.2 Accessing the Draft EA
Comment
• I had difficulties downloading the Draft EA. (Comments 1, 2)
• I was not provided a copy of the EA despite having requested consulting party status. (Comment 1)
• The Notice for the Pāhala DEA was sent to the wrong address. (Comment 3)
Response
The commenter responsible for comments 1, 2, and 3 received a copy of the Draft EA via U.S. Postal Service certified mail on or about September 27, 2018. The comment period ended December 10, 2018, giving the commenter ample time to provide comments on the Draft EA. Efforts to distribute the Draft EA for public review and comment exceeded NEPA outreach requirements that are described in the comment response on pages 25 through 27 above.
Comment
• Only one copy of the Draft EA was sent to the Pāhala library, limiting access to the document, especially for the elderly. (Comment 41)
Response
The Draft EA was prepared and published in The Environmental Notice issued by OEQC on September 23, 2018. The Draft EA was made available through the OEQC website, as well as through EPA’s website, for public review and comment. Upon public request, 11 printed copies of
the Draft EA were made available at both the Nāʻālehu and Pāhala libraries on November 7, 2018. The public comment period ended on December 10, 2018.
These efforts to distribute the Draft EA for public review and comment exceed the NEPA outreach
requirements. This information is included in the Final EA Section 7 (Public Participation).
Comment
• There was no physical copy of the Draft EA available at the October 10, 2018 meeting. (Comment 18)
Response
Federal NEPA regulations do not require a project proponent to hold a public meeting on a Draft EA, nor do they require hard copies of a Draft EA be available at a public meeting. The October 10, 2018 public information meeting included a presentation and display boards to facilitate public understanding of the project. The Draft EA, which is a 300-page-plus document, was made available online and in the Pāhala and Nāʻālehu public libraries in advance of the public information meeting for any person to review, copy, or download. In response to a request from a member of the community, additional copies of the document were made available at public libraries as described in the response to the previous comment.
2.3.3 Public Information Meeting
Comment
• Oral comments should be collected at public meetings. Surely someone can take oral comments and make a transcription as OECQ has done? (Comments 9, 16)
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• The written commenting process used during public meetings is not adequate for people with limited English. (Comment 10)
• Increments of project, if any, should be presented. What is presented is not complete. (in
reference to the October 10, 2018 meeting). (Comment 62)
• Future subdivisions should be included in presentation (in reference to the October 10, 2018 meeting). (Comment 62)
Response
Unlike the process for preparing an EIS, there is no requirement under EPA’s NEPA regulations to hold public meetings concerning an EA or Proposed FONSI. As such, agency officials are not required to collect and respond to oral comments on a Draft EA. Despite not being required, the County held a public information meeting on the Pāhala LCC Replacement Project during the comment period for the Draft EA in order to maximize the public’s awareness of the proposal.
The Draft EA public information meeting included a presentation and display boards that showed the entire project being considered under the Proposed Action. Though the Pāhala LCC Replacement Project would be built in a manner consistent with good engineering practices so that it would not preclude expansion to treat additional flow associated with residences being added to the collection system, there are no current plans to do so. The Draft EA Section 6.2.2
(Ka‘ū Community Development Plan) discussed the Ka‘ū Community Development Plan and included a description of Policy 120, which is stated as “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.” Future subdivisions would be accommodated, as capacity allows, on a first-come, first-served basis. This information has been added to the
Final EA.
Meeting facilitators verbally explained the Proposed Action and were available to answer technical questions concerning the project and its increments. As these meetings were not transcribed for the purpose of responding to oral comments, meeting facilitators made clear that persons seeking a formal response from the agencies to their comments should submit comments in writing to the County or EPA. The County provided staff at the October 10, 2018, public information meeting to personally assist commenters in preparing written comments, including those with limited English skills and those who preferred to dictate written comments instead of preparing the written comments themselves.
Comment
• The make-up of Pāhala is majority immigrants, where English is a second language.
These residents do not fully understand the details of the project and legal jargon, so have not attended the community meetings. (Comment 56)
Response
The Draft EA Section 5.7 (Environmental Justice Executive Order 12898) indicated that Pāhala has a higher proportion of minority groups as compared to the County. The American Community Survey Data for 2012-2016 estimate that the majority of Pāhala residents (58.8 percent) speak
only English at home, and that an additional 18.2 percent speak English “very well.”5 All notices and public outreach materials prepared and distributed for the Pāhala LCC Replacement Project
5 U.S. Census Bureau, 2012-2016 American Community Survey. Table S1601 (Language Spoken at Home). U.S. Census Bureau’s American Community Survey Office, 2017. Web. October 16, 2019.
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(see Section 2.3.1 (Outreach) of this Appendix for more information on outreach efforts) were developed to be as easily readable and understandable by the general public as possible.
On October 10, 2018, a public information meeting was conducted by the County in the Pāhala
at the Ka‘ū Gym Multi-Purpose Conference Room to discuss the Draft EA. During this meeting, the County identified community volunteers attending the meeting who were proficient in Hawaiian, Tagalog, and English to assist anyone who identified as needing assistance. The OEQC rules have no provision for receiving oral comments. However, the facilitator at that meeting offered assistance in putting any oral comments attendees may wish to offer into writing.
This information has been included in the Final EA.
2.3.4 Nāʻālehu and Pāhala LCC Conversion Project – 2007 Final EA
Comment
• The 2007 Nāʻālehu and Pāhala Villages Large Capacity Cesspool Conversion Project called for the use of septic tanks for wastewater treatment. The county switched the plan from septic tanks to a lagoon system without public review. (Comment 30)
• Ballots were only sent to those homeowners that were connected to the C. Brewer system,
not the whole community (in reference to COM 0293.004 2004-2006). (Comment 61)
Response
The Proposed Action described in the Pāhala LCC Replacement Project Draft EA was developed in response to new information and changed circumstances since the 2007 proposal that cast doubt on the viability of the proposal included in the 2007 Final EA.
The Draft EA Section 2.9 (Relationship to 2007 Final Environmental Assessment) describes the reasons for not implementing the project described in the 2007 Nāʻālehu and Pāhala Large Capacity Cesspool (LCC) Conversion project Final EA. Specifically, after the County published
the Final EA in 2007, it performed additional studies and evaluation of the proposed LCC-to-septic conversion project and eventually concluded that the proposed system would not be feasible, and likely would not meet regulatory requirements for a new wastewater treatment/disposal system.
As stated in the Draft EA Section 2.8.2(a), based on current design criteria and current flow projections, an approximately 800,000-gallon community septic tank would be necessary to provide the extended detention times needed to optimize treatment performance, to avoid the
need for frequent septage pumping, and to account for peak flow rates. A community septic tank of this size would require pumping on a 3-year interval. Septic tanks produce hydrogen sulfide, reduced sulfur compounds, and other odorous gases; a community septic tank would concentrate these emissions to a single point source, requiring treatment with a dual-stage scrubber to avoid nuisance odor conditions. Therefore, use of a community septic tank is not considered to be feasible. In addition, Draft EA, Appendix B (Preliminary Engineering Report), Section 7.5.1 states that the use of a community septic tank would require the Department of Health to issue a variance to HAR § 11-62, which requires WWTPs with design capacities greater than 100,000 gallons per day (gpd) to produce effluent containing less than 30 mg/L of both BOD5 [5-day biochemical oxygen demand] and TSS [Total Suspended Solids] – septic tanks are not able to produce effluent of this quality.
On April 25, 2010, a community meeting sponsored by Councilman Guy Enriques was held at the
Pāhala Community Center to discuss the Nāʻālehu and Pāhala LCC Conversion project. As part of the meeting, an informational handout prepared by the County's Wastewater Division provided
a brief history of the project documenting that, in 2004, Mayor Kim's office used a ballot system to get input from property owners regarding different wastewater treatment/disposal alternatives for those residents who would no longer be served by the C. Brewer system after LCC closure.
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As reported in the Draft Section 2.1.4 (History of Wastewater Management in Pāhala), 87 percent of the returned ballots were in favor of the installation of a new sewer collection system and a
treatment and disposal system to be operated and maintained by the County. The handout indicated Mayor Kim's office advised the property owners the County would move forward with new systems for Nāʻālehu and Pāhala on November 5, 2004. Additionally, the handout stated public meetings were held in both Nāʻālehu and Pāhala in November of 2006 to discuss the wastewater system alternatives. The handout included that adequate land for the treatment and disposal system had not been identified in Pāhala. This information is included in the Final EA
Section 2.1.4.
The Pāhala LCC Replacement Project Draft EA was made available online and in public libraries in Nāʻālehu and Pāhala beginning on September 23, 2018. The County and EPA solicited input on the Proposed Action via the public comment period that lasted from September 23 to December 10, 2018. Information concerning the decision to abandon the 2007 proposal has been
added to the Final EA Section 2.9.
2.3.5 State and Local Agencies
Comment
• The Department of Hawaiian Homelands acknowledges receiving the request for comments. After reviewing materials submitted, due to the project’s lack of proximity to Hawaiian Home Lands anticipates no impacts to our lands or beneficiaries. We encourage agencies to consult with Hawaiian Homestead community associations when preparing EAs. Dated 9/27/2018. (Comment 35)
• The County of Hawaiʻi Police Department has reviewed the draft EA and does not have any additional comments or concerns at this time. Dated 10/2/2018. (Comment 36)
• The Hawaiʻi Department of Land and Natural Resources (Engineering Division, Division of Forestry and Wildlife, and Land Division) has reviewed the Draft EA for the Pāhala LCC Replacement Project and has no comments. Dated 10/22/2018. (Comment 77)
• The Hawaiʻi Department of Land and Natural Resources (Division of Forestry and Wildlife
and Land Division) has reviewed the Draft EA (generated in response to the extension of public comment period) for the Pāhala LCC Replacement Project and has no comments. Dated 12/7/2018. (Comment 71)
Response
EPA acknowledges receipt of letters from the above organizations and appreciates their review of the Proposed Action and Draft EA.
Pre-assessment consultation letters were sent to 14 Native Hawaiian Organizations, as stated in the Draft EA Section 3.15.1 (Archeological Resources – Existing Conditions). These organizations included the Piʻihonua Hawaiian Homestead Community Association. No responses were
received from any Native Hawaiian Organization. This information is updated in the Final EA.
2.4 State and Local Processes
Responses to comments regarding compliance with state and local processes have been
arranged into the following categories:
• State of Hawaiʻi Office of Planning
• Hawaiʻi Environmental Policy Act (HEPA), HRS Chapter 343
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• Hawaiʻi Department of Business, Economic Development and Tourism, Land Use Commission (LUC)
• Ka‘ū Community Development Plan (CDP)
2.4.1 State of Hawaiʻi Office of Planning
Comment
• The State of Hawaiʻi Office of Planning indicates that the Final EA should include a discussion of the project's ability to meet all parts of the Hawaiʻi State Planning Act (HRS Chapter 226), and examine the project's consistency with these statutes, or clarify where it is in conflict. A discussion of Priority Guidelines, or a determination that these guidelines are not applicable to the proposed action, should be included in an examination of Part III statutes. (Comment 32)
• The State of Hawaiʻi Office of Planning requests that the Final EA should include a discussion of the project's compatibility with statewide sustainability goals and principles
of sustainability (HRS § 226-108). (Comment 32)
• The State of Hawaiʻi Office of Planning indicates that the option of a District Boundary Amendment could be considered as a land use approval option (could be used instead of a Special Permit) and discussed in the EA. (Comment 32)
Response
The State of Hawaiʻi Office of Planning received a pre-assessment consultation letter on March 15, 2018 and provided a formal response on April 8, 2018 which included comments on the Proposed Action. These initial comments were incorporated into the project planning and the development of the Draft EA as appropriate. In addition to the pre-consultation response, the
State of Hawaiʻi Office of Planning provided comments on the Draft EA (those described above) that requested an expansion of the discussion in the Draft EA Section 6 (Plans, Policies, and Controls) to include the Proposed Action’s ability to meet all parts of the Hawai‘i State Planning Act. Information and a brief discussion of sustainability principles from HRS § 226-108 have been added to the Final EA Table 6.1 in addition to information on other applicable sections of Part III
of HRS § 226 as requested by the Office of Planning.
The State of Hawaiʻi Office of Planning’s comment concerning the option of a District Boundary Amendment is noted.
2.4.2 Hawaiʻi Environmental Policy Act (HEPA)
Comment
• The project is in violation of HEPA and UIPA for disclosure of the August 15, 2018 environmental assessment records, and denial of requested records. (Comment 1)
• The COH/EPA/Contractors should fully explain why two new-build secondary sewage
plants 11 miles apart in remote, rural Ka‘ū would not require an EISPN Act 172-12 notice. (Comment 2)
• The Pāhala and Nāʻālehu projects are in violation of EIS requirements as established by HRS 343/ HAR 11-200 and 11-201. (Comment 13)
• The Pāhala and Nāʻālehu projects should be considered together under HEPA 343. (Comment 16)
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• The project is not in compliance with HRS 343 because of the failure to prepare a HEPA EIS, the methods of public outreach and participation, lack of availability of documents, and lack of TEN public notice for the two “talkstory” sessions. (Comment 23a)
• The Pāhala Draft EA notice failed to include the 9A trigger; the project should trigger HEPA 343 Sec5(a)(9). (Comments 16, 53, 58)
• Demoruelle v. Beck evidence of misconduct in following NEPA/HEPA. (Comment 75)
Response
The above-listed comments relate to compliance with the Hawaiʻi Environmental Policy Act,
otherwise known as Chapter 343 of Hawaiʻi Revised Statutes or HRS 343. The Final EA Section 6 (Plans, Policies and Controls) includes discussion of state and local requirements applicable to this project. Comments related specifically to compliance with state requirements including HRS
343 are addressed by the County in its separate responses to the above comments.
For discussion of compliance with NEPA procedures, please see Section 2.2 (NEPA Processes) of this Appendix. Discussion of public outreach and notice efforts is included in Section 2.3 (Public
Involvement and Outreach) of this Appendix and in the Final EA Section 7 (Public Participation).
Comments regarding the Nāʻālehu Large Capacity Cesspools Closure Project are outside the scope of the Proposed Action. The Nāʻālehu Large Capacity Cesspools Closure Project is currently undergoing a separate environmental review, coordinated by the County of Hawai‘i Department of Environmental Management, in accordance with HRS 343 requirements.
2.4.3 Hawaiʻi Department of Business, Economic Development and Tourism, Land Use
Commission (LUC)
Comment
• Describing the project as 14.9 acres is an attempt to evade LUC scrutiny, as LUC review is required for projects of 15 acres or more. (Comments 1, 6, 23a, 40 and 41)
• The project covered a minimum 667,500 sq. ft. [15.3 acres] plus utility access must be considered as part of the project impacts no matter who will own it, so that is another 37,500 sq. ft., bring total acreage at Site 7 as 16.1 acres. (Comment 23a)
• The LUC should be given a chance to review the project even if the property was not within their range. (Comment 42)
Response
Because the Proposed Action is located within an Agricultural District, under Hawaiʻi law a Special Permit is needed. As described in the Draft EA Sections 3.10.2 (Agricultural Lands – Impacts and
Mitigation Measures) and 6.1.3 (State Land Use District), “under Chapter 205, HRS, use of agricultural lands for non-agricultural purposes greater than 15.0 acres requires approval of a
Special Permit by the Land Use Commission.” The Final EA clarifies that, for the Preferred Alternative at Site 7, the County would apply for a Special Permit which requires approval by the County Planning Commission. For projects that would use agricultural lands for non-agricultural purposes greater than 15.0 acres, the County Planning Commission would then submit their
decision to the State of Hawaiʻi Land Use Commission for their approval.
As stated in the Draft EA Section 3.10.2(a), “construction of the wastewater treatment and disposal facility at Site 7 would require removal of approximately 14.9 acres of macadamia nut trees.” The 14.9-acre site has been selected to provide the necessary land area for the facilities needed to treat the incoming flows and to dispose the treated effluent from the treatment process.
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The proposed project site minimizes the use of the adjacent lands which contain a commercial macadamia orchard. A larger project site is not required. Please refer to the County response to
Comment 23a for more information.
As stated in the Draft EA Section 2.10.3 (Hawaiʻi Revised Statutes (HRS) Chapter 205 Considerations), within the agricultural district, public, private, and quasi-public utility lines are a permitted use. The area of the Proposed Action located within the ROWs and other easements
within the residential areas of Pāhala is considered a permitted use within agricultural land and therefore does not add to the acreage of agricultural lands for purposes of the Special Permit for the LUC review. The County would therefore seek a Special Permit from the County Planning Commission. This information is repeated in the Final EA Section 2.10.3.
No attempt has been made to avoid review by the LUC. The County sent the LUC a pre-consultation letter for this project dated March 15, 2018 providing notice of the preparation of a Draft EA and inviting comments on the Proposed Action as part of the pre-assessment
consultation process. No response was received. Also, the Department of Business, Economic Development and Tourism was directly notified (by mail) of the availability of the Draft EA.
2.4.4 Ka‘ū Community Development Plan (CDP)
Comment
• The Pāhala Draft EA shows no respect for the Ka‘ū CDP, specifically Policy 90, and does not follow its statutes. (Comments 46, 50, 65)
Response
Comments related to compliance with state and local requirements are addressed by the County in a separate response to the above comments. The Draft EA included a detailed discussion of the Ka‘ū Community Development Plan in Section 6.2.2 (Ka‘ū Community Development Plan). That section has been updated in the Final EA.
2.5 Project Location and Design
Responses to comments regarding the location and design of the proposed project have been arranged into the following categories:
• Proximity to Schools
• Location of preferred Alternative
• Extent of Collection System
• Treatment Alternatives
• Technical Design
2.5.1 Proximity to Schools
Comment
• How far away will the Plant be from the Pāhala schools? (Comment 23a)
• I am very concerned about the short distance between the proposed site and the school.
(Comment 26)
Response
As stated in the Draft EA Section 4 (Cumulative Effects), the Kaʻū High School and Pāhala
Elementary School are approximately one-half mile north of the wastewater treatment and
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disposal facility at Site 7 under the Preferred Alternative. The facility would be separated from the schools by a macadamia nut orchard, the old Pāhala Sugar Mill maintenance yard, five streets
and numerous private residences. The wastewater treatment and disposal facility would be enclosed with a 6-foot-high chain-link fence and posted to prevent public access. EPA does not anticipate that construction and operation of the proposed wastewater treatment and disposal facility would have any direct or indirect impact on the schools (e.g., due to visual, smell, or noise impacts), due to the distance between the proposed facility and the schools. This information has been added to the Final EA Sections 3.14 (Air Quality), 3.18 (Noise), and 3.19 (Visual
Characteristics).
The schools currently discharge wastewater to eight (8) DOH-approved septic systems. At the time the septic systems were installed, two new laterals were also installed at the property line on Hala Street and Kamani Street to allow for eventual connection to the new collection system (see Draft EA Section 4.1.1 (Past, Present, and Reasonably Foreseeable Actions)). Upgrading the
collection system in front of the school so that these laterals may be connected to the new collection system may result in temporary traffic impacts during construction but these impacts would be mitigated through the establishment of a traffic control plan which would be coordinated
with HIDOE transportation services (see the Draft EA Section 3.17.2 (Traffic – Impacts and Mitigation Measures)).
Construction of the project would also result in temporary noise impacts for all areas with
construction equipment and trenching as described in Draft EA Section 3.18.2. All construction activities would comply with the Community Noise Control provisions of HAR 11-46. Lastly, the Proposed Action could result in short-term impacts to air quality due to construction activities as a result of fugitive dust or exhaust emissions from mobile construction equipment as described in Draft EA Section 3.14.2. A dust control plan would be implemented to include mitigation measures such as watering of active work areas. EPA does not anticipate any long-term impacts to the Kaʻū
High School and Pāhala Elementary School as a result of construction activities.
2.5.2 Location of Preferred Alternative
Comment
• The plant should be sited below/south of the highway. (Comments 23a, 27, 55, 56, 62, 63, 67, 68, 69, 70, 73) – Commenters provided the following rationales for this comment: concern over flooding risk, concern that caves and burial sites may be present at the proposed location, concern about visual and odor impacts, and concern about safety and health.
• I am very upset with this whole idea of where you are intending to put the new plant. (Comment 34)
• The plant should be sited south of the highway and make use of the existing culvert that was installed by the sugar industry. (Comments 31, 33)
• Please move the proposed Pāhala sewage treatment plant to the makai (seaward side) of the highway. The proposed site is too close for comfort and life quality. (Comment 37)
• The site should be relocated below the highway to be further away from the town due to safety, environmental, historical, and aesthetic concerns. (Comment 41)
Response
The Draft EA Section 2.7 (Development of Site Alternatives and Selection of Preferred Alternative) discussed the alternative sites for construction of a new wastewater treatment and disposal
facility. One of the alternatives discussed, Site 9, is located below the highway. This alternative
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scored lower than the Preferred Alternative location (Site 7) because it would require construction of additional access roads, a longer distance to available power and potable water, and a longer
transmission line due to the further distance from the existing LCCs and collection system infrastructure. Site 9 would require approval by the State of Hawaiʻi Department of Transportation. It also scored lower than Site 7 because of presence of and/or proximity to archeological/cultural sites. In addition, it was determined that, depending on the configuration of the wastewater treatment facility and the land application groves, this alternative could require trenching and construction of piping across south flowing branches of the Hi‘onamoa Gulch, classified as a riverine wetland (per the National Wetland Inventory), which occurs within the site. To avoid this potential impact for Site 9 and to minimize costs, the headworks, lagoons, and the subsurface constructed wetlands could be sited in the upper portion of the site (i.e., the area closest to the highway) which would result in other impacts. Further discussion has been added to the Final EA Sections 2.5 (Proposed Action – Site 9 Alternative) and 3.7 (Surface Water).
Two additional parcels located below the highway were identified in the Draft EA as Sites 4 and 5. Site 4 was eliminated from consideration because, among other reasons, it contained an unnamed gulch that would need to be crossed by influent and fire protection lines and, because
of the soil type, it was estimated that 200 acres would be needed to accommodate the slow-rate land treatment basins (See Draft EA Section 2.8.1(d) (Other Site Alternatives)). Site 5 was eliminated from consideration for similar reasons, as described in Section 2.8.1(e) of the Draft
EA. No other parcels below the highway were identified as potentially suitable for the project.
The location and configuration of the Preferred Alternative (Site 7) were designed to minimize aesthetic impacts of the project. As described in the Draft EA Section 3.19.2 (Visual Considerations and Light Pollution – Impacts and Mitigation Measures), the existing pine trees along Maile Street would continue to obstruct the view of the facility from Maile Street. The facility
would be visible from Māmalahoa Highway (State Route 11); however, impacts to the view plane would be mitigated by the planted trees in the disposal groves and by the rise in elevation between the highway and the facility. In addition, as described in the Draft EA Table 6.1, the project “does not include facilities or improvements that would adversely affect public safety of this area of Hawai‘i.” Potential impacts of the project on historic properties are addressed in Section 2.1.5 (Archeological and Cultural Resources) of this Appendix.
2.5.3 Extent of Collection System
Comment
• It was my understanding that the reason the sewage system was being expanded beyond what was required by the Feds was because it was part of the CDP. Can you please direct me to the section in the CDP that states this? (Comment 29)
• I really feel that the County of Hawai‘i should concentrate on only people involved with LCC’s first and foremost because of the Federal mandated regulations. We non-LCC are not in violation of any standards of the Federal Regulation’s requestings. (Comment 55)
• The County has decided to expand the new sewage system beyond those homes currently on LCCs, and beyond what is required by the federal government. (Comments 31 and 73)
• There are some homes which will have the sewer line running near their homes but are not part of the original C. Brewer LCC line. The homes across the street and connecting
are not part of the LCC line either, so it is perplexing as to why this initial phase of the project is including lines in areas that are not necessary. (Comment 61)
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Response
The Draft EA Section 2.3.2 (Construct New Wastewater Collection System) discusses the
construction a new sewer collection system in the Pāhala community to replace and expand upon the existing system of substandard gravity lines that currently conveys sewage to the two LCCs. As described in the Draft EA Section 6.2.1 (Hawai‘i County General Plan), the current LCC collection system includes lines located the backyard of many parcels. Where easements for the existing collection system aren’t accessible, the County must obtain permission from each landowner to enter them, through private property, to inspect, maintain, repair, or replace existing sewer facilities: all activities essential to an efficient, functioning system. As a result, the proposed new collection system would be located primarily within the public street rights-of-way and to close the LCCs, there would be parcels that become “newly accessible” to the collection system. The collection system is not being expanded under the Proposed Action beyond the area needed to close the LCCs. This information is repeated in the Final EA.
The collection system constructed as part of the Proposed Action would be designed to extend to all properties currently served by the LCC system. While the areal extent of the new collection system would mirror the old collection system, certain properties that are not currently served by
the LCC system and that are adjacent to, or across the street from, the LCC properties, would become accessible to a sewer when the new collection system is installed. Under County code, properties that become accessible to a sewer are required to connect to sewer unless certain
exceptions are met. While the Proposed Action does not include installation of laterals to connect these newly accessible properties to the new collection system, it is nonetheless foreseeable that these properties would be required to connect to the new system. These properties have therefore been included in the scope of the environmental review for this project.
The requirement for accessible properties to connect to sewer is discussed in detail in the Draft EA Section 2.3.2 and the Final EA Section 2.3.2. Comments related to state and local
requirements, including the CDP, are addressed in the County’s response to Comment 29.
2.5.4 Treatment Alternatives
Comment
• If all the County had wanted was compliance with clean-water requirements, and with the least distress to the taxpayer and payer of sewage-system user fees, it probably would have explored alternative means of sewage treatment. Methods such as constructed wetlands generally are less capital and labor intensive than traditional treatment plants. (Comment 5)
• The DEA gives no consideration to any decentralized, more cost-effective project for rural areas such as in Kaʻu. There should be remedial community meetings to consider
alternatives, including the original conversion to septic, to close the LCCs. (Comment 23a)
• Mobile sewage treatment systems should be considered to address Hawaiʻi’s problem with cesspools. Mobile units could be used when cesspools are at capacity, and they do not require pipelines, which are subject to damage. (Comment 44)
• No alternatives, including micro-sewage projects, have been offered to taxpayers. (Comment 52)
• The sewage flow could easily be handled by one or two small packaged plants, affordably modular to accommodate growth, on a very small footprint of land with no noxious odors. (Comment 66)
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Pāhala, Ka‘ū District, Hawai‘i
February 2020 38
• The type of plant to be used should be reconsidered due to the history of flooding from rain, storms, and hurricanes from the slopes of Mauna Loa which would overflow the open sewer reservoir. (Comment 76)
Response
The proposed treatment method for the Pāhala LCC Replacement Project consists of an aerated lagoon treatment system with a constructed wetland and disinfection, followed by land application for effluent management. The system is described in detail in the Draft EA Section 2.3.1 (Acquire Site 7 and Construct New Secondary Wastewater Treatment and Disposal Facility). In addition to the proposed treatment method, the County and EPA considered numerous treatment alternatives, including septic tank alternatives (see Draft EA Section 2.8.2(a)), alternatives for onsite wastewater systems (see Draft EA Section 2.8.2(b)) and other “effluent management options” (see Draft EA Section 2.8.3). As described in the Draft EA, all these alternatives were removed from consideration due to their lack of feasibility and other concerns as outlined in the
Draft EA Section 2.8 (Alternatives Considered but Not Carried Forward).
Specifically, septic tank alternatives were rejected because it was determined that a community
septic system large enough to receive the projected flow from the community would not be capable of achieving the effluent quality standards required by HAR § 11-62-23.1 (see Draft EA Section 2.8.2). In addition, individual septic systems for the lots currently served by the LCCs
were deemed infeasible because many of the lots in Pāhala are too small to construct individual septic systems (see Draft EA Section 2.8.2).
The commenter referring to micro-sewage may have been referring to individual wastewater systems such as composting toilets which would be too small to meet the purpose and need of the Proposed Action. A discussion of alternative individual systems is available in the Preliminary Engineering Report in Appendix B of the Final EA.
Flood risks associated with the proposed wastewater treatment and disposal system are discussed in Section 2.1.1 (Flood Risk) of this Appendix, and in the Final EA Sections 2.3.1 (Acquire Site 7 and Construct New Secondary Wastewater Treatment and Disposal Facility) and
3.23 (Infrastructure – Drainage System).
2.5.5 Technical Design
Comment
• The Brown and Caldwell engineer classified Pāhala wastewater flows (80,000 gallons a day) as municipal. EPA cites small wastewater flows (non-municipal) as under 1 million gallons a day. All consideration of packaged treatment plants were dismissed based on the engineer characterizing the Pāhala wastewater flow as municipal. Since a package plant that would be adequate to close the Pāhala LCCs would cost around $4 million…this option would be given real consideration as a cost effective alternative. It would also require far less land and fit closer to the exiting LCCs. Since packaged plants are modular, capacity could be expanded for future flows by just adding new units. The added cost of electricity and sludge removal would be offset by saving of $10 million in borrowed SRF funds. (Comment 64)
• The proposed facility is too large. The Pāhala WWTP will be built to handle 380,000 gal/day when the actual flow for a larger population base in the 2007 FEA was 80,000 g/d.
Underutilized plants can become a “negative removal efficiency” - meaning what the plant pumped out was more contaminated that what went in. (Comment 5)
Final EA, Pāhala LCC Replacement Project – Appendix E
Pāhala, Ka‘ū District, Hawai‘i
February 2020 39
• The engineers fail to justify the extremely high Pāhala wastewater flow rates which should have been based on City and County of Honolulu Sewer Standards with an average wastewater flow rate of 320 gal/day per lot. The LCC closure only required disconnecting from around one hundred households, so the flow rate is around 32,00 gal/day. (Comment
66)
Response
Per HAR 11-62, wastewater treatment works must be designed in accordance with County standards, or City and County of Honolulu standards if a county does not have design standards. The County of Hawaiʻi does not have design standards; therefore, the City and County of Honolulu
standards are applicable to the Pāhala LCC Replacement Project. The City and County of Honolulu updated their design standards in July 2017 and the 320-gpd standard is no longer applicable.
Based on these standards, the Pāhala LCC Replacement Project is designed to treat an average
dry weather flow of 190,000 gpd including lots which are not in single family residential use or zoning, which is sufficient capacity to allow closure of the LCCs. Additional detail is provided in
the Draft EA Appendix B (Preliminary Engineering Report). It should be noted that wastewater flows from a community are highly variable, and peak flow rates from small community wastewater collection systems are typically three to five times higher than the average flow rates. State and
County design standards take this variability into account, and application of the standards results in conservatively designed facilities that are protective of human health and the environment under anticipated conditions. Information relating to applicable design standards has been added to the Final EA Section 2.3 (Proposed Action – Site 7 Alternative (Preferred Alternative)).
The wastewater treatment and disposal facility and the collection system would be designed to meet the purpose and need of the Proposed Action. The facility would be built to handle 190,000 gpd (average dry weather), not the full-buildout flow projections of 360,000 gpd associated with expansion to entire community. However, as a matter of good engineering practice, and to the extent practical, the wastewater treatment and disposal facility and collection system would be designed not to preclude expansion to treat future average dry weather flows up to 360,000 gpd should the County or community decide in the future that expansion is necessary in accordance
with the requirements established in the Ka‘ū Community Development Plan Policy 120.
The proposed treatment system for the Pāhala LCC Replacement Project includes aerated lagoons that are more energy efficient than conventional activated sludge wastewater treatment
processes. The aerated lagoon process is less sensitive to underloading conditions than conventional activated sludge wastewater treatment processes and would provide excellent treatment performance during low flow conditions. The “negative removal efficiency” effect is not
applicable to the aerated lagoon technology. The Pāhala LCC Replacement Project does include a constructed wetland treatment system and the proposed land treatment tree groves provide an energy efficient “natural” technology that would use sunlight, vegetation, and soil properties to achieve the desired results.
Comment
• The consideration of the use of alternative energy sources (wind, solar, methane) would decrease emissions. Hooking up to HELCO is not looking to the future. Please look beyond the grid for energy. (Comments 31, 73)
Response
The 14.9-acre area for the wastewater treatment and disposal facility under the Preferred Alternative (Site 7) minimizes use of the adjacent macadamia nut farm. The Draft EA Figure 2.3
Final EA, Pāhala LCC Replacement Project – Appendix E
Pāhala, Ka‘ū District, Hawai‘i
February 2020 40
shows the project site as fully utilized by the four lagoons, the four planted groves used for slow-rate land application system, the subsurface flow constructed wetland, and the headworks and
operation building. The remaining land area would not be sufficient to accommodate construction of facilities for an alternative energy source.
The Preferred Alternative does not include utilizing alternative energy systems such as
photovoltaic solar or wind as a total replacement for connecting to the HELCO grid due to:
• The need for consistent power supply;
• Emergency backup power requirements;
• Up-front capital cost;
• Full utilization of the 14.9-acre proposed site for the treatment and disposal facility;
• Objective to minimize the amount of land area removed from agricultural production; and
• EPA-enforced project implementation schedule deadlines.
Partial augmentation of traditional power utilizing photovoltaic solar panel arrays on the headworks and operations building rooftops, however, is feasible and would be further analyzed during the detailed design phase after loads and demand patterns are better understood. Additional alternative energy systems can be added in the future if prioritized and funded by County Council, and the electrical systems would be designed to accept additional alternative energy input.
Methane gas is generated at wastewater treatment plants using a process called anaerobic digestion. The proposed wastewater treatment and disposal facility would be too small for
anaerobic digestion to be economical; the design flow to the Pāhala wastewater treatment and disposal facility would be 190,000 gpd, and anaerobic digestion is only economically attractive for wastewater treatment and disposal facilities that treat at least 5 to 10 million gpd. In addition, the
anaerobic digestion process requires primary clarifiers as part of the liquid treatment process, but primary clarifiers tend to be odorous in tropical climates, due to the relatively high wastewater temperatures. The proposed facility would rely on natural treatment systems that require relatively low energy input. Additional detail regarding the preliminary analysis of alternative energy options can be found in the Final EA, Appendix B (Preliminary Engineering Report).
Comment
• I am concerned with the placement of the sewer lines near the water lines of Pāhala. Is there some kind of spec sheet that shows how far away the sewer line will be to the water
line? (Comment 61)
Response
As stated in Draft EA Section 3.22.1(a) (Infrastructure – Water System – Existing Conditions),
“the water lines are primarily located along or under the roadways in the area.” The Draft EA Appendix A included a letter from the County of Hawai‘i DWS that stated the following:
“The Department requests that the construction plans show, and the proposed sewer lines be
installed with, the proper horizontal and vertical clearances from our existing water system facilities and concrete jacketing at waterline crossings, where necessary, as recommended by the
Department's Water System Standards. In addition, backflow prevention devices must be installed where there are connections to our water system at wastewater processing and treatment facilities.”
Final EA, Pāhala LCC Replacement Project – Appendix E
Pāhala, Ka‘ū District, Hawai‘i
February 2020 41
The Pāhala LCC Replacement Project would not impact existing water lines in the community. This information was added to the Final EA Section 2.3.2 (Construct New Wastewater Collection
System).
2.6 Other Comments
Responses to other comments have been arranged into the following categories:
• Miscellaneous and Other Comments
• Nāʻālehu Large Capacity Cesspools Closure Project
2.6.1 Miscellaneous and Other Comments
Comment
• A councilmember's name was listed incorrectly in the Draft EA. (Comment 8)
Response
Refer to the Final EA Section 10.1 (Pre-Assessment Consultation) for corrected spelling of the
councilmembers name.
Comment
• The Draft EA incorrectly states that Pāhala is the largest town in Ka‘ū District. (Comment 61)
Response
Refer to the Final EA Section 2.1.1 (Pāhala Community) for a correction to the text which has been revised to state “The Ka‘ū district consists of several communities, including the Pāhala community, which has a population of approximately 1,341 persons.”
Comment
• The Draft EA list of preparers did not include the outreach subcontractors. (Comments
23a, 27)
Response
The public outreach subcontractor did not prepare the EA and therefore no correction the List of Preparers in the Final EA is required.
Comment
• What were the agreements made between C. Brewer and the County during the transition of turnover? (Comment 67)
Response
The Draft EA Section 2.1.4 (History of Wastewater Management in Pāhala), which described the
history of wastewater management in Pāhala, includes the following information: “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 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
Final EA, Pāhala LCC Replacement Project – Appendix E
Pāhala, Ka‘ū District, Hawai‘i
February 2020 42
the public right-of-way adjacent to the new collection system. It was 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 County Council. This information has been added to the Final EA Section 2.1.4.
Comment
• Since the Kealakehe WWTP is running so much over budget, why won't the Pāhala
project? (Comment 27)
Response
The Kealakehe Aeration Upgrade and Sludge Removal Project is a repair and upgrade project
that is outside of the original project scope for construction of that facility; comments regarding the cost of that repair and upgrade are not pertinent to the scope, cost, or impacts of the Proposed
Action.
Comment
• A handout was distributed by then County Rep. Guy Enriques to everyone in the community. Why did the county waste money doing an EA regarding the same site? (Comment 41)
• The citizens of Ka‘ū have been significantly harmed by COHDEM and EPA failure to incorporate environmental review from the initial proposal of the WWTP projects in 2012
DEM’s CIP 2012-13 Budget. (Comment 23a)
• The Nāʻālehu/Pāhala 2007 Final EA/FONSI should have been supplemented or withdrawn
prior to the publication of the Pāhala Draft EA/AFNSI notice in September 2018.
(Comment 4)
• Why hasn't the 2007 Ka‘ū LCC project Final EA/FONSI been withdrawn under HRS?
(Comment 27)
Response
In 2007, the County prepared a Final EA for a project to install septic tanks to replace the existing
cesspools in order to comply with HRS 343. Before EPA performed its environmental review of the project as required under NEPA, the project was abandoned because it was determined to be
infeasible based on further engineering review. Additionally, the parcel considered in the 2007 EA for construction of a septic tank treatment system (TMK 9-06-002:016) is not the same parcel as the Preferred Alternative (Site 7) of the current Pāhala LCC Replacement Project (TMK 9-6-
002:018). A discussion of the history of the projects is included in the Final EA Section 2.9 (Relationship to 2007 Final Environmental Assessment).
Comments relating to HRS 343 publication procedures for the project proposed in 2007 are not germane to the Pāhala LCC Replacement Project that is currently the subject of EPA’s review under NEPA. As explained in the Draft EA Section 2.9 and in Section 2.3.4 (Nāʻālehu and Pāhala LCC Conversion Project – 2007 Final EA) of this Appendix, the EPA did not prepare or approve the 2007 County-led environmental review referenced in the comment. Comments related to compliance with publication requirements under HRS 343 are addressed by the County in their responses to the above comments.
Final EA, Pāhala LCC Replacement Project – Appendix E
Pāhala, Ka‘ū District, Hawai‘i
February 2020 43
2.6.2 Nāʻālehu Large Capacity Cesspools Closure Project
Comment
• EPA and CODEM are avoiding NEPA/HEPA, ESA, NHPA, Section 106 and the environmental review for the Nāʻālehu project. (Comments 1, 34, 43, 57, 65)
• EPA has separated the Kaʻu LCC closure grant into two separate projects and refused to follow NEPA/ESA procedures that EPA followed for the Pāhala project DEA as for the
Nāʻālehu WWTP work plan. (Comment 4)
• I have concerns about the Nāʻālehu plant, including its location. (Comment 5)
• Nāʻālehu plant is sited too close to the school. The Nāʻālehu DEA has been withheld since April 2017, and no EA has been published, preventing the opportunity for public review
and comments. (Comment 23a)
• There was no public participation in the decision to site the Nāʻālehu WWTP near the elementary school. (Comment 38)
• How can comments be made about the Nāʻālehu WWTP? We will share this information
at the weekly Ka‘ū community meeting about the WWTPs. (Comment 47)
• The Nāʻālehu project is sited too close to the well, school and in PONC Land. (Comments 43, 47, 48, 52, 75)
• Is the Nāʻālehu Preliminary Engineering Report available at the libraries? I did not know it had been published because two scheduled meetings about the Nāʻālehu project have not
been held. (Comment 48)
• Did the libraries receive copies of the Preliminary Engineering Report for the Nāʻālehu
sewage treatment plant? (Comment 54)
• EPA and COHDEM transferred funding away from the Nāʻālehu project to evade NEPA,
NHPA-/ESA requirements. (Comment 65)
• The estimated costs for the Nāʻālehu project are suspicious. The large value of the administrative and legal expenses budget for suggests it may be a slush fund. (Comment 66)
• HI Department of Education requests to be included in the pre-draft assessment consultation and Draft EA for the Nāʻālehu LCC Replacement Project. (Comment 72)
• COHDEM and its contractors are avoiding Section 7 consultation under the ESA for the
Nāʻālehu project. (Comment 57)
Response
Comments regarding the Nāʻālehu Large Capacity Cesspools Closure Project are outside the scope of the Proposed Action. As explained in the Draft EA Section 4.1.2 (Actions Considered but Excluded from Analysis), the Nāʻālehu Large Capacity Cesspools Closure Project is a
separate project from the Pāhala LCC Replacement Project and the two are not expected to result in any cumulative impacts given the considerable distance between the two towns. This is further clarified and supported in the Final EA Section 4 (Cumulative Effects). In addition, neither project is dependent on the other for completion, nor does approval or completion of one project make it more likely the other would be similarly approved or completed. The Nāʻālehu Large Capacity Cesspools Closure Project is currently undergoing a separate environmental review, coordinated
Final EA, Pāhala LCC Replacement Project – Appendix E
Pāhala, Ka‘ū District, Hawai‘i
February 2020 44
by the County of Hawai‘i Department of Environmental Management, in accordance with HRS 343 requirements.
2.7 Comments Not Related to NEPA
Comment
• EPA should consider a settlement because the third circuit will be considering the preliminary injunction. I am planning to file a personal injury claim. (Comment 17)
• The County should grandfather in the "newly accessible lots" with functional cesspools
and septic tanks. (Comment 31)
• The plaintiff responds to the defendant's Opposition to the Motion for Preliminary Injunction. The Nāʻālehu wastewater system Draft EA should be immediately released,
and the County of Hawaiʻi should cease any and all expenditures on consultant and subconsultant contractors and halt all planning and development activities on the Nāʻālehu
and Pāhala WWTP projects. (Subject of forwarded legal documents) (Comment 21)
• The community plans to file multiple lawsuits. (Comment 23a)
• Is there any impact on rapport when there will be endless lawsuits based on violation of
NEPA/HEPA for the twin Ka‘ū WWTP projects? (Comment 27)
• Since the Kealakehe WWTP is the “most important” project in Kona, why isn’t the Ka‘ū twin WWTP projects treated as “important”? (Comment 27)
• I did not receive any confirmation that comments were mailed. (Comment 39)
• I am having trouble finding an attorney and no one has attempted to talk to me about the case. (Comment 21)
• We will be suing on this forever! (Comment 22)
• Residents of Pāhala have experienced negative psychological impacts since 2005 or 2007. (Comments 40, 41)
• The judge dismissed the Preliminary Injunction, and the COH Motion to Dismiss. The court case will move forward. (Comment 49)
• You have not addressed the problem of an [APA Hawaiʻi Chapter] award for a Ka‘ū CDP that has been totally ignored. The judges who awarded it were misled. (Comment 50)
• I am available as a consultant to produce a Cultural Impact Assessment if the project proceeds to the EIS phase. (Comment 60)
• Will police be present at the public meeting? (Comments 11 and 16)
• The LCC households of Ka‘ū deserve reparations and should not pay for sewer service until the project is completed. (Comment 23a)
• Employee strikes (disputes). (Comment 67)
Response
These comments are not relevant to the environmental review.
Final EA, Pāhala LCC Replacement Project – Appendix E
Pāhala, Ka‘ū District, Hawai‘i
February 2020 45
Comment
• A Brown & Caldwell sub-contractor has approached community members seeking personal information about me, which is criminal invasion. I will be contacting the Pele Defense Fund and the FBI. (Comment 19)
• I will not be consulting the Pele Defense Fund. I have been traumatized by the Brown and Caldwell sub-contractor inquiring about me. The County Council will request an audit of
this 13 year fiasco or I will take evidence of malfeasance to the FBI. (Comment 20)
Response
These comments are not relevant to the environmental review. EPA has found no indication that
illegal conduct has occurred.
Final EA, Pāhala LCC Replacement Project – Appendix E
Pāhala, Ka‘ū District, Hawai‘i
February 2020 46
3 County of Hawaiʻi Response to Comments
The following is a compilation of all comment letters from agencies, organizations, and others who formally replied with comments to the Draft EA. Note that some of the comments were submitted as a letter and some via e-mail as shown by the date and time. As required by HAR § 11-200-9.1(c), all written comments and County of Hawaiʻi responses are reproduced in this appendix.
(*) denotes comment number shown in Table 1
State Agencies
(32) Office of Planning
(72) Department of Education
(35) Department of Hawaiian Home Lands
(77) Department of Land and Natural Resources, Engineering Division
(71; 77) Department of Land and Natural Resources, Land Division
(71; 77) Department of Land and Natural Resources, Division of Forestry and Wildlife
County of Hawaii Agencies
(36) County of Hawaiʻi Police Department
Interested Parties
(37) Ruby Javar
(26) Tina Tuttle
(27) Sandra Demoruelle
(28) Dr. Noelani Hong 10/10/2018; 11:38 am
(44) Dale A. Loper 9/29/2018; 7:46 am
(29) Ngaire Gilmour 10/17/2018; 10:30 am
(30) Jerome Warren
(31) Ngaire Gilmour 10/20/2018; 12:40 pm
(33) Edward Andrade, Jr.
(41) Sophia M. Hanoa 10/23/2018; 4:47 pm
(42) Jadelyn Kaapana-Moses 10/24/2018; 1:39 pm
(38) Lila Lopes
(34) Charles Tuttle and Tina Tuttle
(43) Amanda McDowell and Anthony McDowell
(40) Pele Defense Fund
(55) Alfred Ibarra and Mary Ibarra
(56) Walter T.L. and Debra A. Wong Yuen
(63) Gwendolyn Sorensen 11/2/2018; 2:43 pm
Final EA, Pāhala LCC Replacement Project – Appendix E
Pāhala, Ka‘ū District, Hawai‘i
February 2020 47
(62) Prodincio Fuerte
(59) Larry O. Navarro 11/19/2018; 11:27 am
(60) Lisa Gollin 11/19/2018; 11:46 am
(61) Tanya Ibarra 12/3/2018; 8:19 am
(68) Dorothy Kalua
(67; 69; 70) Pele Defense Fund (2 duplicates) 12/10/2018; 6:15 am; 6:26 am; 6:26 am
(73) Ngaire Gilmour 12/10/2018; 5:01 pm
(74) Keoni Fox 12/10/2018; 5:43 pm
(76) Noelani Hong
(1) Sandra Demoruelle 9/24/2018; 8:57 am
(2) Sandra Demoruelle 9/24/2018; 10:26 am
(3) Sandra Demoruelle 9/24/2018; 11:15 am
(4) Sandra Demoruelle 9/24/2018; 1:21 pm
(5) Sandra Demoruelle 9/25/2018; 8:32 am
(6) Sandra Demoruelle 9/25/2018; 9:39 am
(7) Sandra Demoruelle 9/25/2018; 12:28 pm
(8) Sandra Demoruelle 9/25/2018; 12:39 pm
(9) Sandra Demoruelle 9/28/2018; 9:54 am
(10) Sandra Demoruelle 9/28/2018; 11:52 am
(11) Sandra Demoruelle 9/28/2018; 1:21 pm
(12) Sandra Demoruelle 9/28/2018; 1:43 pm
(13) Sandra Demoruelle 9/29/2018; 5:50 pm
(14) Sandra Demoruelle 10/1/2018; 10:29 am
(15) Sandra Demoruelle 10/1/2018; 10:41 am
(16) Sandra Demoruelle 10/3/2018; 8:17 am
(17) Sandra Demoruelle 10/6/2018; 9:00 am
(18) Sandra Demoruelle 10/10/2018; 10:50 pm
(19) Sandra Demoruelle 10/12/2018; 10:20 am
(20) Sandra Demoruelle 10/13/2018; 8:51 am
(21) Sandra Demoruelle 10/21/2018; 4:12 pm
(22) Sandra Demoruelle 10/24/2018; 4:03 pm
(39) Sandra Demoruelle 10/23/2018; 2:48 pm
(46) Sandra Demoruelle 10/31/2018; 8:03 am
(45) Sandra Demoruelle 10/31/2018; 8:13 am
(48) Sandra Demoruelle 10/31/2018; 11:39 am
(47) Sandra Demoruelle 10/31/2018; 12:41 pm
(49) Sandra Demoruelle 10/26/2018; 11:12 am
Final EA, Pāhala LCC Replacement Project – Appendix E
Pāhala, Ka‘ū District, Hawai‘i
February 2020 48
(50) Sandra Demoruelle 11/2/2018; 12:22 pm
(51) Sandra Demoruelle 11/5/2018; 9:26 am
(52) Sandra Demoruelle 11/6/2018; 11:51 am
(53) Sandra Demoruelle 11/8/2018; 11:52 am
(54) Sandra Demoruelle 11/13/2018; 12:40 pm
(57) Sandra Demoruelle 11/16/2018; 10:03 am
(58) Sandra Demoruelle 11/2/2018; 12:14 pm
(64) Sandra Demoruelle 12/10/2018; 2:36 pm
(65) Sandra Demoruelle 12/10/2018; 3:01 pm
(66) Sandra Demoruelle 12/10/2018; 3:29 pm
(75) Sandra Demoruelle 12/10/2018; 4:38 pm
(23a) Sandra Demoruelle 10/22/2018; USPS
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (32)March 6, 2020
Ms. Mary Alice Evans, Director, Office of State Planning235 South Beretania Street, 6th FloorHonolulu, Hawaii 96813
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻū,HawaiʻiResponse to Comment - October 17, 2018
Dear Ms. Evans:
Thank you for your October 17, 2018 comment letter (DTS201810160922NA) regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
1. No response required.
2. i. State Land Use Unpermitted Use ConsiderationA District Boundary Amendment is an option to the County Special Permit. However, a District Boundary Amendment to Urban would result in a spot designation where the surrounding area is currently designated as Agricultural by the State Land Use Commission and by the County in both the General Plan and Ka‘ū Community Development Plan. Also, this same surrounding area zoning designation is Agriculture (A-20a or A-1a) or MG-1a in the case of the adjacent macadamia nut facility. Overall, this spot zoning designation is not preferable in lieu of the Special Permit. This information will be included in the Final EA Section 2.10.3.
ii.The Hawaii State Planning ActThe Final EA will include the following discussion of Part III Priority Guidelines.
iii.PrinciplesofSustainabilityThe Final EA will include the followingdiscussion on this project's compatibilitywith theprinciples on sustainability, HRS §226-108.
The Final EA will include the following in Table 6.1:
10349-01Letter to Ms. Mary Alice Evans, Director, Page 2March 6, 2020
PART II. PLANNING COORDINATION and IMPLEMENTATION
Part II does not apply to the PƗhala Community Large Capacity Cesspool Replacement project.
PART III. PRIORITY GUIDELINES
2EMHFWLYHVDQG3ROLFLHVRIWKH+DZDLދL6WDWH3ODQ Discussion
§226-101 Purpose.The purpose of this part is to establish overall priority guidelines to address areas of statewide concern.
The Pāhala project will support applicable overall priority guidelines, as follows:
§226-102 Overall direction. The State shall strive to improve the quality of life for Hawaii's present and future population through the pursuit of desirable courses of action in seven major areas of statewide concern which merit priority attention: economic development, population growth and land resource management,affordable housing, crime and criminal justice, quality education, principles of sustainability, and climate change adaptation.
The Pāhala project will affect short-term economic development and jobs during the construction period. The Pāhala project will not affect economic development, population growth and land resource management, affordable housing, crime and criminal justice, quality education and climate change adaption. Removal of cesspools is consistent with the principles of sustainability.§226-103 Economic priority guidelines.(a) Priority guidelines to stimulate economic growth and encourage business expansion and development to provide needed jobs for Hawaii's people and achieve a stable and diversified economy. (e) Priority guidelines for water use and development:(1) Maintain and improve water conservation programs to reduce the overall water consumption rate.(2) Encourage the improvement of irrigation technology and promote the use of nonpotable water for agricultural and landscaping purposes.
The Pāhala project will stimulate economic development and jobs during the construction period.
§226-104 Population growth and land resources priority guidelines.(a) Priority guidelines to effect desired statewide growth and distribution:
The Pāhala project will d not affect population growth but may help protect the environment and improve water quality in nearby surface water resources.
10349-01Letter to Ms. Mary Alice Evans, Director, Page 3March 6, 2020
§226-105 Crime and criminal justice.Priority guidelines in the area of crime and criminal justice:
The Pāhala project will not affect crime or criminal justice in the Pāhala area.
§226-106 Affordable housing.Priority guidelines for the provision of affordable housing:
The Pāhala project will not affect affordable housing in the Pāhala area.
226-107 Quality education. Priority guidelines to promote quality education:The Pāhala project will not affect education in the Pāhala area.[§226-108] Sustainability. Priority guidelines and principles to promote sustainability include:(5) Promoting decisions based on meeting the needs of the present without compromising the needs of future generations.
The Pāhala project will close 2 large capacity cesspools, replacing them with secondary treatment and disposal systems, thereby protecting ground water resources for future generations, potentially benefitting the health and vitality of the area coastal and marine ecosystem.
[§226-109] Climate change adaptationpriority guidelines. Priority guidelines to prepare the State to address the impacts of climate change, including impacts to the areas of agriculture; conservation lands; coastal and nearshore marine areas; natural and cultural resources; education; energy; higher education; health; historic preservation; water resources; the built environment, such as housing, recreation, transportation; and the economy.
The wastewater treatment and disposal facility will be designed to contain the 100-year, 24-hour storm event while maintaining sufficient freeboard to account for the uncertainty of climate model projections..
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPA; C. Lekven, BC; P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (72)March 6, 2020
Mr. Kenneth G. Madsen II, Public Works ManagerPlanning SectionDepartment of Education State of Hawai‘iP.O. Box 2360Honolulu, HI 96804
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻū, HawaiʻiResponse to Comment - December 7, 2018
Dear Mr. Madsen:
Thank you for your December 7, 2018 comment letter regarding the County of HawaiʻiDepartment of Environmental Management (DEM) Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
The Final EA Section 2.3.2 will include the following:
As stated in Section 4.7.2 of the County of Hawai‘i, Department of Public Works, Final
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3ƗKDOD.Dµnj'LVWULFW$SULO: “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. ”
Further, the Ka‘ū Gym and Shelter Final EA states: “The Ka’ū High and Pahala ElementarySchool, including the Ka’ū District Gym and Shelter, will become accessible to the proposedCounty sewer system with the installation of two new laterals at the property line on HalaStreet and Kamani Street. While typically only a single lateral is provided for a lot, theadditional lateral on Hala Street is being installed to accommodate the project and create agravity flow connection.”
Information regarding project schedules, including US Environmental Protection Agency (USEPA) compliance dates, project updates and milestones can be found on the USEPA website
10349-01Letter to Mr. Kenneth G. Madsen IIPage 2March 6, 2020
at: https://www.epa.gov/uic/county-hawaii-administrative-order-consent-closure-cesspools-pahala-and-naalehu.
The County will also provide information about the construction schedule for the treatment and disposal facility and the collection system to the Facilities Development Branch Public Works Administrator on request. Impacts and mitigation measures for addressing construction-related dust, traffic and noise are addressed in the Draft EA Sections 3.14.2, 3.17.2 and 3.18.2.
Further, the County will coordinate with the HIDOE Student Transportation Services Branch Manager and the School in order to minimize construction-related impacts to student transportation services. This information will be included in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (35)March 6, 2020
M. Kaleo Manuel, Acting Planning Program ManagerState of Hawai‘iDepartment of Hawaiian Home Lands91-5420 Kaplolei ParkwayKapolei, HI 96707
Subject: Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement ProjectDistrict of Ka‘ū, HawaiʻiResponse to Comment – September 27, 2018
Dear Mr. Manuel:
Thank you for your September 27, 2018 comment letter regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. The Final Environmental Assessment(EA) will note that due to the lack of proximity to Hawaiian Home Lands properties, the Department of Hawaiian Home Lands does not anticipate any impacts to the lands or beneficiaries from the project.
The Draft EA Section 10.1 lists the Native Hawaiian Organizations consulted in preparation of the Draft EA. This information will be repeated in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (77)March 6, 2020
Mr. Russell Y. Tsuji, Land Administrator Land DivisionDepartment of Land and Natural ResourcesState of Hawai‘iPost Office Box 621Honolulu, HI 96809
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of,Kaʻū, HawaiʻiResponse to Comment, e-mail December 10, 2018
Dear Mr. Tsuji:
Thank you for your December 12, 2018 comment letter regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
The Draft EA Section 3.9.1 (a) states:
“The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM), Community Panel No. 155166 1800F, effective date September 29, 2017 shows 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-1is very close to the edge of the 500-year floodplain.
On April 16, 2018, in response to the pre-assessment notification, the State of Hawai‘i Department of Land and Natural Resources Engineering Division stated the responsibility for conducting research as to the flood hazard designation for the project site lies with the project proponent. Also on April 16, 2018 and in response to the pre-assessment notification, the County of Hawai‘i Department of Public Works confirmed that the proposed treatment and disposal project site at Site 7 is designated as Zone X on the FIRM and is outside the 500-year floodplain.”
10349-01Letter to Mr. Russell Y. TsujiPage 2March 6, 2020
This information will be repeated in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (71; 77)March 6, 2020
Mr. Russell Y. Tsuji, Land Administrator Land DivisionDepartment of Land and Natural ResourcesState of Hawai‘iPost Office Box 621Honolulu, HI 96809
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻū, HawaiʻiResponse to Comment - December 7, 2018
Dear Mr. Tsuji:
Thank you for your December 7, 2018 comment letter regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our response follows:
The Final EA will note the Land Division - HawaiʻiDistrict and the Division of Forestry and Wildlife had no comments.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (71;77)March 6, 2020
Mr. Russell Y. Tsuji, Land Administrator Land DivisionDepartment of Land and Natural ResourcesState of Hawai‘iPost Office Box 621Honolulu, HI 96809
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻū, HawaiʻiResponse to Comment - October 22, 2018
Dear Mr. Tsuji:
Thank you for your October 22, 2018 comment letter regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
The Final EA will include the Department of Land and Natural Resources Engineering Division had no additional comments, the Division of Forestry and Wildlife had no comments, and the Land Division - Hawaiʻi District had no objections.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (36)March 6, 2020
Chief Paul Ferreira, Police ChiefCounty of Hawai‘iPolice Department349 Kapiolani StreetHilo, HI 96720
Attention: Captain Miles Chong, Commander Ka‘ū District
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Ka‘ū, HawaiʻiResponse to Comment – October 2, 2018
Dear Chief Ferreira:
Thank you for your October 2, 2018 comment letter regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment for the Pāhala Large Capacity Cesspool Replacement project. The Final Environmental Assessment (EA) will note that the County of Hawaiʻi Police Department has reviewed the Draft EA and does not have any comments or concerns at this time.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (37)March 6, 2020
Mr. Ruby Javar P.O. Box 847 Pāhala, HI 96777
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻū, HawaiʻiResponse to Comment – October 10, 2018
Dear Mr. Javar:
Thank you for your October 10, 2018 comment letter regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool (LCC) Replacement project. Our responses follow:
The Draft EA Section 2.7 describes the site selection process, including the factors and their relative weights used to evaluate the various sites. Further, Section 2.7 describes the twenty-one criteria within four general categories (environmental, social and cultural; location and site; land use and availability; and collection system and service area) that were established and defined for the analysis. The Draft EA Appendix B, Section 8, provides additional information regarding the site selection process. As a result of this process, the County identified three sites (Sites 7, 8, and 9) as reasonable alternatives for construction of the wastewater treatment and disposal facilityunder the Proposed Action. The final scores for Sites 7, 8, and 9 were 4.33, 4.06, and 4.10 respectively, out of a total possible score of 5. Based on this analysis, Site 7 was selected as the Preferred Alternative. The site is easily accessible, has good soils for a land application system, and is close to the existing LCCs.
The Draft EA Section 2.5 describes Site 9, which is south (makai) of the Preferred Alternative Site 7. As outlined in Appendix B Section 8, Site 9 earned a lower ranking than Site 7 for the following criteria: presence of and/or proximity to archaeological/cultural sites, existing vehicle access, power and potable water availability, and distance from the area of the wastewater collection system. Site 7 had a lower ranking than Site 9 in one category: topography. With the distance between the two sites less than 300 feet, they were ranked equally for the criteria of proximity of treatment units to existing occupied buildings.
The Draft EA Sections 2.5 and 2.7 provide information as to the issues related to the use of Site 9. An unnamed stream near the upper portion of the parcel could affect the selectedconfiguration of the wastewater treatment facility and the land application groves. Potentially, to maximize energy efficiency by taking advantage of gravity flow, the headworks, lagoons and the
10349-01Letter to Mr. Ruby Javar Page 2March 6, 2020
subsurface constructed wetlands could be sited in the upper portion of the site, or the area closest to the highway. In addition, since the site is located across Māmalahoa Highway from the Pāhala community, it would require construction of piping and other utilities within the highway ROW and approval by the State of Hawaiʻi Department of Transportation. Site 9 would require additional access roads to facilitate both construction and operation of the treatment and disposal facility and a slightly longer transmission line given its increased distance from the existing LCCs.
This information will be included in the Final EA.
The comment referencing fines is not specifically a comment to the content of Draft EA, and the potential for penalties to be levied against the County by the EPA for failure to close the LCCs is unrelated to the site selection process.
The Draft EA Section 2.3.2 states the new collection system would be subject to the County of Hawaiʻi Code (HCC) Chapter 21, Sewers. Specifically, HCC Chapter 21, Article 2 (Public Sewers), Section 21-5, which 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.”
The financial impact of the project on individual newly accessible property owners was raised by the community during the December 2017 public meetings. Although not required by Hawaii Administrative Rules (HAR) Title 11, Chapter 200, Department of Environmental Management voluntarily convened two additional public meetings in Pāhala, one on October 9, 2018 and the second on March 21, 2019 to gain further input from newly accessible property owners and present funding options for them to pursue.
The Draft EA Section 7 will be revised to add that the County held additional meetings in Pāhala including one to provide information on financing sources available to owners of parcels which would become accessible to the County collection system. The purpose of the March 21, 2019 meeting was to fulfill a County commitment made in October, 2018 to research financing options available to the newly accessible residents of the Pahala Community. At the meeting, Department of Environmental Management provided the preliminary results of the County investigation into funding sources and options available for newly accessible property ownersonce the new treatment and disposal facility and wastewater collection system have been designed, permitted and constructed.
10349-01Letter to Mr. Ruby Javar Page 3March 6, 2020
Programs discussed included:
x US Department of Housing and Urban Development (HUD) with County of Hawaii Office of Housing and Community Development Residential Repair Program -Community Block Grant Program, and x US Department of Agriculture - Rural Development (USDA-RDA) Program.
As noted during the presentation, these programs may change in the coming years, and additional options may be added to this preliminary list. Hawaii Legislature, Senate Bill 221 SD1, which could amend Hawaii Revised Statutes (HRS) Chapter §342D to establish a low interest loan program to offer financial assistance to cesspool owners to connect to wastewater treatment systems approved by the Department of Health was also discussed; however, this bill was subsequently not passed during the 2019 legislative session.
This information will be included in the Final EA.
The Draft EA Section 3.16 discusses the socioeconomic characteristics of and impacts on the Pahala community.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (27)March 6, 2020
Ms. Tina TuttleP.O. Box 727177Naalehu, HI 96722
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Ka‘ū, HawaiʻiResponse to Comment – October 10, 2018
Dear Ms. Tuttle:
Thank you for your October 10, 2018 comment letter regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our response follows:
The Elementary School Complex, the portion of campus closest to the treatment and disposal facility within the Ka‘ū High and Pāhala Elementary School campus, lies more than ½ mile directly or about 1 mile away from the treatment and disposal facility by road. From the school, one must travel on a portion of the school parcel and on 5 streets to reach the fenced wastewater treatment and disposal facility. The intervening streets access or abut residential parcels and other land uses. The distance and intervening land uses show the treatment and disposal facility is not located in close proximity to a school facility. This information will be included in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (27)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Ka‘ū, HawaiʻiResponse to Comment – October 10, 2018
Dear Ms. Demoruelle:
Thank you for your October 10, 2018 comment letter regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
M-1Hawaii Revised Statutes (HRS) Section 343-5 Applicability and requirements(a) states “Except as otherwise provided, an environmental assessment shall be required for actions that: (1) Propose the use of state or county lands or the use of state or county funds…” as well as, “(9) Propose any: (A) Wastewater treatment unit…”
However, Hawaii Administrative Rules (HAR) Title 11, Chapter 200, which implements HRS Chapter 343, differentiates between “agency actions” - those proposed by an agency to utilize state or county lands or funds; and, “applicant” actions” – those for which an applicant requires approval from an agency.
The Pāhala Large Capacity Cesspool Replacement project is a proposal by an agency (Department of Environmental Management) to use County funds, thereby “triggering” the need for an EA.
The September 23, 2108 Environmental Notice provided the following project description:“The County of Hawaiʻi Department of Environmental Management proposes to construct wastewater system improvements replacing the large capacity cesspools (LCCs) currently serving Pāhala, in order to comply with U.S. Environmental Protection Agency (EPA) regulations. The project improvements would include a new wastewater collection system located primarily within public streets in the Pāhala community, and a treatment and disposal system on land to be acquired by the County (TMK: 9-6-002: 018). The project would be partially funded by an EPA grant and by the Clean Water State Revolving Fund loan program.
10349-01Letter to Ms. Sandra Demoruelle Page 2March 6, 2020
The collection system would consist of approximately 12,150 linear feet of 8 to 12-inch diameter underground gravity flow piping in Maile, ʻIlima, Huapala, Hīnano, Hala, Puahala and Pīkake Streets. The treatment and disposal facility would occupy about 14.9 acres and consist of a headworks and an odor control unit, an operations building, four lined aerated lagoons, a subsurface flow constructed wetland to remove nitrogen with an adjacent disinfection system to remove pathogens, and four slow rate land treatment basins for further treatment and disposal of the treated effluent. A perimeter security fence would enclose the entire facility. The existing LCCs and associated wastewater collection system would be abandoned.”
M-2- N/A
M-3Hawaii Administrative Rules Title 11 Department of Health Chapter 200 §11.1(d) does not include a requirement to withdraw a determination. Nor, is there a time stated for such a withdrawal.
M-4The public outreach subcontractor did not prepare the Draft EA.
M-5This is not a comment on the content of the Draft EA for the Pāhala Large Capacity Cesspool Replacement project.
M-6The quoted statement was from the Councilmember for the Kona district, in relation to the Kealakehe Aeration Upgrade and Sludge Removal project. The Kealakehe Aeration Upgrade and Sludge Removal project is not the subject of this Draft EA. The County of HawaiʻiDepartment of Environmental Management considers the Pāhala Large Capacity Cesspool Replacement project important.
M-7As stated in the article, additional funding for the Kealakehe Aeration Upgrade and Sludge Removal project was requested to replace the “badly eroded liners in several of the lagoons”. The liner replacement was outside of the original project scope. Expanding the scope of any project generally necessitates additional cost in order to complete the work associated with that expanded scope.
M-8Hawaiʻi Administrative Rules (HAR) Title 11 Chapter 200-10 Contents of an environmental assessment does not include a requirement for evaluating the fiscal impacts of a project on a County’s budget or ability to obtain funding.
10349-01Letter to Ms. Sandra Demoruelle Page 3March 6, 2020
M-9The Draft EA Section 2.7 describes the site selection process, including the factors and their relative weights used to evaluate the various sites. Further, Section 2.7 describes the twenty-one criteria within four general categories (environmental, social and cultural; location and site; land use and availability; and collection system and service area) that were established and defined for the analysis. The Draft EA, Appendix B, Section 8, provides additional information regarding the site selection process. As a result of this process, the County identified three sites (Sites 7, 8, and 9) as reasonable alternatives for construction of the wastewater treatment and disposal facility under the Proposed Action. The final scores for Sites 7, 8, and 9 were 4.33, 4.06, and 4.10 respectively, out of a total possible score of 5. Based on this analysis, Site 7 was selected as the Preferred Alternative. The site is easily accessible, has good soils for a land application system, and is close to the existing LCCs.
The Draft EA Section 2.5 describes Site 9, which is south (makai) of the Preferred Alternative Site 7. As outlined in Appendix B Section 8, Site 9 earned a lower ranking than Site 7 for the following criteria: presence of and/or proximity to archaeological/cultural sites, existing vehicle access, power and potable water availability, and distance from the area of the wastewater collection system. Site 7 had a lower ranking than Site 9 in one category: topography. With the distance between the two sites less than 300 feet, they were ranked equally for the criteria of proximity of treatment units to existing occupied buildings.
The Draft EA Sections 2.5 and 2.7 provide information as to the issues related to the use of Site 9. An unnamed stream near the upper portion of the parcel could affect the selected configuration of the wastewater treatment facility and the land application groves. Potentially, to maximize energy efficiency by taking advantage of gravity flow, the headworks, lagoons and the subsurface constructed wetlands could be sited in the upper portion of the site, or the area closest to the highway. In addition, since the site is located across Māmalahoa Highway from the Pāhala community, it would require construction of piping and other utilities within the highway ROW and approval by the State of Hawaiʻi Department of Transportation. Site 9 would require additional access roads to facilitate both construction and operation of the treatment and disposal facility and a slightly longer transmission line given its increased distance from the existing LCCs.
This information will be repeated in the Final EA.
M-10The Draft EA Section 2.2 sets forth the purpose of the Pāhala Large Capacity Cesspool Replacement project: “The purpose of the actions considered in this Environmental Assessment (EA) is to provide the infrastructure necessary to enable the County to comply with the SDWA and fulfill the compliance provisions of the AOC between EPA and the County with respect to closure of the Pāhala LCCs”. The remaining portions of the Pāhala community are not serviced by the LCCs and hence not included in the Pāhala Large Capacity Cesspool Replacement
10349-01Letter to Ms. Sandra Demoruelle Page 4March 6, 2020
project. The Draft EA Figure 2.6 shows the area of the community serviced by the current and proposed collection system.
The Draft EA Section 2.3.1 states the treatment and disposal facility will be designed to provide an average dry weather flow capacity of 190,000 gallons per day, which will be sufficient capacity to allow the closure of the two LCCs. In addition, the Draft EA Appendix B states the wastewater treatment plant (WWTP) designed not to preclude treating future average dry weather flows up to 360,000 gpd to meet the future needs of the community, in accordance withthe requirements established in the Ka‘ū Community Development Plan Policy 120.
M-11The Draft EA Section 4 discusses Cumulative Effects including the scope of analysis and also actions considered but excluded from analysis.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (28)March 6, 2020
Dr. B Noelani Hong Via email: noealoha@gmail.com
Subject: Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement ProjectDistrict of,Ka‘ū, Hawaiʻi Response to Comment - October 28, 2018 11:38 a.m.
Dear Dr. Hong:
Thank you for your October 28, 2018 11:38 a.m. comment message regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our response follow:
The County is aware of two existing culverts that allow stormwater to flow across the Māmalahoa Highway in the vicinity of the project. The first is a box culvert located at the intersection with Maile Street that conveys stormwater under the highway. The second culvert is located approximately 600 feet east of the Maile Street intersection and was used to convey sugar mill flume water across the highway for disposal.
The Draft EA Figure 2.3 shows the intersection of Maile Street and Māmalahoa Highway lies at about 580 feet above mean sea level (MSL). The Draft EA Figure 2.2 shows the Pāʻauʻau Gulch crosses underMāmalahoa Highway near the hospital about 0.88 miles north of that intersection and lies at approximately 780 feet MSL or about 200 feet higher in elevation than the culvert at the Maile Street and Māmalahoa Highway intersection. Due to this distance and the elevation difference, surface flows at Site 7 would not affect the gulch. Similarly, the Kaimani Street and Māmalahoa Highway intersection lies about 0.84 miles north of the proposed facility site and at about 780 feet MSL. Surface flows at the facility would also not affect that intersection. Figures 2.2 and 2.3 will be repeated in the Final EA.
The Draft EA Section 3.9.1 (a) states:
“The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM), Community Panel No. 155166 1800F, effective date September 29, 2017 shows 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
10349-01Letter to Dr. B Noelani HongPage 2March 6, 2020
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.
On April 16, 2018, in response to the pre-assessment notification, the State of Hawai‘i Department of Land and Natural Resources Engineering Division stated the responsibility for conducting research as to the flood hazard designation for the project site lies with the project proponent. Also on April 16, 2018 and in response to the pre-assessment notification, the County of Hawai‘i Department of Public Works confirmed that the proposed treatment and disposal project site at Site 7 is designated as Zone X on the FIRM and is outside the 500-year floodplain.”
The relevant FIRM panel is reproduced in Appendix B as Figure 4-13.
This information will be repeated in the Final EA.
Draft EA Section 3.23.2 (a) states:
“The proposed wastewater treatment and disposal facility would include an on-site drainage system to address stormwater surface runoff created by new impervious surfaces within the facility. The site would include a system to collect runoff via grated inlets or swales, and flows would be conveyed to on-site drainage detention systems, such as subsurface linear infiltration or depressed detention basins.”
This information will be repeated in the Final EA.
The preferred alternative (Site 7) slopes from approximately north to south (mauka to makai) such that, during rain events, surface flows pass through the existing orchard to the southern (makai) end where the flows eventually drain through the culvert located at the Maile Street-Māmalahoa Highway intersection to the areas below (makai) the highway. Most of the land surface area below the existing macadamia nut orchard contains little to no vegetation to absorb or slow these flows. The gradient of Site 7 and surrounding area results in this natural pattern of surface flows which also existed when the area was planted in sugar cane and is not considered flooding.
Based on the roadway flooding concerns expressed by the community during the Pahala public meetings held in December 2017 and October 2018, the State of Hawai‘i Department of Transportation (DOT) Hawai‘i District office was contacted to discuss drainage at the treatment and disposal facility project site and the culvert at the Maile Street and Māmalahoa Highway intersection. On February 20, 2019, the District office confirmed via telephone that the DOT
10349-01Letter to Dr. B Noelani HongPage 3March 6, 2020
owns and maintains the culvert at the Maile Street intersection, and that they have no record of the roadway being inundated by stormwater drainage during precipitation events at that location.
Stormwater runoff generated mauka of the treatment and disposal facility project site will be directed around the perimeter of the site via diversion swales that will convey flow back to the existing drainage pattern that flows to the existing culvert at Maile Street. During heavy rain events, stormwater may temporarily back up behind the culvert. There will be no changes to this culvert and the proposed treatment and disposal facility will not be located within the area of the culvert.
As stated in the Draft EA, the on-site stormwater management system would meet the requirements of Hawai‘i County Code (HCC), Chapter 27 Floodplain Management, Section 20, Standards for subdivisions and other developments (e) which mandates a site drainage plan to “comply with sections 27-20(a) and (b) and section 27-24, and shall include a storm water disposal system to contain run-off caused by the proposed development, within the site boundaries, up to the expected [design] storm event, as shown in the department of public works “Storm Drainage Standards”.
To meet the requirements of HCC, Chapter 27, Section 20 (f), the project “shall not alter the general drainage pattern above or below the development”. Thus, for the HCC design storm event, no increase in flow amount will be directed to either of the culverts at the highway as a result of the site development. A drainage report will be prepared during the design process to evaluate the improvements necessary to comply with HCC Chapter 27 requirements.
The wastewater treatment processes will be designed to accommodate the associated peak flows, including precipitation that falls on the area occupied by the aerated lagoon treatment system. The Draft EA Appendix B, Section 2.2 outlines the anticipated peak wastewater flows from the community, based on the applicable flow standard. The Draft EA Section 2.3.1 states the aerated lagoons will be lined to prevent water seepage through the bottom and sides of the lagoons. The Draft EA Appendix B, Section 5.3 shows the operational freeboard that will be available to contain and to equalize lagoon flows during. In addition, the slow-rate land application groves will be designed to completely contain both peak effluent flows and precipitation from a 100-year, 24-hour storm event. A geotechnical engineering assessment of berm stability will be conducted during the design process. The tree groves will be designed in accordance with the EPA’s “Process Design Manual, Land Treatment of Municipal Wastewater Effluents”. Effluent will be applied at a hydraulic loading rate that is a small percentage of the percolation rate of the soil, ensuring sufficient capacity for assimilation of peak effluent flow rates and precipitation from the design storm event.
This information will be included in the Final EA.
10349-01Letter to Dr. B Noelani HongPage 4March 6, 2020
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (44)March 6, 2020
Mr. Dale A. Loperz75dloter_sv9@dallop.us
Subject: Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement ProjectDistrict of Ka‘ū, HawaiʻiResponse to Comment - September 29, 2018 7:46 a.m.
Dear Mr. Loper:
Thank you for your September 29, 2018 7:46 a.m. comment message regarding the County ofHawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our response follows.
As stated in the Draft EA Section 2.1.4, in 2003, C. Brewer requested assistance from the County to close the large capacity cesspools (LCCs) in Pāhala. Further, “Voting took place via mail for the Pāhala community to choose the preferred sewer improvement alternative resulting in 87 percent of the returned ballots in favor of installation of a new sewer collection system and a treatment and disposal system to be operated and maintained by the County.”
The Draft EA Section 2.3.1 states the treatment and disposal facility will be designed to provide an average dry weather flow capacity of 190,000 gallons per day. In addition, the Draft EA Appendix B states the wastewater treatment plant (WWTP) will be designed not to preclude expansion to treat future average dry weather flows up to 360,000 gpd to meet the future needs of the community, in accordance with the requirements established in the Ka‘ū Community Development Plan Policy 120. The information provided in your message shows units with a treatment capacity of 250 to 2,000 gallons per day. Thus, these systems do not have sufficient capacity to accommodate the flows for the Pāhala Large Capacity Cesspool Replacement project.
Use of a system of 250 to 2,000 gallons per day to treat the wastewater generated by each privately-owned parcel in the community currently served by the LCCs would likely necessitate siting multiple units within private property. As outlined in the Draft EA, Appendix B Section 7.5.4, issues associated with individual wastewater systems include:
x locating the treatment units within developed private parcels, many of which are small (less than 10,000 square feet) and significantly improved,
x insufficient land area within developed private parcels to effectively use/dispose of treated effluent without impacting adjacent parcels, and
10349-01 Letter to Mr. Dale A. Loper Page 2March 6, 2020
x soil conditions and subsurface geology unsuitable for effluent disposal compliant withHawaiʻi Administrative Rules (HAR) Title 11 Chapter 62-34 requirements, potentiallynecessitating the import of suitable fill soils or elevated mound systems.
This information will be repeated in the Final EA.
Additional issues include: access for construction equipment, ownership of the units, and operation and maintenance of the units either by the County of Hawaiʻi on private property or by individual property owners in this remote location.
This information will be added to the Final EA, section 2.8.2.
Based on the above, use of small capacity treatment units for this project does not appear to be a practical and feasible option for the County.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng Project Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWD K. Rao, EPA C. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (29)March 6, 2020
Ms. Ngaire Gilmourngaire.joy@gmail.com
Subject: Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻū, HawaiʻiResponse to Comment - October 17, 2018 10:30 a.m.
Dear Ms. Gilmour:
Thank you for your October 17, 2018 10:30 a.m. comment message regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Community Large Capacity Cesspool (LCC) Replacement project.
The Draft EA Section 6.2.2 discusses the Ka‘ū Community Development Plan (CDP): “Section 5 of the CDP prioritizes improvements in infrastructure, facilities, and services, including Section 5.8 which applicable to …Environmental management facilities, including expanded sewer lines, …”. As you noted, Policy 120 is to “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 accommodating the Pāhala community. Similarly, the treatment and disposal facility has been designed not to preclude accommodating the wastewater flows from the collection system from the Pāhala community.
The Draft EA Section 2.2 describes the purpose of the Pāhala Large Capacity Cesspool Replacement project is to close the Pāhala large capacity cesspools (LCC).The Draft EA Section 2.3.2 discusses the construction of a new sewer collection system in the Pāhala community to replace the existing system of substandard gravity lines that currently conveys sewage to the two LCCs. As described in Section 6.2.1, the current collection system includes facilities located in the backyards of many parcels. Where easements for the existing collection system aren’t accessible, the County must obtain permission from individual landowners to enter them, through private property, to inspect, maintain, repair or replace existing sewer facilities: all activities essential to an efficient, functioning system. As a result, the proposed new collection system would consist of a total of approximately 12,150 linear feet (LF) (2.3 miles) of corrosion-resistant polyvinyl chloride (PVC) piping located almost entirely within the right of way (ROW)of eight public streets.
10349-01Letter to Ms. Ngaire GilmourPage 2March 6, 2020
Also as outlined in the Draft EA, Section 2.3.2, the new collection system would be subject to the Hawaiʻi County Code (HCC) Chapter 21, Sewers, specifically, Article 2 (Public Sewers), Section 21-5, which 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.”
Each adjacent lot will be provided with a lateral connection to the sewer main as required by HCC and standards. Under the Preferred Alternative, the design of the new collection system would extend between street intersections and include sewer service stub-outs (the lateral connection to the sewer main) to the lot lines of adjacent properties, including the newly accessible, to accommodate their eventual connection. Accordingly, to close the existing LCCs, there will be additional properties in Pāhala that would be required to connect to the new wastewater collection system, at their expense, after it becomes operational. Such properties are near the existing service area but are presently connected to individual wastewater systems. To conform to the stated section of HCC, the respective, newly accessible property owners would be responsible for the design, permitting and completion of sewer service connections between the County stub-outs and improvements for stated uses on their property, as well as for the proper closure of their individual wastewater systems. The Draft EA Figure 2.6 shows the area of the community serviced by the current and proposed collection systems.
The above information will be repeated in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (30)March 6, 2020
Mr. Jerome WarrenP.O. Box 951Naalehu, Hawaii 96722
Subject: Draft Environmental Assessment (EA)Pāhala Large Capacity Cesspool Replacement ProjectDistrict of,Ka’ū, HawaiʻiResponse to Comment - October 19, 2018
Dear Mr. Warren:
Thank you for your October 19, 2018 comment letter regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our response follows:
The Draft EA, Section 2.8.2(a), discusses use of a community septic tank as follows:
“Community Septic Tank. Based on current design criteria and current flow projections, an approximately 800,000-gallon community septic tank would be necessary to provide the extended detention times needed to optimize treatment performance, to avoid the need for frequent septage pumping, and to account for peak flow rates. A community septic tank of this size would require pumping on a 3-year interval. Septic tanks produce hydrogen sulfide, reduced sulfur compounds, and other odorous gases; a community septic tank would concentrate these emissions to a single point source, requiring treatment with a dual-stage scrubber to avoid nuisance odor conditions. More significantly, a community septic tank would not be capable of achieving the effluent quality standards (less than 30 mg/L of both BOD5 and TSS) specified in HAR 11-62-23.1. Therefore, use of a community septic tank is not considered to be feasible.”
Further details for the use of community septic tanks are also provided in the Draft EA, Appendix B, Section 7.5.1 and 7.5.2 including the need for a DOH variance from HAR 11-62-23.1 requirements (which must be renewed every five years), and the need to provide for wastewater treatment and disposal capacity to meet the rest of the community’s current andfuture needs.
The Draft EA Section 2.9 discusses the relationship between the current project and the 2007 Final EA for the Naalehu-Pāhala Large Capacity Cesspool (LCC) Conversion project. As stated in Section 2.9:
10349-01Letter to Mr. Jerome WarrenPage 2March 6, 2020
“After the issuance of the Final EA and Negative Declaration/FONSI in 2007, the County conducted additional study and evaluation of the proposed LCC conversion project. The County eventually concluded that the LCC conversion project described in the 2007 Final EA would not meet the need to provide a collection system and a treatment and disposal facility, close the LCCs, and provide for the future needs of the Pāhala community. This determination was based on several factors…”
The Draft EA Section 2.8.2 (a) discusses the conversion of LCC1 to a seepage pit for septic tank effluent disposal, as documented below:
x “Converting LCC to Seepage Pit. Converting LCC 1 to a seepage pit regulated as an injection well (LCC 2 could not be converted as it is on private land) would lead to numerous potential compliance issues with HAR 11-23-07, which regulates injection wells. The condition and structure of LCC 1 is unknown, and HAR 11-62-25 requires all new and proposed effluent disposal systems are required to have a backup system. No such system could be feasibly constructed as new injection wells are not allowed.”
Pāhala is located mauka of the UIC line, as such conversion of one or more LCC to a seepage pit for disposal of septic tank effluent would be subject to HRS 340E and Hawaiʻi AdministrativeRules Title 11, Department of Health, Chapter 23, Underground Injection Control (HAR Chapter 23). In 2018, H.B. No, 1934, H.D. 1, S.D. 2 was enacted as Act 131 which amended Section 340E-2 to add:
“The director shall promulgate regulations establishing an underground injection control
program. Such program shall prohibit any underground injection which is not authorized by
a permit issued by the director; provided that the director shall not issue permits for the
construction of sewage wastewater injection wells unless alternative wastewater disposal
options are not available, feasible, or practical;”
The Draft EA Section 2.8.2 (a) also discusses the leachfield option considered for septic tank effluent disposal as outlined below: “Leachfield Disposal. To meet DOH’s leachfield design criteria, a minimum of 30 acres of land would be required to meet loading rate and redundancy requirements. Achieving even distribution of effluent over a leachfield of this size would be challenging. Therefore, leachfield disposal is not considered to be feasible.”
The above information will be repeated in the Final EA.
The Draft EA Section 7.0 provides information regarding the community outreach program for the current proposed action, including meetings starting in December 2017.
The Draft EA Section 2.1.4, History of Wastewater Management in Pāhala, will be expanded in the Final EA to provide the following additional information:
10349-01Letter to Mr. Jerome WarrenPage 3March 6, 2020
Field investigation conducted on February 4, 2009 on the property conveyed by C. Brewer for a treatment/disposal site in Nā‘ālehu showed unacceptable percolation rates, making converted seepage pit or leach field options less desirable in this area.
On December 13, 2008 a community meeting sponsored by Councilman Guy Enriques was held at the Nā‘ālehuCommunity Center to discuss the Nā‘ālehu and Pāhala Large Capacity Cesspool Replacement project. As part of the meeting,an informational handout prepared by the County’s Wastewater Division stated that adequate land for the treatment and disposal system had not been identified in Pāhala. A preliminary location for a treatment and disposal site below the Old Pāhala Mill site was not acceptable due to reports of archaeological sites in the area, and outlined the benefits of a lagoon type treatment and disposal system. At an April 25, 2010 community meeting at the Pahala Community Center, which was also sponsored by Councilmember Enriques, the meeting informational handout stated the County was investigating available properties for siting wastewater treatment/disposal facility in Pahala. The handout also stated that all properties accessible to the new sewer system would be required to connect in accordance with Hawaii County Code Chapter 21.
Also, although not specific to the Pāhala project, it was stated at a July 22, 2016 2:00 p.m. presentation at the Nā‘ālehu Community Center that the County had purchased the parcel containing the makahiki grounds in Nā‘ālehu for a lagoon type wastewater treatment/leach field disposal system.
The Draft EA Section 7 provides information regarding the five “talk story” sessions held in December 2017. Section 7 identifies the various issues, concerns, environmental impacts and mitigations measures which were addressed in the Draft EA.
On September 26, 2018, a public notice was published in both the Hawaii Tribune Herald and West Hawaii Today to advertise the October 10, 2018 public information meeting conducted by the County in Pāhala at the Ka‘ū Gym Multi-Purpose Conference Room to discuss the availability of the Draft EA and process for submitting comments. A public notice was also published in the October 1, 2018 online and print editions of the Ka‘ū Calendar and made available on the Ka‘ū News Briefs web site http://kaunewsbriefs.blogspot.com. All materials circulated, posted and published for the October 2018 meetings included the electronic link to the Draft EA at http://health.hawaii.gov/oeqc/.
The Draft EA was made available online on the County of Hawai‛i and EPA websites and in public libraries in Nāʻālehu and Pāhala beginning on September 23, 2018. Upon public request, 11 printed copies of the Draft EA were made available at both the Nāʻālehu and Pāhala libraries on November 7, 2018. The County’s transmittal requested the library make the copies available for checkout. The Draft EA was also posted on the County of Hawaii and EPA websites at:
10349-01Letter to Mr. Jerome WarrenPage 4March 6, 2020
http://records.co.hawaii.hi.us/weblink/1/edoc/96064/Pahala%20FINAL%20DRAFT%20EA%20and%20Appendices_508_9-11-18.pdfhttps://www.epa.gov/uic/proposed-pahala-community-large-capacity-cesspool-replacement-project-draft-environmental
At the October 10, 2018, public information meeting, the County provided staff to personally assist commenters in preparing written comments on the Draft EA. In addition, during this meeting, the County identified community volunteers attending the meeting who were proficient in Hawaiian, Tagalog, and English to assist anyone who identified as needing assistance in providing written comments on the Draft EA.
The public notice also stated that a second part of the meeting on October 10, 2018 would address Section 106 of the National Historic Preservation Act (NHPA) involving consultation with Native Hawaiian Organizations and Native Hawaiian descendants with ancestral lineal or cultural ties to, cultural knowledge or concerns for, or cultural religious attachment to the proposed project area. Eight persons placed their names on a sign-in sheet to contribute during the Section 106 part of the meeting; however, no comments or information from the public were forthcoming during this meeting.
Appropriate portions of this historical information related to public outreach regarding closure of the Pāhala LCCs will be included in the Section 7 of the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (31)March 6, 2020
Ms. Ngaire Gilmourngaire.joy@gmail.com
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Ka‘ū, HawaiʻiResponse to Comment -October 20, 2018 12:40 p.m.
Dear Ms. Gilmour:
Thank you for your October 20, 2018 12:40 p.m. comment message regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
1.a) The Draft EA Section 2.2 describes the purpose of the Pāhala Large Capacity Cesspool Replacement project is to close the Pāhala large capacity cesspools (LCC). The Draft EA Section 2.3.2 discusses the construction a new sewer collection system in the Pāhala community to replace the existing system of substandard gravity lines that currently conveys sewage to the two LCCs. As described in Section 6.2.1, the current LCC collection system includes lines located the backyard of many parcels. Where easements for the existing collection system aren’t accessible, the County must obtain permission from each landowner to enter them, through private property, to inspect, maintain, repair, or replace existing sewer facilities: all activities essential to an efficient, functioning system. As a result, the proposed new collection system will be located within the public street rights-of-way and to close the LCCs, there will be parcels that become “newly accessible” to the collection system. The collection system is not being expanded under the proposed action beyond the area needed to close the LCCs. This information will be repeated or included in the Final EA.
b) The Draft EA Section 2.3.2 discusses Hawai‘i County Code, Chapter 21, specifically, Article 2 (Public Sewers), Section 21-5, which 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.
10349-01Letter to Ms. Ngaire GilmourPage 2March 6, 2020
The financial impact of the project on individual newly accessible property owners was raised by the community during the December 2017 public meetings as summarized in Section 7 of the Draft EA. Although not required by Hawaii Administrative Rules (HAR) Title 11, Chapter 200, DEM voluntarily convened two additional public meetings on October 9, 2018 and March 21, 2019 to gain further input from newly accessible property owners and present funding options for them to pursue.This information will be added to the final EA Section 7.
c) County Council approval would be required to grandfather or fund connections of newly accessible properties to the new collection system.
2.Although the project does not currently include alternative energy systems such as photovoltaic, solar or wind power as a total replacement to the HELCO grid, feasible alternatives utilizing energy systems can be added in the future if prioritized and funded by County Council. A source of methane is not currently available in the Pāhala area, natural gas distribution infrastructure is not in place in this remote location, and the Proposed Alternative, utilizing natural, low energy, treatment systems does not provide for wastewater-related methane production and capture.
3.The Draft EA Section 2.7 describes the site selection process, including the factors and their relative weights used to evaluate the various sites. Further, Section 2.7 describes the twenty-one criteria within four general categories (environmental, social and cultural; location and site; land use and availability; and collection system and service area) that were established and defined for the analysis. The Draft EA Appendix B, Section 8, provides additional information regarding the site selection process. As a result of this process, the County identified three sites (Sites 7, 8, and 9) as reasonable alternatives for construction of the wastewater treatment and disposal facility under the Proposed Action. The final scores for Sites 7, 8, and 9 were 4.33, 4.06, and 4.10 respectively, out of a total possible score of 5. Based on this analysis, Site 7 was selected as the Preferred Alternative. The site is easily accessible, has good soils for a land application system, and is close to the existing LCCs.
The Draft EA Section 2.5 describes Site 9, which is south (makai) of the Preferred Alternative Site 7. As outlined in Appendix B Section 8, Site 9 earned a lower ranking than Site 7 for the following criteria: presence of and/or proximity to archaeological/cultural sites, existing vehicle access, power and potable water availability, and distance from the area of the wastewater collection system. Site 7 had a lower ranking than Site 9 in one category: topography. With the distance between the two sites less than 300 feet, they were ranked equally for the criteria of proximity of treatment units to existing occupied buildings.
The Draft EA Sections 2.5 and 2.7 provide information as to the issues related to the use of Site 9. An unnamed stream near the upper portion of the parcel could affect the selected
10349-01Letter to Ms. Ngaire GilmourPage 3March 6, 2020
configuration of the wastewater treatment facility and the land application groves. Potentially, to maximize energy efficiency by taking advantage of gravity flow, the headworks, lagoons and the subsurface constructed wetlands could be sited in the upper portion of the site, or the area closest to the highway. In addition, since the site is located across Māmalahoa Highway from the Pāhala community, it would require construction of piping and other utilities within the highway ROW and approval by the State of Hawaiʻi Department of Transportation. Site 9 would require additional access roads to facilitate both construction and operation of the treatment and disposal facility and a slightly longer transmission line given its increased distance from the existing LCCs.
The above information will be repeated in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (33)March 6, 2020
Mr. Edward Andrade, Jr. P.O. Box 514Pāhala, Hawaii 96777
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Ka‘ū, HawaiʻiResponse to Comment - October 19, 2018
Dear Mr. Andrade:
Thank you for your October 19, 2018 comment letter regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
A.The County is aware of two existing culverts that allow stormwater to flow across the Mamalahoa Highway in the vicinity of the project. The first is a box culvert located at the intersection with Maile Street that conveys stormwater under the highway. The second culvert is located approximately 600 feet east of the Maile Street intersection and was used to convey sugar mill flume water across the highway for disposal.
The Draft EA Section 3.9.1 (a) states:
“The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM), Community Panel No. 155166 1800F, effective date September 29, 2017 shows 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-1is very close to the edge of the 500-year floodplain.
On April 16, 2018, in response to the pre-assessment notification, the State of Hawai‘i Department of Land and Natural Resources Engineering Division stated the responsibility for conducting research as to the flood hazard designation for the project site lies with the project
10349-01Letter to Mr. Edward Andrade, Jr. Page 2March 6, 2020
proponent. Also on April 16, 2018 and in response to the pre-assessment notification, the County of Hawai‘i Department of Public Works confirmed that the proposed treatment and disposal project site at Site 7 is designated as Zone X on the FIRM and is outside the 500-year floodplain.”
The relevant FIRM panel is reproduced in Appendix B as Figure 4-13.
This information will be repeated in the Final EA.
The Draft EA Section 3.23.2 (a) states:
“The proposed wastewater treatment and disposal facility would include an on-site drainage system to address stormwater surface runoff created by new impervious surfaces within the facility. The site would include a system to collect runoff via grated inlets or swales, and flows would be conveyed to on-site drainage detention systems, such as subsurface linear infiltration or depressed detention basins.”
This information will be repeated in the Final EA.
The preferred alternative (Site 7) slopes from approximately north to south (mauka to makai) such that, during rain events, surface flows pass through the existing orchard to the southern (makai) end where the flows eventually drain through the culvert located at the Maile Street-Mamalahoa Highway intersection to the areas below (makai) the highway. Most of the land surface area below the existing macadamia nut orchard contains little to no vegetation to absorb or slow these flows. The gradient of Site 7 and surrounding area results in this natural pattern of surface flows which also existed when the area was planted in sugar cane and is not considered flooding.
Based on the roadway flooding concerns expressed by the community during the Pahala public meetings held in December 2017 and October 2018, the State of Hawai‘i Department of Transportation (DOT) Hawai‘i District office was contacted to discuss drainage at the treatment and disposal facility project site and the culvert at the Maile Street and Mamalahoa Highway intersection. On February 20, 2019, the District office confirmed via telephone that the DOT owns and maintains the culvert at the Maile Street intersection, and that they have no record of the roadway being inundated by stormwater drainage during precipitation events at that location.
Stormwater runoff generated mauka of the treatment and disposal facility project site will be directed around the perimeter of the site via diversion swales that will convey flow back to the existing drainage pattern that flows to the existing culvert at Maile Street. During heavy rain events, stormwater may temporarily back up behind the culvert. There will be no changes to this culvert and the proposed treatment and disposal facility will not be located within the area of the culvert.
10349-01Letter to Mr. Edward Andrade, Jr. Page 3March 6, 2020
As stated in the Draft EA, the on-site stormwater management system will meet the requirements of Hawai‘i County Code (HCC), Chapter 27 Floodplain Management, Section 20, Standards for subdivisions and other developments (e) which mandates a site drainage plan to “comply with sections 27-20(a) and (b) and section 27-24, and shall include a storm water disposal system to contain run-off caused by the proposed development, within the site boundaries, up to the expected [design] storm event, as shown in the Department of Public Works Storm Drainage Standards.
To meet the requirements of HCC, Chapter 27, Section 20 (f), the project “shall not alter the general drainage pattern above or below the development”. Thus, for the HCC design storm event, no increase in flow amount will be directed to either of the culverts at the highway as a result of the site development. A drainage report will be prepared during the design process to evaluate the improvements necessary to comply with HCC Chapter 27 requirements.
The wastewater treatment processes will be designed to accommodate the associated peak flows, including precipitation that falls on the area occupied by the aerated lagoon treatment system. The Draft EA Appendix B, Section 2.2 outlines the anticipated peak wastewater flows from the community, based on the applicable flow standard. The Draft EA Section 2.3.1 states the aerated lagoons will be lined with liners to prevent water seepage through the bottom and sides of the lagoons. The Draft EA Appendix B, Section 5.3 shows the operational freeboard that will be available to contain and to equalize lagoon flows. In addition, the slow-rate land application groves will be designed to completely contain both peak effluent flows and precipitation from a 100-year, 24-hour storm event. A geotechnical engineering assessment of berm stability will be conducted during the design process. The tree groves will be designed in accordance with the EPA’s “Process Design Manual, Land Treatment of Municipal Wastewater Effluents”. Effluent will be applied at a hydraulic loading rate that is a small percentage of the percolation rate of the soil, ensuring sufficient capacity for assimilation of peak effluent flow rates and precipitation from the design storm event.
This information will be included in the Final EA.
B.The Draft EA Section 3.15 references a November 2016 archaeological field inspection report that states, while the 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 parcel (which includes Site 7), as well as evidence from plantation-era documents that the opening of a lava tube containing human remains once existed in the southeastern corner of the parcel, indicate that further archaeological studies may be necessary. The Final EA will clarify that the report also stated it would be advisable to limit the development footprint to exclude the southeastern corner of the 42.5-acre parcel. This area, which is presently not used as a macadamia nut orchard, but forms part of the macadamia nut processing plant complex, is the location of a known (but sealed) lava tube opening that local informants have indicated is linked
10349-01Letter to Mr. Edward Andrade, Jr. Page 4March 6, 2020
to tubes that possess traditional human burials. Further, by excluding this section of the parcel, it will be possible to avoid at least one known historic property. The Draft EA Figure 2.3 provides the Preliminary Site Plan for the new treatment and disposal facility, shows the 14.9-acre project site has been developed to exclude the area in the southeastern corner as the location of the sealed lava tube opening.
Between September 18, 2018 and January 10, 2019, a team of qualified archaeologists conducted a pedestrian survey of the proposed project site and completed subsurface trenching to determine the presence of archaeological resources. The work was undertaken in accordance with the State of Hawaii Department of Land and Natural Resources State Historic Preservation Division (SHPD) requirements, with the archaeological inventory survey (AIS) approach accepted by SHPD in their August 20, 2018 letter. The results of the survey and subsurface trenching showed no burials or lava tube openings were identified on site. The AIS submitted to SHPD in March 2019 documents that a sealed lava tube opening is located east of the proposed wastewater treatment and disposal facility project site, outside the proposed property boundary and outside of the area of potential effect considered in consultation with SHPD as required by the National Historic Preservation Act.
The complete document is available for download from the County’s website at: http://records.co.hawaii.hi.us/weblink/1/edoc/100962/Draft%20Archeological%20Inventory%20Survey%20-%20Pahala%20WWTP%20and%20Sewer%20System.pdf
A geophysical survey of the proposed area will be performed during detailed design with the specific intent to locate subsurface voids (such as lava tubes) present beneath the site that may impact design and construction of the new wastewater treatment, disposal and collection systems.
This information will be included in the Final EA.
C. The Draft EA Section 3.14.2 states:
“Wastewater treatment plants can be a source of nuisance odors to the surrounding community if not properly designed or operated. Typically, nuisance odors are most commonly associated with anaerobic (without oxygen) conditions and with processing of residual solids. Incoming raw sewage flows to the proposed wastewater treatment and disposal facility would first be routed to the headworks, which is the facility where the solids are removed from the flows.
To mitigate potential nuisance odors, the headworks would be equipped with an odor control system with a granulated activated carbon (GAC) scrubber to remove odors. Apackage GAC scrubber passes the odorous air through a bed of activated carbon, which
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adsorbs the odorous constituents within the pore spaces of the carbon. The County currently operates GAC scrubbers at other facilities, and it has been proven to be an effective means of odor control both locally and nationwide. The treatment lagoons would be equipped with mechanical aerators capable of maintaining sufficiently aerobic (with oxygen) conditions within the water column, which would prevent nuisance odor conditions from occurring. The disposal groves would be irrigated with fully-treated and aerobic secondary effluent from the treatment process; irrigation with secondary effluent is not associated with development of nuisance odor conditions.”
This information will be included in the Final EA Section 3.14.2.
D.The Draft EA Section 2.7 describes the site selection process, including the factors and their relative weights used to evaluate the various sites. Further, Section 2.7 describes the twenty-one criteria within four general categories (environmental, social and cultural; location and site; land use and availability; and collection system and service area) that were established and defined for the analysis. The Draft EA Appendix B, Section 8, provides additional information regarding the site selection process. As a result of this process, the County identified three sites (Sites 7, 8, and 9) as reasonable alternatives for construction of the wastewater treatment and disposal facility under the Proposed Action. The final scores for Sites 7, 8, and 9 were 4.33, 4.06, and 4.10 respectively, out of a total possible score of 5. Based on this analysis, Site 7 was selected as the Preferred Alternative. The site is easily accessible, has good soils for a land application system, and is close to the existing LCCs.
The Draft EA Section 2.5 describes Site 9, which is south (makai) of the Preferred Alternative Site 7. As outlined in Appendix B Section 8, Site 9 earned a lower ranking than Site 7 for the following criteria: presence of and/or proximity to archaeological/cultural sites, existing vehicle access, power and potable water availability, and distance from the area of the wastewater collection system. Site 7 had a lower ranking than Site 9 in one category: topography. With the distance between the two sites less than 300 feet, they were ranked equally for the criteria of proximity of treatment units to existing occupied buildings.
The Draft EA Sections 2.5 and 2.7 provide information as to the issues related to the use of Site 9.An unnamed stream near the upper portion of the parcel could affect the selected configuration of the wastewater treatment facility and the land application groves. Potentially, to maximize energy efficiency by taking advantage of gravity flow, the headworks, lagoons and the subsurface constructed wetlands could be sited in the upper portion of the site, or the area closest to the highway. In addition, since the site is located across Māmalahoa Highway from the Pāhala community, it would require construction of piping and other utilities within the highway ROW and approval by the State of Hawaiʻi Department of Transportation. Site 9 would require additional access roads to facilitate both construction and operation of the treatment and disposal
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facility and a slightly longer transmission line given its increased distance from the existing LCCs.
This information will be included in the Final EA.
On September 26, 2018, a public notice was published in both the Hawaii Tribune Herald and
West Hawaii Today which stated a public meeting was to be held on October 10, 2018 for the Pāhala Community Large Capacity Cesspool Replacement Project Draft EA. A public notice was also published in the October 1, 2018 print and online editions of the .Dµnj&DOHQGDU and made available on the Ka‘ū News Briefs web site http://kaunewsbriefs.blogspot.com. Fliers were also posted in public venues such as the community shopping center, realtor office, grocery store, library, and the Pāhala Community Center.
On September 10, 2018, letters containing information on the availability of the Draft EA, the comment period, and the October 10, 2018 meeting were mailed to all property owners on record adjacent to the proposed collection system. This direct mailout included an invitation from DEM to workshops conducted prior to the October 10 public meeting. The workshop for owners served by C. Brewer lines was held on October 8, and the mailout for this meeting also included anyone with a current sewer account. The workshop for owners of newly accessible properties was convened on October 9. In addition to the direct mailout, online announcements for the October 8 and 9 workshops were available on the Ka‘ū News Briefs website.
This information will be included in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (41)March 6, 2020
Ms. Sophia Hanoa sohia.hanoa@aol.com
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Ka‘ū, HawaiʻiResponse to Comment - October 23, 2018 4:47 p.m.
Dear Ms. Hanoa:
Thank you for your October 23, 2018 4:47 p.m. comment message regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Community Large Capacity Cesspool Replacement project. Our responses follow:
1. a. b. c. d. The Draft EA Section 7 documents the 5 public meetings held in Pāhala December 12, 13 and 14, 2017 to discuss the Pāhala Large Capacity Cesspool Replacement project. As documented in the Draft EA, the community outreach program for the current project was designed as “talk story” sessions to optimize community conversations in informal sessions. Further, as documented in the Draft EA, invitations and announcements for the talk story sessions were intended to reach all audiences, as follows:
• Property owners with C. Brewer lines on their property were mailed letters from DEM inviting them to these sessions. The letters included stamped, mail-in postcards to facilitate the RSVP process. • Fliers were hand-delivered to “newly-accessible” properties.• Organizational leaders were provided copies of fliers announcing meetings and asked to circulate among their members. •Fliers were posted in public venues, such as the post office, the Pāhala Community Center and the Ka‘ū Hospital. •Several online announcements were included in Ka‘ū News Briefs available at http://kaunewsbriefs.blogspot.com.
This information will be repeated in the Final EA.
On September 10, 2018, letters containing information on the availability of the Draft EA, the comment period, and the October 10, 2018 meeting were mailed to all property owners on record adjacent to the proposed collection system. On October 26, 2018 letters were mailed to property owners on record adjacent to the proposed collection system informing them of the extension of the public comment period to December 10, 2018.
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On September 26, 2018, a public notice was published in both the Hawaii Tribune Herald and
West Hawaii Today which stated a public meeting was to be held on October 10, 2018 for the Pāhala Community Large Capacity Cesspool Replacement Project Draft EA. A public notice was also published in the October 1, 2018 online and print editions of the .Dµnj&DOHQGDU and made available on the Ka‘ū News Briefs web site http://kaunewsbriefs.blogspot.com.
This information will be included in the Final EA.
The Draft EA Section 7 will be revised to add that, on March 21, 2019, the County held anothermeeting in Pāhala which included a presentation to provide information on financing optionsavailable to owners of parcels which would become accessible to the County collection system.The purpose of the meeting was to fulfill a County commitment made in October, 2018 to research financing options available to the newly accessible residents of the Pahala Community by March, 2019.
1. e. On, November 7, 2018, the County of Hawaiʻi hand delivered eleven copies of the Draft EA to the Pāhala Public Library and eleven copies to the Nā‘ālehuPublic Library. The County’s transmittal requested the library make the copies available for checkout. This information will be included in the Final EA Section 7.
All materials circulated, posted and published for the October 2018 meetings included the electronic link to the Draft EA at http://health.hawaii.gov/oeqc/. The Draft EA was also posted on the County of Hawaii and EPA websites at:
x http://records.co.hawaii.hi.us/weblink/1/edoc/96064/Pahala%20FINAL%20DRAFT%20EA%20and%20Appendices_508_9-11-18.pdfxhttps://www.epa.gov/uic/proposed-pahala-community-large-capacity-cesspool-lcc-replacement-project-draft-environmental
This information will be included in the Final EA.
2. a. The Draft EA Section 3.15 references a November 2016 archaeological field inspection report that states, while the 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 parcel (which includes Site 7), as well as evidence from plantation-era documents that the opening of a lava tube containing human remains once existed in the southeastern corner of the parcel, indicate that further archaeological studies may be necessary. The Final EA will clarify that the report also stated it would be advisable to limit the development footprint to exclude the southeastern corner of the 42.5-acre parcel. This area, which is presently not used as a macadamia nut orchard, but forms part of the macadamia nut processing plant complex, is the location of a known (but sealed) lava tube opening that local informants have indicated is linked to tubes that possess traditional human burials. Further, by excluding this section of the parcel, it
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will be possible to avoid at least one known historic property. The Draft EA Figure 2.3, whichprovides the Preliminary Site Plan for the new treatment and disposal facility, shows the 14.9-acre project site has been developed to exclude the area in the southeastern corner identified as the location of the sealed lava tube opening.
Between September 18, 2018 and January 10, 2019 a team of qualified archaeologists conducted a pedestrian survey of the proposed project site and completed subsurface trenching to determine the presence of archaeological resources. The work was undertaken in accordance with the State of Hawaii Department of Land and Natural Resources State Historic Preservation Division (SHPD) requirements, with the archaeological inventory survey (AIS) approach accepted by SHPD in their August 20, 2018 letter. The results of the survey and subsurface trenching showed no burials or lava tube openings were identified on-site. The AIS submitted to SHPD in March 2019 documents that a sealed lava tube opening is located east of the proposed wastewater treatment and disposal facility project site, outside the proposed property boundary, and outside of the area of potential effect considered in consultation with SHPD as required by the National Historic Preservation Act.
The complete document is available for download from the County’s website at: http://records.co.hawaii.hi.us/weblink/1/edoc/100962/Draft%20Archeological%20Inventory%20Survey%20-%20Pahala%20WWTP%20and%20Sewer%20System.pdf
A geophysical survey of the proposed project area will be performed during detailed design with the specific intent to locate subsurface voids (such as lava tubes) present beneath the site that may impact design and construction of the new wastewater treatment, disposal and collection systems.
This information will be included in the final EA.
On April 25, 2010, a community meeting sponsored by Councilman Guy Enriques was held at the Pāhala Community Center to discuss the Nā‘ālehu and Pāhala Large Capacity Cesspool Replacement project. As part of the meeting, an informational handout prepared by the County’s Wastewater Division provided a brief history of the project documenting that, in 2004, Mayor Kim’s office used a ballot system to get input from property owners regarding different wastewater treatment/disposal alternatives for those property owners connected to the LCCs who would no longer be served by the C. Brewer system after LCC closure. As reported in the Draft EA Section 2.1.4, 87 percent of the returned ballots were in favor of the installation of a new sewer collection system and a treatment and disposal system to be operated and maintained by the County. The handout indicated that Mayor Kim’s office advised the property owners the County would move forward with new systems for Nā‘ālehu and Pāhala on November 5, 2004. Additionally, the handout stated public meetings were held in both Nā‘ālehu and Pāhala in November 2006, to discuss the wastewater system alternatives. The handout included that adequate land for the treatment and disposal system had not been identified in Pāhala.The
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handout also stated that all properties accessible to the new sewer system would be required to connect in accordance with Hawaii County Code Chapter 21.
2. b. As shown in Figure 2.3 the 14.9-acre treatment and disposal facility project site does not extend into Maile Street. Similarly, Figure 2.3 shows the 14.9-acre treatment and disposal facility does not extend into Māmalahoa Highway. The site fencing will not extend into the Maile Street or Māmalahoa Highway rights-of-way. The Draft EA Figure 2.3 shows the intersection of Maile Street and Māmalahoa Highway lies at about 580 feet above mean sea level (MSL). Figure 2.3 will be repeated in Final EA.
The Draft EA Figure 2.3 shows the intersection of Maile Street and Māmalahoa Highway lies at about 580 feet above mean sea level (MSL). The Draft EA Figure 2.2 shows the Pāʻauʻau Gulch crosses underMāmalahoa Highway near the hospital about 0.88 miles north of that intersection and lies at approximately 780 feet MSL or about 200 feet higher in elevation than the culvert at the Maile Street and Māmalahoa Highway intersection.Due to this distance and the elevation difference, surface flows at Site 7 would not affect the gulch. Similarly, the Kaimani Street and Māmalahoa Highway intersection lies about 0.84 miles north of the proposed facility site and at about 780 feet MSL. Surface flows at the facility would also not affect that intersection. Figures 2.2 and 2.3 will be repeated in the Final EA.
3. The Draft EA Section 2.7 describes the site selection process, including the factors and their relative weights used to evaluate the various sites. Further, Section 2.7 describes the twenty-one criteria within four general categories (environmental, social and cultural; location and site; land use and availability; and collection system and service area) that were established and defined for the analysis. The Draft EA Appendix B, Section 8, provides additional information regarding the site selection process. As a result of this process, the County identified three sites (Sites 7, 8, and 9) as reasonable alternatives for construction of the wastewater treatment and disposal facility under the Proposed Action. The final scores for Sites 7, 8, and 9 were 4.33, 4.06, and 4.10 respectively, out of a total possible score of 5. Based on this analysis, Site 7 was selected as the Preferred Alternative. The site is easily accessible, has good soils for a land application system, and is close to the existing LCCs.
The Draft EA Section 2.5 describes Site 9, which is south (makai) of the Preferred Alternative Site 7. As outlined in Appendix B Section 8, Site 9 earned a lower ranking than Site 7 for the following criteria: presence of and/or proximity to archaeological/cultural sites, existing vehicle access, power and potable water availability, and distance from the area of the wastewater collection system. Site 7 had a lower ranking than Site 9 in one category: topography. With the distance between the two sites less than 300 feet, they were ranked equally for the criteria of proximity of treatment units to existing occupied buildings.
The Draft EA Sections 2.5 and 2.7 provide information as to the issues related to the use of Site 9.An unnamed stream near the upper portion of the parcel could affect the selected configuration of
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the wastewater treatment facility and the land application groves. Potentially, to maximize energy efficiency by taking advantage of gravity flow, the headworks, lagoons and the subsurface constructed wetlands could be sited in the upper portion of the site, or the area closest to the highway. In addition, since the site is located across Māmalahoa Highway from the Pāhala community, it would require construction of piping and other utilities within the highway ROW and approval by the State of Hawaiʻi Department of Transportation. Site 9 would require additional access roads to facilitate both construction and operation of the treatment and disposal facility and a slightly longer transmission line given its increased distance from the existing LCCs.
This information will be included in the Final EA.
3. a. Mr. Andrade has provided comments to the Draft EA.
The County is aware of two existing culverts that allow stormwater to flow across the Māmalahoa Highway in the vicinity of the project. The first is a box culvert located at the intersection with Maile Street that conveys stormwater across the highway. The second culvert is located approximately 600 feet east of the Maile Street intersection and was used to convey sugar mill flume water across the highway for disposal.
The Draft EA Section 3.9.1 (a) states:
“The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM), Community Panel No. 155166 1800F, effective date September 29, 2017 shows 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-1is very close to the edge of the 500-year floodplain.
On April 16, 2018, in response to the pre-assessment notification, the State of Hawai‘i Department of Land and Natural Resources Engineering Division stated the responsibility for conducting research as to the flood hazard designation for the project site lies with the project proponent. Also on April 16, 2018 and in response to the pre-assessment notification, the County of Hawai‘i Department of Public Works confirmed that the proposed treatment and disposal project site at Site 7 is designated as Zone X on the FIRM and is outside the 500-year floodplain.”
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The relevant FIRM panel is reproduced in Appendix B as Figure 4-13.
This information will be repeated in the Final EA.
The Draft EA Section 3.23.2 (a) states:
“The proposed wastewater treatment and disposal facility would include an on-site drainage system to address stormwater surface runoff created by new impervious surfaces within the facility. The site would include a system to collect runoff via grated inlets or swales, and flows would be conveyed to on-site drainage detention systems, such as subsurface linear infiltration or depressed detention basins.”
This information will be repeated in the Final EA.
The preferred alternative (Site 7) slopes from approximately north to south (mauka to makai) such that, during rain events, surface flows pass through the existing orchard to the southern (makai) end where the flows eventually drain through the culvert located at the Maile Street-Māmalahoa Highway intersection to the areas below (makai) the highway. Most of the land surface area below the existing macadamia nut orchard contains little to no vegetation to absorb or slow these flows. The gradient of Site 7 and surrounding area results in this natural pattern of surface flows which also existed when the area was planted in sugar cane and is not considered flooding.
Based on the roadway flooding concerns expressed by the community during the Pahala public meetings held in December 2017 and October 2018, the State of Hawai‘i Department of Transportation (DOT) Hawai‘i District office was contacted to discuss drainage at the treatment and disposal facility project site and the culvert at the Maile Street and Māmalahoa Highway intersection. On February 20, 2019, the District office confirmed via telephone that the DOT owns and maintains the culvert at the Maile Street intersection, and that they have no record of the roadway being inundated by stormwater drainage during precipitation events at that location.
Stormwater runoff generated mauka of the treatment and disposal facility project site will be directed around the perimeter of the site via diversion swales that will convey flow back to the existing drainage pattern that flows to the existing culvert at Maile Street. During heavy rain events, stormwater may temporarily back up behind the culvert. There will be no changes to this culvert and the proposed treatment and disposal facility will not be located within the area of the culvert.
As stated in the Draft EA, the on-site stormwater management system would meet the requirements of Hawai‘i County Code (HCC), Chapter 27 Floodplain Management, Section 20, Standards for subdivisions and other developments (e) which mandates a site drainage plan to “comply with sections 27-20(a) and (b) and section 27-24, and shall include a storm water
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disposal system to contain run-off caused by the proposed development, within the site boundaries, up to the expected [design] storm event as shown in the department of public works “Storm Drainage Standards”.
To meet the requirements of HCC, Chapter 27, Section 20 (f), the project “shall not alter the general drainage pattern above or below the development”. Thus, for the HCC design storm event, no increase in flow amount will be directed to either of the culverts at the highway as a result of the site development. A drainage report will be prepared during the design process to evaluate the improvements necessary to comply with HCC requirements.
The wastewater treatment processes will be designed to accommodate the associated peak flows, including precipitation that falls on the area occupied by the aerated lagoon treatment system. The Draft EA Appendix B, Section 2.2 outlines the anticipated peak wastewater flows from the community, based on the applicable flow standard. The Draft EA Section 2.3.1, states the aerated lagoons will be lined to prevent water seepage through the bottom and sides of the lagoons. The Draft EA Appendix B, Section 5.3 shows the operational freeboard that will be available to contain and to equalize lagoon flows. In addition, the slow-rate land application groves will be designed to completely contain both peak effluent flows and precipitation from a 100-year, 24-hour storm event. A geotechnical engineering assessment of berm stability will be conducted during the design process. The tree groves will be designed in accordance with the EPA’s “Process Design Manual, Land Treatment of Municipal Wastewater Effluents”. Effluent will be applied at a hydraulic loading rate that is a small percentage of the percolation rate of the soil, ensuring sufficient capacity for assimilation of peak effluent flow rates and precipitation from the design storm event.
This information will be included in the Final EA.
3 b. Without specific citations it is not possible to confirm the issue related to negative impacts to residents near wastewater treatment plants.
3 c. The proposed site plan is included in the Draft EA as Figure 2.3. As noted in Section 2.3.1, “disposal of the treated and disinfected effluent would be accomplished through land treatment in four groves of native, water-tolerant trees occupying a total area of approximately 8.0 acres.” This 8.0 acre planted area, combined with the sloping site topography and existing Cook pine trees (Araucaria columnaris)on Maile Street, will provide a visual buffer from both the Māmalahoa Highway and Maile Street. As outlined in Section 3.19.2 of the Draft EA, the Proposed Action is not expected to adversely affect the views or viewsheds identified in the County General Plan. The wastewater collection system would be installed below the streets and therefore would not impact views. Above-ground structures may include the operations building, headworks and UV cover structures, and berms around the basins. The existing pine trees along Maile Street, most of which would remain with no changes, would continue to obstruct the viewplanes from Maile Street. The facility site would be adjacent (mauka) to, and
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visible from, Māmalahoa Highway (State Route 11); however, impacts to the viewplane would be mitigated by the planted trees in the basins and by the rise in elevation between the highway and the facility.
3. d. The Draft EA Section 2.3.1 states Site 7 is owned by Kamehameha Schools and Section 2.5 states Site 9 is owned by Kamehameha Schools. The Final EA will clarify that the current landowner is BP Bishop Estate Trustees (Kamehameha Schools).
4. a. As outlined above and in the Draft EA Section 2.1.3, the County has been discussing the need for a new collection system, treatment and disposal facility to replace the existing collection system and LCCs, which have been prohibited by the U.S. Environmental Protection Agency, with the community since 2004. The County has not fast-tracked this project. Although not a comment specific to the content of the Draft EA, for clarification, fees currently paid by Pāhalaresidents serviced by the existing County-owned collection and LCC disposal system are collected for operation and maintenance of that system. All properties connected to County of Hawaiʻi wastewater collection systems pay fees as outlined in County of Hawaii Code (HCC) Chapter 21 Section 21-36.1. Currently, users connected to gang cesspools (LCCs) pay a reduced charge per unit as compared to rates charged to other user categories.
4. b. and c. The Draft EA Section 2.2 describes the purpose of the Pāhala Large Capacity Cesspool Replacement project is to close the Pāhala large capacity cesspools (LCC). The Draft EA Section 2.3.2 discusses the construction of a new sewer collection system in the Pāhala community to replace the existing system of substandard gravity lines that currently conveys sewage to the two LCCs. As described in Section 6.2.1, the current collection system includes facilities located in the backyards of many parcels. Where easements for the existing collection system aren’t accessible, the County must obtain permission from individual landowners to enter them, through private property, to inspect, maintain, repair or replace existing sewer facilities: all activities essential to an efficient, functioning system.
As a result, the proposed new collection system would consist of a total of approximately 12,150 linear feet (LF) (2.3 miles) of corrosion-resistant polyvinyl chloride (PVC) piping located almost entirely within the right of way (ROW) of eight public streets.
Also as outlined in the Draft EA, Section 2.3.2, the new collection system would be subject to the Hawaiʻi County Code (HCC) Chapter 21, Sewers, specifically, Article 2 (Public Sewers), Section 21-5, which 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.”
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Each adjacent lot will be provided with a lateral connection to the sewer main as required by HCC and standards. Under the Preferred Alternative, the design of the new collection system would extend between street intersections and include sewer service stub-outs (the lateral connection to the sewer main) to the lot lines of adjacent properties, including the newly accessible, to accommodate their eventual connection. Accordingly, to close the existing LCCs, there will be additional properties in Pāhala that would be required to connect to the new wastewater collection system, at their expense, after it becomes operational. Such properties are near the existing service area but are presently connected to individual wastewater systems. To conform to the stated section of HCC, the respective, newly accessible property owners would be responsible for the design, permitting and completion of sewer service connections between the County stub-outs and improvements for stated uses on their property, as well as for the proper closure of their individual wastewater systems. The Draft EA Figure 2.6 shows the area of the community serviced by the current and proposed collection systems.
The Draft EA Figure 2.6 shows the area of the community serviced by the current and proposed collection systems.
The financial impact of the project on individual newly accessible property owners was raised by the community during the December 2017 public meetings as summarized in Section 7 of the Draft EA. Although not required by Hawaii Administrative Rules (HAR) Title 11, Chapter 200, DEM voluntarily convened two additional public meetings on October 9, 2018 and March 26, 2019 to gain further input from newly accessible property owners and present funding options for them to pursue. This information will be added to the final EA.
The County’s intent, as stated in the June 22, 2017 US Environmental Protection Agency Region 9 Administrative Order on Consent is to provide an industry standard wastewater collection system and a secondary treatment and disposal facility, a basic service to the Pāhala community to eliminate underground injection from LCCs it operates to help protect underground drinking water sources. Closure of individual cesspools is mandated by legislation at the State level. In 2017, Act 125 was enacted requiring all cesspools, not exempted by the Department of Health, be upgraded or converted to septic systems, or aerobic treatment unit systems, or connected to sewage systems by January 1, 2050. Though closure of individual wastewater systems by the County is not part of the Proposed Action, this legislation will affect all parcels in Pāhala currently using cesspools for sewage disposal.
4. d. The Draft EA Section 2.9 provides information regarding the 2007 Final EA for the Nā‘ālehu-Pāhala Large Capacity Cesspool Conversion project. There is no statement in the 2007 Final EA that the project was a joint venture.
4. e. The Pāhala wastewater treatment plant (WWTP) 14.9-acre project site has been developed to provide the necessary land area for the facilities needed to treat the incoming flows and to dispose the treated effluent from the treatment processes. The project site minimizes the use of
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the adjacent lands which contain a commercial macadamia orchard. A larger project site is not required. The special permit requirement applies to the proposed WWTP parcel only, not to the proposed utility easement. The County will apply for the required special permit through the Planning Commission. This information will be repeated in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (42)March 6, 2020
Jadelyn Kaapana Mosesmamajapab71@gmail.com
Subject: Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻū, HawaiʻiResponse to Comment October 24, 2018 1:39 a.m.
Dear Ms. Moses:
Thank you for your October 24, 2018 1:39 a.m. comment message regarding the Draft Environmental Assessment (EA) for the County of Hawaiʻi Department of Environmental Management Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
We appreciate you taking the time to attend meetings and encourage you to continue your engagement. The purpose of this letter is to address your emailed comments as they relate to the content requirements of the Draft EA.
Section 2.1.4 of the Draft EA provides a history of wastewater management for Pāhala. As stated, in 2003 C. Brewer requested assistance from the County to close their large capacity cesspools as required by the Environmental Protection Agency. Section 2.14 discussed that, around 2006, C. Brewer requested that the County construct and maintain a new and improved sewer system for the Pāhala community. A County Council Resolution approved the C. Brewer request. In anticipation of C. Brewer's dissolution, the company proposed, and the County agreed in April 2007, to enter into a formal agreement to construct and maintain a new and improved community sewer system or assume maintenance and required service of the existing systems by April 30, 2010. The Final EA will clarify that 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 for specific private properties in Pāhala and Nāʻālehu. It was agreed, if the County did not complete its’ portion of the work by April 30, 2010, it 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, the projectincludes connecting these C. Brewer laterals, which may now need to be replaced.
As outlined in the Draft EA Section 2.1.3, the County has been discussing the need for a new collection system, treatment and disposal facility to replace the existing collection system and LCCs, with the community since 2004.
10349-01Letter to Jadelyn Kaapana MosesPage 2March 6, 2020
On April 25, 2010, a community meeting sponsored by Councilman Guy Enriques was held at the Pāhala Community Center to discuss the Nā‘ālehu and Pāhala Large Capacity Cesspool Replacement project. As part of the meeting, an informational handout prepared by the County Wastewater Division, provided a history of the project documenting that, in 2004, Mayor Kim’s office used a ballot system to get input from property owners regarding different wastewater treatment/disposal alternatives for those property owners connected to the LCCs who would no longer be served by the C. Brewer system after LCC closure. As reported in the Draft EA Section 2.1.4, 87 percent of the returned ballots were in favor of the installation of a new sewer collection system and a treatment and disposal system to be operated and maintained by the County. The handout indicated that Mayor Kim’s office advised the property owners the County would move forward with a new system for Nā‘ālehu and Pāhalaon November 5, 2004.Additionally, the handout stated that public meetings were held in both Nā‘ālehu and Pāhala in November 2006 to discuss the wastewater system alternatives.
This historical information related to public outreach regarding closure of the LCCs will be included in the Final EA.
The Draft EA Section 7 documents the five public meetings held in Pāhala December 12, 13 and 14, 2017 to discuss the Pāhala Large Capacity Cesspool Replacement project. As documented in the Draft EA, the community outreach program for the current project was designed as “talk story” sessions to optimize community conversations in informal sessions. Further, as documented in the Draft EA, invitations and announcements for the talk story sessions were intended to reach all audiences, as follows:
• Property owners with C. Brewer lines on their property were mailed letters from DEM inviting them to these sessions. The letters included stamped, mail-in postcards to facilitate the RSVP process. • Fliers were hand-delivered to “newly-accessible” properties.• Organizational leaders were provided copies of fliers announcing meetings and asked to circulate among their members. • Fliers were posted in public venues, such as the post office, the Pāhala Community Center and the Ka‘ū Hospital. •Several online announcements were included in Ka‘ū News Briefs available at http://kaunewsbriefs.blogspot.com.
This information will be repeated in the Final EA.
On September 10, 2018, letters containing information on the availability of the Draft EA, the comment period, and the October 10, 2018 meeting were mailed to all property owners on record adjacent to the proposed collection system. This direct mailout included an invitation from DEM to workshops conducted prior to the October 10 public meeting. The workshop for owners served by C. Brewer lines was held on October 8, and the mailout for this meeting also included
10349-01Letter to Jadelyn Kaapana MosesPage 3March 6, 2020
anyone with a current sewer account. The workshop for owners of newly accessible properties was convened on October 9. In addition to the direct mailout, online announcements for the October 8 and 9 workshops were available on the Ka‘ū News Briefs website.
On September 26, 2018, a public notice was published in both the Hawaii Tribune Herald and
West Hawaii Today which stated a public meeting was to be held on October 10, 2018 for the Pāhala Large Capacity Cesspool Replacement Project Draft EA. A public notice was also published in the October 1, 2018 print and online editions of the .Dµnj&DOHQGDU and made available on the Ka‘ū News Briefs web site http://kaunewsbriefs.blogspot.com. Fliers were also posted in public venues such as the community shopping center, realtor office, grocery store, library, and the Pāhala Community Center.
This information will be included in the Final EA.
All accessible properties will be required to connect to the new wastewater collection system in accordance with Hawaiʻi County Code, Chapter 21, Article 2, Section 21-5. However, as you have noted, the County entered into an agreement with C. Brewer (in April 2007) to eliminate LCCs from the existing community sewer system and connect properties discharging to them to new County collection, treatment and disposal systems. Once the actual costs are determined, County Council action is still required to approve the expenditures.
The financial impact of the project on individual newly accessible property owners was raised by the community during the December 2017 public meetings as summarized in Section 7 of the Draft EA and again during the October 2018 meetings. Although not required by HawaiʻiAdministrative Rules (HAR) Title 11, Chapter 200, DEM 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 for the newly accessible residents of the Pāhala Community to pursue.
Programs discussed included:
x US Department of Housing and Urban Development (HUD) with County of HawaiʻiOffice of Housing and Community Development Residential Repair Program-Community Block Grant Program, and x US Department of Agriculture – Rural Development (USDA-RDA) Program.
As noted during the presentation, these programs may change in the coming years and additional options may be added to this preliminary list.HawaiʻiLegislature, Senate Bill 221 SD1, which could amend Hawaiʻi Revised Statutes (HRS) Chapter §342D to establish a low interest loan program offering financial assistance to cesspool owners to connect to wastewater treatment systems approved by the Department of Health was also discussed; however, this bill was subsequently not passed during the 2019 legislative session.
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This information will be included in the Final EA.
The County has investigated reports of cultural and historical sites in the context of this project in consultation with the State Historic Preservation Division (SHPD), as follows:
The Draft EA Section 3.15 references a November 2016 archaeological field inspection report that states, while the 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 parcel (which includes Site 7), as well as evidence from plantation-era documents, that the opening of a lava tube containing human remains once existed in the southeastern corner of the parcel, indicate that further archaeological studies may be necessary. The Final EA will clarify that the report also stated it would be advisable to limit the development footprint to exclude the southeastern corner of the 42.5-acre parcel. This area, which is presently not used as a macadamia nut orchard, but forms part of the macadamia nut processing plant complex, is the location of a known (but sealed) lava tube opening that local informants have indicated is linked to tubes that possess traditional human burials. Further, by excluding this section of the parcel, it will be possible to avoid at least one known historic property. The Draft EA Figure 2.3, whichprovides the Preliminary Site Plan for the New Treatment and Disposal Facility shows the 14.9-acre project site has been developed to exclude the area identified as the location of the sealed lava tube opening.
Between September 18, 2018 and January 10, 2019 a team of qualified archaeologists conducted a pedestrian survey of the proposed project site and subsurface trenching to determine the presence of archaeological resources. The work was undertaken in accordance with the State of HawaiʻiDepartment of Land and Natural Resources SHPD requirements, with the archaeological inventory survey (AIS) approach accepted by SHPD in their August 20, 2018 letter. The archaeological inventory survey submitted to SHPD in March 2019 documents that a sealed lava tube opening is located east of the proposed wastewater treatment and disposal facility project site, outside the proposed property boundary, and outside of the area of potential effect considered in consultation with the SHPD.
The complete document is available for download from the County’s website at: http://records.co.hawaii.hi.us/weblink/1/edoc/100962/Draft%20Archeological%20Inventory%20Survey%20-%20Pahala%20WWTP%20and%20Sewer%20System.pdf
A geophysical survey and geotechnical investigation of the proposed project area will be performed during detailed design with the specific intent to locate subsurface voids (such as lava tubes) present beneath the site, conduct infiltrometer testing, and determine subsurface soil characteristics that may impact design and construction of the new wastewater treatment, disposal and collection systems.
This information will be included in the Final EA.
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The project will be designed to accommodate the future needs of the Pāhala community in accordance with the Kaʻū Community Development Plan Policy 120 as discussed in the Draft EA Sections 2.9, 6.2.2, 7 and Appendix B. Additional information will be included in the appendices of the Final EA to clarify how accommodations will be made not to preclude future expansion of the new collection system. Future development will be accommodated as capacity allows on a first-come, first-served basis.
As stated in the Draft EA Section 2.10, the County of Hawaiʻi Department of Environmental Management will submit a Special Use Permit application, Subdivision Application, and obtain plan approval as required by applicable Hawaiʻi County Code and Hawaiʻi Revised Statutes. This information will be repeated in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (38)March 6, 2020
Ms. Lila LopesNaalehu, 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻū, HawaiʻiResponse to Comment – October 22, 2018
Dear Ms. Lopes:
Thank you for your October 22, 2018 comment letter regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
The Nāʻālehu LCC project is not the subject of the Draft EA for the Pāhala Large Capacity Cesspool (LCC) Replacement project.
Hawaii Administrative Rules (HAR) 11-200-7 Multiple or phased applicant or agency actionsstates that “A group of actions proposed by an agency or an applicant shall be treated as a single action when (1) The component actions are phases or increments of a larger total undertaking, (2) An individual project is a necessary precedent for a larger project; (3) An individual project represents a commitment to a larger project; or (4) The actions in question are essentially identical and a single statement will adequately address the impacts of each individual action and those of the group of actions as a whole.” The wastewater projects at Pāhala and Nāʻālehu are not phases or increments of a larger total undertaking, are not precedents or commitments for a larger project, nor are they identical. Hence, there is no requirement to consider them in a single environmental review document.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
10349-01Letter to Ms. Lila LopesPage 2
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (34)March 6, 2020
Mr. Charles TuttleMs. Tina Tuttle95-1513 Kaalualu RoadNaalehu 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻū, HawaiʻiResponse to Comment – October 22, 2018
Dear Mr. and Ms. Tuttle:
Thank you for your October 22, 2018 comment letter regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool (LCC) Replacement project. Our responses follow:
The Nāʻālehu LCC project is not the subject of the Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project.
The Draft EA Section 5 discusses the federal cross cutter requirements for the Pāhala Large Capacity Cesspool Replacement project.
The Draft EA Sections 2.3 through 2.8 discuss project siting issues.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (43)March 6, 2020
Ms. Amanda McDowell Mr. Anthony McDowell 95-5587A Māmalahoa HighwayNaalehu, Hawaii 96772
Subject: Draft Environmental Assessment for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of,Kaʻū, HawaiʻiResponse to Comment – October 22, 2018
Dear Ms. and Mr. McDowell:
Thank you for your October 22, 2018 comment letter regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool (LCC) Replacement project. Our responses follow:
The Draft EA Section 4.1.2 states: “The community of Naʻālehu, approximately 11 miles southwest of Pāhala, is also considering options for closure of LCCs and development of a new wastewater treatment system. The Naʻālehu project was excluded from this analysis of cumulative improvements and impacts because, due to its distance from Pāhala, the effects of that project are not expected to have a significant cause-and-effect relationship with the direct and indirect effects of the Proposed Action. The Naʻālehu project is undergoing separate community outreach and environmental review processes that will identify potential impacts for that project separately from the Pāhala wastewater system improvements.”
This information will be included in the Final EA.
The Nāʻālehu LCC project is not the subject of the Draft EA for the Pāhala Large Capacity Cesspool Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
10349-01Letter to Ms. Amanda McDowell/Mr. Anthony McDowell Page 2March 6, 2020
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (40)March 6, 2020
Pele Defense FundResidents of Pāhala P.O. Box 4969Hilo, Hawaii 96720
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻū, HawaiʻiResponse to Comment – October 23, 2018
Dear Sir/Madam:
Thank you for your October 23, 2018 comment letter regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project.
Please note that in response to requests from your organization and others in the community, the public comment period was extended through December 10, 2018. See #2 below for additional detail.
Our responses follow:
1. As outlined in the Draft EA Section 2.1.3, the County has been discussing the need for a new collection system, treatment and disposal facility to replace the existing collection system and LCCs, which have been prohibited by the U.S. Environmental Protection Agency, with the community since 2004. The Draft EA Section 7 documents the 5 public meetings held in Pāhala December 12, 13 and 14, 2017 to discuss the Pāhala Large Capacity Cesspool Replacement project. As documented in the Draft EA, the community outreach program for the current project was designed as “talk story” sessions to optimize community conversations in informal sessions. Further, as documented in the Draft EA, invitations andannouncements for the talk story sessions were intended to reach all audiences, as follows:
• Property owners with C. Brewer lines on their property were mailed letters from DEM inviting them to these sessions. The letters included stamped, mail-in postcards to facilitate the RSVP process. • Fliers were hand-delivered to “newly-accessible” properties.• Organizational leaders were provided copies of fliers announcing meetings and asked to circulate among their members.
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• Fliers were posted in public venues, such as the post office, the Pāhala Community Center and the Ka‘ū Hospital. •Several online announcements were included in Ka‘ū News Briefs available at http://kaunewsbriefs.blogspot.com.
This information will be repeated in the Final EA.
On September 10, 2018, letters containing information on the availability of the Draft EA, the comment period, and the October 10, 2018 meeting were mailed to all property owners on record adjacent to the proposed collection system. This direct mailout included an invitation from DEM to workshops conducted prior to the October 10 public meeting. The workshop for owners served by C. Brewer lines was held on October 8, and the mailout for this meeting also included anyone with a current sewer account. The workshop for owners of newly accessible properties was convened on October 9. In addition to the direct mailout, online announcements for the October 8 and 9 workshops were available on the Ka‘ū News Briefs website.
On September 26, 2018, a public notice was published in both the Hawaii Tribune Herald and West Hawaii Todaywhich stated a public meeting was to be held on October 10, 2018 for the Pāhala Large Capacity Cesspool Replacement Project Draft EA. A public notice was also published in the October 1, 2018 print and online editions of the .Dµnj&DOHQGDU and made available on the Ka‘ū News Briefs web site http://kaunewsbriefs.blogspot.com. Fliers were also posted in public venues such as the community shopping center, realtor office, grocery store, library, and the Pāhala Community Center.
This information will be included in the Final EA.
The Draft EA Section 7 will be revised to add that, on March 21, 2019, the County held another meeting in Pāhala which included a presentation to provide information on financing sources available to owners whose property would become accessible to the County collection system. The purpose of the meeting was to fulfill a County commitment made in October, 2018 to research financing options available to the newly accessible residents of the Pahala Community by March, 2019.
2. On October 26, 2018, the County requested the Office of Environmental Quality Control issued a Re-Publication notice of the Draft EA in the November 8, 2018 issue of The Environmental Notice. This was to allow additional time for public comments. Public comments were accepted from September 23, 2018 to December 10, 2018.
3. and 4. The Draft EA Section 3.15 provides information on the archaeological and cultural resources related to the Pāhala Community Large Capacity Cesspool Replacement project. The Draft EA Section 3.15 states, on March 29, 2018, consultation was initiated for the
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project under the National Historic Preservation Act. The Draft EA Section 10 provides a list of the consulted parties. The Final EA Section 3.15 will include that the list of Native Hawaiian Organizations (NHO) was generated by the EPA for NHPA Section 106 and HRS Chapter 6E compliance from the U.S. Department of the Interior, Office of Native Hawaiian Relations, Native Hawaiian Organization (NHO) Notification List. Letters were sent to 14 NHOS during the pre-assessment consultation. No responses were received from these organizations.
The HRS Chapter 6E determination and Section 106 review packet were submitted to SHPD with a draft archaeological inventory survey (AIS) on March 13, 2019. SHPD response is pending. The Draft EA Section 3.15.2 states that prior to finalization of this EA and initiation of the Proposed Action, the Environmental Protection Agency (EPA) and the County of Hawai‘i will conclude consultation with SHPD in accordance with Section 106 of the NHPA and will incorporate additional impact avoidance and minimization measures as necessary to result in a finding of no adverse effects to historic properties.
The Draft EA Section 7 will be revised to include that on September 26, 2018, a public notice was published in the Hawaii Tribune Herald and West Hawaii Today newspapers to advertise the October 10, 2018, public information meeting conducted by the County in Pāhala at the Ka‘ū Gym Multi-Purpose Conference Room to discuss the availability of Draft EA and the process for submitting comments. The notice stated that the second part of the meeting would address Section 106 of the National Historic Preservation Act of 1966, as amended (2006) involving consultation with Native Hawaiian Organizations and the Native Hawaiian descendants with ancestral lineal or cultural ties to, cultural knowledge or concerns for, and cultural religious attachment to the proposed project area. Eight persons placed their names on a sign in sheet at the beginning of the October 10, 2018 meeting to contribute during the second part of the meeting dedicated to the Section 106 consultation. There were no comments or information forthcoming during the Section 106 portion of the meeting.
The Draft EA Section 3.15 references a November 2016 archaeological field inspection report that states, while the 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 parcel (which included Site 7), as well as evidence from plantation-era documents that the opening of a lava tube containing human remains once existed in the southeastern corner of the parcel, indicate that further archaeological studies may be necessary. The Final EA will clarify that the report also stated it would be advisable to limit the development footprint to exclude the southeastern corner of the 42.5-acre parcel. This area, which is presently not used as a macadamia nut orchard, but forms part of the macadamia nut processing plant complex, is the location of a known (but sealed) lava tube opening that local informants have indicated is linked to tubes that possess traditional human burials. Further, by excluding this section of the parcel, it will be possible to avoid at least one known historic property. The Draft EA Figure 2.3, which provides the Preliminary Site
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Plan for the new treatment and disposal facility, shows the 14.9-acre project site has been developed to exclude the area in the southeastern corner identified as the location of the sealed lava tube opening.
Between September 18, 2018 and January 10, 2019 a team of qualified archaeologists conducted a pedestrian survey of the proposed project site and completed subsurface trenching to determine the presence of archaeological resources. The work was undertaken in accordance with the State of Hawaii Department of Land and Natural Resources StateHistoric Preservation Division (SHPD) requirements, with the archaeological inventory survey (AIS) approach accepted by SHPD in their August 20, 2018 letter. The results of the survey and subsurface trenching showed no burials or lava tube openings were identified on-site. The AIS submitted to SHPD in March 2019 documents that a sealed lava tube opening is located east of the proposed wastewater treatment and disposal facility project site, outside the proposed property boundary, and outside of the area of potential effect considered in consultation with the SHPD.
The complete document is available for download from the County’s website at: http://records.co.hawaii.hi.us/weblink/1/edoc/100962/Draft%20Archeological%20Inventory%20Survey%20-%20Pahala%20WWTP%20and%20Sewer%20System.pdf
The Final EA will include the pedestrian survey included residential streets within the project area, including Pikake Street, Kamani Street, Puahala Street, Huapala Street, Hala Street, Hinano Street, Ilima Street and Maile Street. The survey found these typically streets consist of one-to-two-lane asphalt travel ways with no curbing or sidewalks, except for a short segment portion of Maile Street which has a sidewalk.
Two historic properties were newly documented within the project area based on a review of historic maps. These include Pikake Street which is a portion of a historic road alignment (SIHP # -31088, Wood Valley Road/Coastal Road) and Maile Street which is a portion of a historic road alignment (SIHP # -31089, Volcano Road). These two streets overlap historic-era road corridors which functioned as primary transportation routes throughout the greater Pāhala/eastern Kaʻū area. None of the constructed elements of the subject portions of the original SIHP #s -31088 or -31089 roadways are evident today, and these portions of the historic properties lack integrity apart from their location.
A geophysical survey of the proposed project area will be performed during detailed design with the specific intent to locate subsurface voids (such as lava tubes) present beneath the site that may impact design and construction of the new wastewater treatment, disposal and collection systems.
This information will be included in the final EA.
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5. The Draft EA Section 3.9.1 (a) states:
“The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM), Community Panel No. 155166 1800F, effective date September 29, 2017 shows 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-1is very close to the edge of the 500-year floodplain.
On April 16, 2018, in response to the pre-assessment notification, the State of Hawai‘i Department of Land and Natural Resources Engineering Division stated the responsibility for conducting research as to the flood hazard designation for the project site lies with the project proponent. Also on April 16, 2018 and in response to the pre-assessment notification, the County of Hawai‘i Department of Public Works confirmed that the proposed treatment and disposal project site at Site 7 is designated as Zone X on the FIRM and is outside the 500-year floodplain.”
The relevant FIRM Panel is reproduced in Appendix B as Figure 4-13. This information will be repeated in the Final EA.
The Draft EA Section 3.23.2 (a) states:
“The proposed wastewater treatment and disposal facility would include an on-site drainage system to address stormwater surface runoff created by new impervious surfaces within the facility. The site would include a system to collect runoff via grated inlets or swales, and flows would be conveyed to on-site drainage detention systems, such as subsurface linear infiltration or depressed detention basins.”
The preceding information does not support significant historic flooding to the proposed project area.
This information will be included in the Final EA.
The preferred alternative (Site 7) slopes from approximately north to south (mauka to makai) such that, during rain events, surface flows pass through the existing orchard to the southern (makai) end where the flows eventually drain through the culvert located at the Maile Street-Māmalahoa Highway intersection to the areas below (makai) the highway. Most of the land
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surface area below the existing macadamia nut orchard contains little to no vegetation to absorb or slow these flows. The gradient of Site 7 and surrounding area results in this natural pattern of surface flows which also existed when the area was planted in sugar cane and is not considered flooding.
Based on the roadway flooding concerns expressed by the community during the Pahala public meetings held in December 2017 and October 2018, the State of Hawai‘i Department of Transportation (DOT) Hawai‘i District office was contacted to discuss drainage at the treatment and disposal facility project site and the culvert at the Maile Street and Māmalahoa Highway intersection. On February 20, 2019, the District office confirmed via telephone that the DOT owns and maintains the culvert at the Maile Street intersection, and that they have no record of the roadway being inundated by stormwater drainage during precipitation eventsat this location.
Stormwater runoff generated mauka of the treatment and disposal facility project site will be directed around the perimeter of the site via diversion swales that will convey flow back to the existing drainage pattern that flows to the existing culvert at Maile Street. During heavy rain events, stormwater may temporarily back up behind the culvert. There will be no changes to this culvert and the proposed treatment and disposal facilities will not be located within the area of the culvert.
As stated in the Draft EA, the on-site stormwater management system will meet the requirements of Hawai‘i County Code (HCC), Chapter 27 Floodplain Management, Section 20,Standards for subdivisions and other developments (e) which mandates a site drainage plan to “comply with sections 27-20(a) and (b) and section 27-24, and shall include a storm water disposal system to contain run-off caused by the proposed development, within the site boundaries, up to the expected [design] storm event as shown in the department of public works “Storm Drainage Standards”.”
To meet the requirements of HCC, Chapter 27, Section 20 (f), the project “shall not alter the general drainage pattern above or below the development”. Thus, for the HCC design storm event no increase in flow amount will be directed to either of the culverts at the highway as a result of the site development. A drainage report will be prepared during the detailed design process to evaluate the improvements necessary to comply with HCC Chapter 27 requirements.
The wastewater treatment processes will be designed to accommodate the associated peak flows, including precipitation that falls on the area occupied by the aerated lagoon treatment system. The Draft EA Appendix B, Section 2.2 outlines the anticipated peak wastewater flows from the community, based on the applicable flow standard. The Draft EA Section 2.3.1 states the aerated lagoons will be lined to prevent water seepage through the bottom and sides of the lagoons. The Draft EA Appendix B, Section 5.3 shows the operational freeboard
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that will be available to contain and to equalize lagoon flows. In addition, the slow-rate land application groves will be designed to completely contain both peak effluent flows and precipitation from a 100-year, 24-hour storm event. A geotechnical engineering assessment of berm stability will be conducted during the design process. The tree groves will be designed in accordance with the EPA’s “Process Design Manual, Land Treatment of Municipal Wastewater Effluents”. Effluent will be applied at a hydraulic loading rate that is a small percentage of the percolation rate of the soil, ensuring sufficient capacity for assimilation of peak effluent flow rates and precipitation from the design storm event.
This information will be included in the Final EA.
6. The Pāhala wastewater treatment plant (WWTP) 14.9-acre project site has been developed to provide the necessary land area for the facilities needed to treat the incoming flows and to dispose the treated effluent from the treatment processes. The project site minimizes the use of the adjacent lands which contain a commercial macadamia orchard. A larger project site is not required. The special permit requirement applies to the proposed WWTP parcel only, not to the proposed utility easement. The County will apply for the required special permit through the Planning Commission.
7. The following is a summary of information from Final EA. The U.S. Census Bureau provides the American Community Survey (ACS), which updates selected demographic, social, and economic information for various years. This includes age, racial composition, and economic information, including employment and household income by Census Designated Place for several locations in Hawaiʻi County. The most recent version of the ACS is the 2012-2016 5-Year Estimates, released in 2017.
The ACS shows the Pāhala population has a similar age distribution to Hawai‘i County, although Pāhala has a higher proportion of individuals in the “Under 5 to 19” age category, 28.5 percent compared to 24.4 percentfor the County. The median age for Pāhala is 42.4 years compared to 41.8 years for the County.
Overall, Pāhala is characterized by a racial composition that includes a greater proportion of minorities than the County. 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 higher proportion of residents that have completed high school and some college than the County overall, but a 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. For analysis
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purposes 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
Despite the relatively high proportions of low-income, minority, and children residents in Pāhala compared to the County, the project would not result in disproportionately high and adverse human health or environmental effects on these sensitive populations. The design shows the proposed wastewater treatment and disposal facility would include odor controls to minimize odor and air quality impacts to nearby areas. 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, construction activities within the community would need to comply with provisions of HAR 11-46 (Community Noise Control). This includes the contractor 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 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, with replacement of the substandard collection system and closure of the LCCs, the project is expected to result in positive human health and environmental effects to Pāhala residents by providing a cleaner and longer-lasting wastewater collection and treatment and treatment and disposal system.
The Final EA Section 3.16 will include further detail information.
The Draft EA Section 2.1.4 provides a history of wastewater management for Pāhala. In2003, C. Brewer requested assistance from the County to close their large capacity cesspools as required by the Environmental Protection Agency. The County entered into an agreement with C. Brewer (in April 2007) and is moving forward with the Pāhala Large Capacity Cesspool Replacement project. The Draft EA Section 2.1.2 states the project may also be funded by the State of Hawaiʻi DOH Clean Water State Revolving Fund (CWSRF) Program. 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.
The Draft EA Section 2.3.2 states the new collection system would be subject to the County of Hawaiʻi Code (HCC) Chapter 21, Sewers. Specifically, HCC Chapter 21, Article 2 (Public Sewers), Section 21-5, which 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
10349-01Letter to Pele Defense FundPage 9March 6, 2020
their expense to connect directly with the public sewer within 180 days after date of official notice.”
All accessible properties will be required to connect to the new wastewater collection system in accordance with Hawaii County Code, Chapter 21, Article 2, Section 21-5. However, the County entered into an agreement with C. Brewer (in April 2007) to eliminate LCCs from the existing community sewer systems and connect properties discharging to them to new County collection, treatment and disposal systems. Once the actual costs are determined, County Council action is still required to approve the expenditures. The agreement with C. Brewer did not address newly accessible properties.
The financial impact of the project on individual newly accessible property owners was raised by the community during the December 2017 public meetings as summarized in Section 7 of the Draft EA. Although not required by Hawaii Administrative Rules (HAR) Title 11, Chapter 200, DEM voluntarily convened two additional public meetings on October 9, 2018 and March 21, 2019 to gain further input from newly accessible property owners and present funding options for them to pursue.
The Draft EA Section 7 will be revised to add that the County held additional meetings in Pāhala including one to provide information on financing sources available to owners of parcels which would become accessible to the County collection system. The purpose of the March 21, 2019 meeting was to fulfill a County commitment made in October, 2018 to research financing options available to the newly accessible residents of the Pahala Community. At the meeting, DEM provided the preliminary results of the County investigation into funding sources and options available for newly accessible property owners once the new treatment and disposal facility and wastewater collection system have been designed, permitted and constructed.
Programs discussed included:
x US Department of Housing and Urban Development (HUD) with County of Hawaii Office of Housing and Community Development Residential Repair Program -Community Block Grant Program, and
x US Department of Agriculture - Rural Development (USDA-RDA) Program.
As noted during the presentation, the programs may change in the coming years and additional options may be added to this preliminary list. Hawaii Legislature, Senate Bill 221SD1, which could amend Hawaii Revised Statutes (HRS) Chapter §342D to establish a low interest loan program to offer financial assistance to cesspool owners to connect to wastewater treatment systems approved by the Department of Health was also discussed; however, this bill was subsequently not passed during the 2019 legislative session.
10349-01Letter to Pele Defense FundPage 10March 6, 2020
This information will be included in the Final EA.
8. This is not a comment pertinent to the content requirements of the Draft EA for the Pahala Large Capacity Cesspool Replacement project.
Regarding the attached resident petition, the Draft EA Section 2.7 describes the site selection process, including the factors and their relative weights used to evaluate the various sites. The section further describes the twenty-one criteria within four general categories (environmental, social and cultural; location and site; land use and availability; and collection system and service area) that were established and defined for the analysis. The Draft EA Appendix B, Section 8, provides additional information regarding the site selection process. As a result of this process, the County identified three sites (Sites 7, 8, and 9) as reasonable alternatives for construction of the wastewater treatment and disposal facility under the Proposed Action. The final scores for Sites 7, 8, and 9 were 4.33, 4.06, and 4.10 respectively, out of a total possible score of 5. Based on this analysis, Site 7 was selected as the Preferred Alternative. The site is easily accessible, has good soils for a land application system, and is close to the existing LCCs.
The Draft EA Section 2.5 describes Site 9, which is south (makai) of the Preferred Alternative Site 7. As outlined in Appendix B Section 8, Site 9 earned a lower ranking than Site 7 for the following criteria: presence of and/or proximity to archaeological/cultural sites, existing vehicle access, power and potable water availability, and distance from the area of the wastewater collection system. Site 7 had a lower ranking than Site 9 in one category: topography. With the distance between the two sites less than 300 feet, they were ranked equally for the criteria of proximity of treatment units to existing occupied buildings.
The Draft EA Sections 2.5 and 2.7 provide information as to the issues related to the use of Site 9.An unnamed stream near the upper portion of the parcel could affect the selected configuration of the wastewater treatment facility and the land application groves. Potentially, to maximize energy efficiency by taking advantage of gravity flow, the headworks, lagoons and the subsurface constructed wetlands could be sited in the upper portion of the site, or the area closest to the highway. In addition, since the site is located across Māmalahoa Highway from the Pāhala community, it would require construction of piping and other utilities within the highway ROW and approval by the State of Hawaiʻi Department of Transportation. Site 9 would require additional access roads to facilitate both construction and operation of the treatment and disposal facility and a slightly longer transmission line given its increased distance from the existing LCCs.
This information will be included in the Final EA.
The proposed site plan is included in the Draft EA as Figure 2.3. As noted in Section 2.3.1, “disposal of the treated and disinfected effluent would be accomplished through land treatment in four groves of native, water-tolerant trees occupying a total area of approximately 8.0 acres.”This 8.0 acre planted area, combined with the sloping site topography and existing Cook pine
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trees (Araucaria columnaris) on Maile Street, will provide a visual buffer from both the Māmalahoa Highway and Maile Street. As outlined in Section 3.19.2 of the Draft EA, the Proposed Action is not expected to adversely affect the views or viewsheds identified in the County General Plan. The wastewater collection system would be installed below the streets and therefore would not impact views. Above-grade structures may include the operations building, headworks and UV cover structures, fuel storage tank, and low berms around the basins. The existing pine trees along Maile Street, most of which would remain with no changes, would continue to obstruct the viewplanes from Maile Street. The facility site would be adjacent (mauka) to, and visible from, Māmalahoa Highway (State Route 11); however, impacts to the viewplane would be mitigated by the planted trees in the basins and by the rise in elevation between the highway and the facility.
Please note, the attached documentation shows the County’s attempt to gather information related to the 6 notarized attachments to your October 23, 2108 letter. Refer to response 4 above for additional information regarding additional archaeological and geophysical investigations undertaken since the publication of the Draft EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (55)March 6, 2020
Mr. Alfred Ibarra Mrs. Mary Ibarra P.O. Box 396 Pāhala, Hawaii 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻū, HawaiʻiResponse to Comment – post marked November 13, 2018
Dear Mr. and Ms. Ibarra
Thank you for your comment letter post marked November 13, 2018 regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
The County’s intent, as stated in the June 22, 2017 US Environmental Protection Agency Region 9 Administrative Order on Consent (AOC), is to provide an industry-standard wastewater collection system and a secondary treatment and disposal facility, a basic service to the Pāhala community, to eliminate underground injection from LCCs it operates to help protect underground drinking water sources. The AOC, which was issued on June 22, 2017 states: “The Pahala Wastewater Treatment Facility shall be designed in accordance with good engineering practices and capable of servicing all residential properties currently connected to the Pahala Community Cesspools, plus a minimum of sixty-five (65) additional properties…”. An electronic version of the AOC can be found on the USEPA website at: https://www.epa.gov/sites/production/files/2017-06/documents/sdwa-uic-aoc-09-2017-0002-aoc-2017-04-26.pdf.
Closure of individual cesspools is mandated by legislation at the State level. In 2017, Act 125was enacted by the Hawaiʻi State legislature requiring all cesspools, not exempted by the Department of Health, be upgraded or converted to septic systems, or aerobic treatment unit systems, or connected to sewage systems by January 1, 2050. Though closure of individual wastewater systems by the County is not part of the Proposed Action, this legislation will affect all parcels in Pāhala currently utilizing cesspools for sewage disposal.
The Draft EA Figure 2.2 shows the collection system on the various streets within the community. The extent of the collection system is to ensure the parcels connected to the former C. Brewer system will have access to the treatment and disposal facility so the large capacity cesspools can be closed. It is conventional to extend the utility to the nearest intersection to minimize the number of manholes. Similar to Huapala and Puahala Streets, the collection
10349-01Letter to Mr. Alfred Ibarra/Mrs. Mary Ibarra Page 2March 6, 2020
system in Pīkake Street extends to Pakalana Street to meet the objectives of the Ka‘ū Community Development Plan and not preclude a future line in Pakalana Street. As stated in the Draft EA, the proposed collection system is routed primarily within the County right-of-way, for ease of access for both construction and maintenance.
As outlined in the Draft EA, Section 2.3.2, the new collection system would be subject to the Hawaiʻi County Code (HCC) Chapter 21, Sewers, specifically, Article 2 (Public Sewers), Section 21-5, which 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.”
Each adjacent lot will be provided with a lateral connection to the sewer main as required by HCC and standards. Under the Preferred Alternative, the design of the new collection system would extend between street intersections and include sewer service stub-outs (the lateral connection to the sewer main) to the lot lines of adjacent properties, including the newly accessible, to accommodate their eventual connection. Accordingly, to close the existing LCCs, there will be additional properties in Pāhala that would be required to connect to the new wastewater collection system, at their expense, after it becomes operational. Such properties are near the existing service area but are presently connected to individual wastewater systems. To conform to the stated section of HCC, the respective, newly accessible property owners would be responsible for the design, permitting and completion of sewer service connections between the County stub-outs and improvements for stated uses on their property, as well as for the proper closure of their individual wastewater systems. The Draft EA Figure 2.6 shows the area of the community serviced by the current and proposed collection systems.
All accessible properties will be required to connect to the new wastewater collection system in accordance with Hawaii County Code, Chapter 21, Article 2, Section 21-5. However, the County entered into an agreement with C. Brewer (in April 2007) to eliminate LCCs from the existing community sewer systems and connect properties discharging to them to new County collection, treatment and disposal systems. Once the actual costs are determined, County Council action is still required to approve the expenditures.
Although not a comment related to the content requirements of the Draft EA, County of Hawaii sewer rates are outlined in HCC Chapter 21, Article 4 (Sewer Service Charges):
“Sewer user charges for residential customers shall be assessed to all lots accessible
to a public sewer or public gang cesspools whether connected or not. User charges for sewer service…shall be according to the schedule shown under section 21-36.1”
The Hawaii County Code Chapter 21 was adopted in 1983.
10349-01Letter to Mr. Alfred Ibarra/Mrs. Mary Ibarra Page 3March 6, 2020
On April 25, 2010, a community meeting sponsored by Councilman Guy Enriques was held at the Pāhala Community Center to discuss the Nā‘ālehu and Pāhala Large Capacity Cesspool Replacement project. As part of the meeting, an informational handout prepared by the County’s Wastewater Division provided a brief history of the project documenting that, in 2004, Mayor Kim’s office used a ballot system to get input from property owners regarding different wastewater treatment/ disposal alternatives for those property owners connected to the LCCs who would no longer be served by the C. Brewer system after LCC closure. As reported in the Draft EA Section 2.1.4, 87 percent of the returned ballots were in favor of the installation of a new sewer collection system and a treatment and disposal system to be operated and maintained by the County. The handout indicated that Mayor Kim’s office advised the property owners the County would move forward with a new system for Nā‘ālehu and Pāhala on November 5, 2004. Additionally, the handout stated public meetings were held in both Nā‘ālehu and Pāhala in November 2006 to discuss the wastewater system alternatives. The handout included that adequate land for the treatment and disposal system had not been identified in Pāhala. The handout also stated that all properties accessible to the new system would be required to connect in accordance with Hawaii County Code Chapter 21.
The Draft EA Section 7 documents the 5 public meetings held in Pāhala December 12, 13 and 14, 2017 to discuss the Pāhala Large Capacity Cesspool Replacement project. As documented in the Draft EA, the community outreach program for the current project was designed as “talk story” sessions to optimize community conversations in informal sessions. Further, as documented in the Draft EA, invitations and announcements for the talk story sessions were intended to reach all audiences, as follows:
• Property owners with C. Brewer lines on their property were mailed letters from DEM inviting them to these sessions. The letters included stamped, mail-in postcards to facilitate the RSVP process. • Fliers were hand-delivered to “newly-accessible” properties. • Organizational leaders were provided copies of fliers announcing meetings and asked to circulate among their members. •Fliers were posted in public venues, such as the post office, the Pāhala Community Center and the Ka‘ū Hospital. •Several online announcements were included in Ka‘ū News Briefs available at http://kaunewsbriefs.blogspot.com.
This information will be repeated in the Final EA.
On September 26, 2018, a public notice was published in both the Hawaii Tribune Herald and
West Hawaii Today which stated a public meeting was to be held on October 10, 2018 for the Pāhala Large Capacity Cesspool Replacement Project Draft EA. A public notice was also published in the October 1, 2018 print and online editions of the .Dµnj&DOHQGDU and made available on the Ka‘ū News Briefs web site http://kaunewsbriefs.blogspot.com. Fliers were also
10349-01Letter to Mr. Alfred Ibarra/Mrs. Mary Ibarra Page 4March 6, 2020
posted in public venues such as the community shopping center, realtor office, grocery store, library, and the Pāhala Community Center. This information will be included in the Final EA.
On September 10, 2018, letters containing information on the availability of the Draft EA, the comment period, and the October 10, 2018 meeting were mailed to all property owners on record adjacent to the proposed collection system. On October 26, 2018 letters were mailed to all property owners on record adjacent to the proposed collection system informing them of the extension of the public comment period to December 10, 2018.
The financial impact of the project on individual newly accessible property owners was raised by the community during the December 2017 public meetings as summarized in Section 7 of the Draft EA and again during the October 2018 meetings. Although not required by HawaiʻiAdministrative Rules (HAR) Title 11, Chapter 200, DEM 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 for the newly accessible residents of the Pāhala Community to pursue.
Programs discussed and included:
x US Department of Housing and Urban Development (HUD) with County of Hawaii Office of Housing and Community Development Residential Repair Program -Community Block Grant Program, and
x US Department of Agriculture - Rural Development (USDA-RDA) Program.
As noted during the presentation, these programs may change in the coming years, and additional options may be added to this preliminary list. Hawaii Legislature, Senate Bill 221 SD1, which could amend Hawaii Revised Statutes (HRS) Chapter §342D to establish a low interest loan program offering financial assistance to cesspool owners to connect to wastewater treatment systems approved by the Department of Health was also discussed; however, this bill was subsequently not passed during the 2019 legislative session.
This information will be included in the Final EA.
The Draft EA Section 3.9.1 (a) states:
“The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM), Community Panel No. 155166 1800F, effective date September 29, 2017 shows 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
10349-01Letter to Mr. Alfred Ibarra/Mrs. Mary Ibarra Page 5March 6, 2020
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.
On April 16, 2018, in response to the pre-assessment notification, the State of Hawai‘i Department of Land and Natural Resources Engineering Division stated the responsibility for conducting research as to the flood hazard designation for the project site lies with the project proponent. Also on April 16, 2018 and in response to the pre-assessment notification, the County of Hawai‘i Department of Public Works confirmed that the proposed treatment and disposal Site 7 is designated as Zone X on the FIRM and is outside the 500-year floodplain.”
The relevant FIRM panel is reproduced in Appendix B as Figure 4-13.
This information will be repeated in the Final EA.
The Draft EA Section 3.23.2(a) states:
“The proposed wastewater treatment and disposal facility would include an on-site drainage system to address stormwater surface runoff created by new impervious surfaces within the facility. The site would include a system to collect runoff via grated inlets or swales, and flows would be conveyed to on-site drainage detention systems, such as subsurface linear infiltration or depressed detention basins.”
This information will be repeated in the Final EA.
The preferred alternative (Site 7) slopes from approximately north to south (mauka to makai)such that, during rain events, surface flows drain through the existing orchard to the southern (makai) end where the flows eventually drain through the culvert located at the Maile Street-Māmalahoa Highway intersection to the areas below (makai) the highway. Most of the land surface area below the existing macadamia nut orchard contains little to no vegetation to absorb or slow these flows. The gradient of Site 7 and surrounding area results in this natural pattern of surface flows which also existed when the area was planted in sugar cane and is not considered flooding.
Based on the roadway flooding concerns expressed by the community during the Pahala public meetings held in December 2017 and October 2018, the State of Hawai‘i Department of Transportation (DOT) Hawai‘i District office was contacted to discuss drainage at the treatment and disposal facility project site and the culvert at the Maile Street and Māmalahoa Highway intersection. On February 20, 2019, the District office confirmed via telephone that the DOT
10349-01Letter to Mr. Alfred Ibarra/Mrs. Mary Ibarra Page 6March 6, 2020
owns and maintains the culvert at the Maile Street intersection, and that they have no record of the roadway being inundated by stormwater drainage during precipitation events at that location.
Stormwater runoff generated mauka of the treatment and disposal facility project site will be directed around the perimeter of the site via diversion swales that will convey flows back to the existing drainage pattern that flows to the existing culvert at Maile Street. During heavy rainevents, stormwater may temporarily back up behind the culvert. There will be no changes to this culvert and the proposed treatment and disposal facilities will not be located within the area of the culvert.
As stated in the Draft EA, the on-site stormwater management system would meet the requirements of Hawai‘i County Code (HCC), Chapter 27 Floodplain Management, Section 20, Standards for subdivisions and other developments (e) which mandates a site drainage plan to “comply with sections 27-20(a) and (b) and section 27-24, and shall include a storm water disposal system to contain run-off caused by the proposed development, within the site boundaries, up to the expected [design] storm event as shown in the department of public works “Storm Drainage Standards”.
To meet the requirements of HCC, Chapter 27, Section 20 (f), the project site “shall not alter the general drainage pattern above or below the development”. Thus, for the HCC design storm event, no increase in flow amount will be directed to either of the culverts at the highway as a result of the site development. A drainage report will be prepared during the design process to evaluate the improvements that are necessary to comply with Chapter 27 HCC requirements.
The wastewater treatment processes will be designed to accommodate the associated peak flows, including precipitation that falls on the area occupied by the aerated lagoon treatment system. The Draft EA Appendix B, Section 2.2 outlines the anticipated peak wastewater flows from the community, based on the applicable flow standard. The Draft EA Section 2.3.1, states the aerated lagoons will be lined to prevent water seepage through the bottom and sides of the lagoons. The Draft EA, Appendix B, Section 5.3 shows the operational freeboard that will be available to contain and to equalize lagoon flows. In addition, the slow-rate land application groves will be designed to completely contain both peak effluent flows and precipitation from a 100-year, 24-hour storm event. A geotechnical engineering assessment of berm stability will be conducted during the design process for berms intended to act as secondary containment. The tree groves will be designed in accordance with the EPA’s “Process Design Manual, LandTreatment of Municipal Wastewater Effluents”. Effluent will be applied at a hydraulic loading rate that is a small percentage of the percolation rate of the soil, ensuring sufficient capacity for assimilation of peak effluent flow rates and precipitation from the design storm event.
This information will be included in the Final EA.
10349-01Letter to Mr. Alfred Ibarra/Mrs. Mary Ibarra Page 7March 6, 2020
The Draft EA Section 2.7 describes the site selection process, including the factors and their relative weights used to evaluate the various sites. Further, Section 2.7 describes the twenty-one criteria within four general categories (environmental, social and cultural; location and site; land use and availability; and collection system and service area) that were established and defined for the analysis. The Draft EA Appendix B, Section 8, provides additional information regarding the site selection process. As a result of this process, the County identified three sites (Sites 7, 8, and 9) as reasonable alternatives for construction of the wastewater treatment and disposalfacility under the Proposed Action. The final scores for Sites 7, 8, and 9 were 4.33, 4.06, and 4.10 respectively, out of a total possible score of 5. Based on this analysis, Site 7 was selected as the Preferred Alternative. The site is easily accessible, has good soils for a land application system, and is close to the existing LCCs.
The Draft EA Section 2.5 describes Site 9, which is south (makai) of the Preferred Alternative Site 7. As outlined in Appendix B Section 8, Site 9 earned a lower ranking than Site 7 for the following criteria: presence of and/or proximity to archaeological/cultural sites, existing vehicle access, power and potable water availability, and distance from the area of the wastewater collection system. Site 7 had a lower ranking than Site 9 in one category: topography. With the distance between the two sites less than 300 feet, they were ranked equally for the criteria of proximity of treatment units to existing occupied buildings.
The Draft EA Sections 2.5 and 2.7 provide information as to the issues related to the use of Site 9. An unnamed stream near the upper portion of the parcel could affect the selected configuration of the wastewater treatment facility and the land application groves. Potentially, to maximize energy efficiency by taking advantage of gravity flow, the headworks, lagoons and the subsurface constructed wetlands could be sited in the upper portion of the site, or the area closest to the highway. In addition, since the site is located across Māmalahoa Highway from the Pāhala community, it would require construction of piping and other utilities within the highway ROW and approval by the State of Hawaiʻi Department of Transportation. Site 9 would require additional access roads to facilitate both construction and operation of the treatment and disposal facility and a slightly longer transmission line given its increased distance from the existing LCCs.
This information will be included in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
10349-01Letter to Mr. Alfred Ibarra/Mrs. Mary Ibarra Page 8March 6, 2020
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (56)March 6, 2020
Mr. Walter T.L. and Ms. Debra A. Wong YuenP.O.Box 29Pāhala, Hawai‘i 96777
Subject: Draft Environmental Assessment for the,Pāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻū, HawaiʻiResponse to Comment - November 14, 2018
Dear Mr. and Ms. Wong Yuen:
Thank you for your November 14, 2018 comment letter regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
The Draft EA Section 2.1.3 states: “In 1999, EPA promulgated regulations under the Safe Drinking Water Act’s Underground Injection Control (UIC) Program which prohibited the construction of new large capacity cesspools (LCCs) as of April 2000 and required the closure of all existing LCCs by April 5, 2005 (see 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. Cesspools can release disease-causing pathogens and other pollutants (e.g., nitrates) into ground water aquifers, streams, and eventually the ocean, thus leading to public health and environmental concerns. In June 2017, EPA and the County entered into an Administrative Order on Consent (AOC) to close the County-operated LCCs serving the Pāhala Community by June 2021.”
The Final EA Section 2.1.3 will include the County has previously abandoned or assisted with closure of other LCCs in locations including Hilo, Kona, Honokaa and Pāhala.
The County’s intent, as stated in the June 22, 2017 US Environmental Protection Agency Region 9 Administrative Order on Consent is to provide an industry-standard wastewater collection system and a secondary treatment and disposal facility, a basic service to the Pāhala community, to eliminate underground injection from LCCs it operates to help protect underground drinking water sources. Closure of individual cesspools is mandated by legislation at the State level. In 2017, Act 125 was enacted by the Hawai’i State legislature requiring all cesspools, not exempted by the Department of Health, be upgraded or converted to septic systems, or aerobic treatment unit systems, or connected to sewage systems by January 1, 2050. Though closure of individual wastewater systems by the County is not part of the Proposed Action, this legislation will affect all parcels in Pāhala currently using cesspools for sewage disposal.
10349-01Letter to Mr. Walter T.L. and Ms. Debra A. Wong YuenPage 2March 6, 2020
The Final EA Section 3.16 will include further detail information.
The Draft EA Section 5.7 will be revised as follows
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 2017 American Community Survey (ACS) (5-Year Estimates) is the most recent information related to socioeconomic conditions in the state and County. The 2017 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 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. Pāhala has more households in the “less than $24,999” income bracket (33.7 percent) than the County as a whole (26.3 percent).
Overall, Pāhala is characterized by a racial composition that includes a greater proportion of minorities (92.1 percent non-White) than the County at large (66.8 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 Hawai‘i County, although Pāhala has a higher proportion of individuals in the “Under 5 to 19” age category (28.5 percent) compared to the County as a whole (24.4 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. The design and location of the proposed wastewater treatment and disposal 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,
10349-01Letter to Mr. Walter T.L. and Ms. Debra A. Wong YuenPage 3March 6, 2020
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.
Based on the above, construction and operation of the collection system and the treatment and disposal facility would have a disproportionately high adverse impact on the minority and low income population in the Pāhala community.”
This information will be included in the Final EA.
The financial impact of the project on individual newly accessible property owners was raised by the community during the December 2017 public meetings as summarized in Section 7 of the Draft EA. Although not required by Hawaii Administrative Rules (HAR) Title 11, Chapter 200, DEM convened two additional public meetings one on October 9, 2018 and another on March 21, 2019 to gain further input from newly accessible property owners and present funding options for them to pursue.
The Draft EA Section 7 will be revised to add that the County held additional meetings in Pāhala including one to provide information on financing sources available to owners of parcels which would become accessible to the County collection system. The purpose of the March 21, 2019 meeting was to fulfill a County commitment made in October, 2018 to research financing options available to the newly accessible residents of the Pāhala Community. At the meeting, DEM provided the preliminary results of the County investigation into funding sources and options available for newly accessible property owners once the new treatment and disposal facility and wastewater collection system have been designed, permitted and constructed.
Programs discussed included:
x US Department of Housing and Urban Development (HUD) with County of Hawaii Office of Housing and Community Development Residential Repair Program -Community Block Grant Program, and
x US Department of Agriculture - Rural Development (USDA-RDA) Program.
As noted during the presentation, these programs may change in the coming years, and additional options may be added to this preliminary list. Hawaii Legislature, Senate Bill 221 SD1, which could amend Hawaii Revised Statutes (HRS) Chapter §342D to establish a low interest loan
10349-01Letter to Mr. Walter T.L. and Ms. Debra A. Wong YuenPage 4March 6, 2020
program to offer financial assistance to cesspool owners to connect to wastewater treatment systems approved by the Department of Health was also discussed; however, this bill was subsequently not passed during the 2019 legislative session.
This information will be included in the Final EA.
The Final EA Section 7 will include that on September 26, 2018 a public notice was published in the Hawaii Tribune Herald and West Hawaii Todaynewspapers. The public notice was to advertise the October 10, 2018, public information meeting conducted by the County in the Pāhala at the Ka‘ū Gym Multi-Purpose Conference Room to discuss the availability of the Draft EA and process for submitting comments. The notice stated that the second part of the meeting would address Section 106 of the National Historic Preservation Act of 1966, as amended (2006)involving consultation with Native Hawaiian Organizations and the Native Hawaiian descendants with ancestral lineal or cultural ties to, cultural knowledge or concerns for, and cultural religious attachment to the proposed project area. The Office of Environmental Quality Control rules have no provision for receiving oral comments. However, the facilitator at that meeting offered assistance by persons available at the meeting in putting any oral comments attendees may wish to offer into writing.
The Draft EA Section 2.7 describes the site selection process, including the factors and their relative weights used to evaluate the various sites. Further, Section 2.7 describes the twenty-one criteria within four general categories (environmental, social and cultural; location and site; land use and availability; and collection system and service area) that were established and defined for the analysis. The Draft EA Appendix B, Section 8, provides additional information regarding the site selection process. As a result of this process, the County identified three sites (Sites 7, 8, and 9) as reasonable alternatives for construction of the wastewater treatment and disposal facility under the Proposed Action. The final scores for Sites 7, 8, and 9 were 4.33, 4.06, and 4.10 respectively, out of a total possible score of 5. Based on this analysis, Site 7 was selected as the Preferred Alternative. The site is easily accessible, has good soils for a land application system, and is close to the existing LCCs.
The Draft EA Section 2.5 describes Site 9, which is south (makai) of the Preferred Alternative Site 7. As outlined in Appendix B Section 8, Site 9 earned a lower ranking than Site 7 for the following criteria: presence of and/or proximity to archaeological/cultural sites, existing vehicle access, power and potable water availability, and distance from the area of the wastewater collection system. Site 7 had a lower ranking than Site 9 in one category: topography. With the distance between the two sites less than 300 feet, they were ranked equally for the criteria of proximity of treatment units to existing occupied buildings.
The Draft EA Sections 2.5 and 2.7 provide information as to the issues related to the use of Site 9. An unnamed stream near the upper portion of the parcel could affect the selected configuration of the wastewater treatment facility and the land application groves. Potentially, to
10349-01Letter to Mr. Walter T.L. and Ms. Debra A. Wong YuenPage 5March 6, 2020
maximize energy efficiency by taking advantage of gravity flow, the headworks, lagoons and the subsurface constructed wetlands could be sited in the upper portion of the site, or the area closest to the highway. In addition, since the site is located across Māmalahoa Highway from the Pāhala community, it would require construction of piping and other utilities within the highway ROW and approval by the State of Hawaiʻi Department of Transportation. Site 9 would require additional access roads to facilitate both construction and operation of the treatment and disposal facility and a slightly longer transmission line given its increased distance from the existing LCCs.
This information will be included in the Final EA.
HRS 343 Section 5 (a)(9)(A), states as follows: “(a) Except as otherwise provided, an environmental assessment (emphasis added) shall be required for actions that: ... (9) Propose any: (A) Wastewater treatment unit, except an individual wastewater system or a wastewater treatment unit serving fewer than fifty single-family dwellings or the equivalent…”.
HRS 343-5 Applicability and requirements states under item (c) (4) “A(n environmental impact) statement shall be required if the agency finds that the proposed action may have a significant effect on the environment…” The criteria by which the proposing agency makes the significance determination is provided in HAR 11- 200-12 (a) and (b) which states: “(a) In considering the significance of potential environmental effects, agencies shall consider the sum of the effects on the quality of the environment, and shall evaluate the overall and cumulative effects of an action. (b) In determining whether an action may have a significant effect on the environment, the agency shall consider every phase of a proposed action, the expected consequences,… and the…effects of the action.”
HAR 11-200-10 Contents of an environmental assessment includes “(9) Findings and reasons supporting the agency determination or anticipated determination…” The Draft EA provides this information in Chapter 8 Findings and Determination. Neither HRS Chapter 343 nor HAR Title 11, Chapter 200 contain any requirement that all proposed wastewater systems require an EIS.
The Draft EA Section 3.15 references a November 2016 archaeological field inspection report undertaken as part of the initial planning for the LCC closure. The report states, while the 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 parcel (which includes Site 7), as well as evidence from plantation-era documents that the opening of a lava tube containing human remains once existed in the southeastern corner of the parcel, indicate that further archaeological studies may be necessary. The Final EA will include that the November 2016 archaeological field inspection report also stated it would be advisable to limit the development footprint to exclude the southeastern corner of the 42.5-acre parcel. This area, which is presently not used as a macadamia nut orchard, but forms part of the macadamia nut plant, is the location of a known (but sealed) lava tube opening that local informants have
10349-01Letter to Mr. Walter T.L. and Ms. Debra A. Wong YuenPage 6March 6, 2020
indicated is linked to tubes that possess traditional human burials. Further, by excluding this section of the parcel, it will be possible to avoid at least one known historic property. The Draft EA Figure 2.3, which provides the Preliminary Site Plan for the new treatment and disposal facility, shows the 14.9-acre project site has been developed to exclude the area in the southeastern corner identified as the location of the sealed lava tube opening.
Between September 18, 2018 and January 10, 2019 a team of qualified archaeologists conducted a pedestrian survey of the proposed project site and completed subsurface trenching to determine the presence of archaeological resources. The work was undertaken in accordance with the State of Hawaii Department of Land and Natural Resources State Historic Preservation Division (SHPD) requirements, with the archaeological inventory survey (AIS) approach accepted by SHPD in their August 20, 2018 letter. The results of the survey and subsurface trenching showed no burials or lava tube openings were identified on-site. The AIS submitted to SHPD in March 2019 documents that a sealed lava tube opening is located east of the proposed wastewater treatment and disposal facility project site, outside the proposed property boundary, and outside of the area of potential effect considered in consultation with the SHPD.
The complete document is available for download from the County’s website at: http://records.co.hawaii.hi.us/weblink/1/edoc/100962/Draft%20Archeological%20Inventory%20Survey%20-%20Pahala%20WWTP%20and%20Sewer%20System.pdf
A geophysical survey of the proposed project area will be performed during detailed design with the specific intent to locate subsurface voids (such as lava tubes) present beneath the site that may impact design and construction of the new wastewater treatment, disposal and collection system.
This information will be included in the Final EA.
The Draft EA Section 3.9.1 (a) states:
“The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM), Community Panel No. 155166 1800F, effective date September 29, 2017 shows 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-1is very close to the edge of the 500-year floodplain.
10349-01Letter to Mr. Walter T.L. and Ms. Debra A. Wong YuenPage 7March 6, 2020
On April 16, 2018, in response to the pre-assessment notification, the State of Hawai‘i Department of Land and Natural Resources Engineering Division stated the responsibility for conducting research as to the flood hazard designation for the project site lies with the project proponent. Also on April 16, 2018 and in response to the pre-assessment notification, the County of Hawai‘i Department of Public Works confirmed that the proposed treatment and disposal project site at Site 7 is designated as Zone X on the FIRM and is outside the 500-year floodplain.”
The relevant FIRM panel is reproduced in Appendix B as Figure 4-13.
This information will be repeated in the Final EA.
The Draft EA Section 3.23.2 (a) states:
“The proposed wastewater treatment and disposal facility would include an on-site drainage system to address stormwater surface runoff created by new impervious surfaces within the facility. The site would include a system to collect runoff via grated inlets or swales, and flows would be conveyed to on-site drainage detention systems, such as subsurface linear infiltration or depressed detention basins.”
This information will be repeated in the Final EA.
The preferred alternative (Site 7) slopes from approximately north to south (mauka to makai) such that, during rain events, surface flows pass through the existing orchard to the southern (makai) end where the flows eventually drain through the culvert located at the Maile Street-Māmalahoa Highway intersection to the areas below (makai) the highway. Most of the land surface area below the existing macadamia nut orchard contains little to no vegetation to absorb or slow these flows. The gradient of Site 7 and surrounding area results in this natural pattern of surface flows which also existed when the area was planted in sugar cane and is not considered flooding.
Based on the roadway flooding concerns expressed by the community during the Pāhala public meetings held in December 2017 and October 2018, the State of Hawai‘i Department of Transportation (DOT) Hawai‘i District office was contacted to discuss drainage at the treatment and disposal facility project site and the culvert at the Maile Street and Māmalahoa Highway intersection. On February 20, 2019, the District office confirmed via telephone that the DOT owns and maintains the culvert at the Maile Street intersection, and that they have no record of the roadway being inundated by stormwater drainage during precipitation events at that location.
Stormwater runoff generated from mauka of the treatment and disposal facility project site will be directed around the perimeter of the site via diversion swales that will convey flow back to the existing drainage pattern that flows to the existing culvert at Maile Street. During heavy rain
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events, stormwater may temporarily back up behind the culvert. There will be no changes to this culvert and the proposed treatment and disposal facilities will not be located within the area of the culvert.
As stated in the Draft EA, the on-site stormwater management system would meet the requirements of Hawai‘i County Code (HCC), Chapter 27 Floodplain Management, Section 20, Standards for subdivisions and other developments (e) which mandates a site drainage plan to “comply with sections 27-20(a) and (b) and section 27-24, and shall include a storm water disposal system to contain run-off caused by the proposed development, within the site boundaries, up to the expected [design] storm event as shown in the department of public works “Storm Drainage Standards”.”
To meet the requirements of HCC, Chapter 27, Section 20 (f), the project site “shall not alter the general drainage pattern above or below the development”. Thus, for the HCC design storm event, no increase in flow amount will be directed to either of the culverts at the highway as a result of the site development. A drainage report will be prepared during the design process to evaluate the improvements necessary to comply with HCC Chapter 27 requirements.
The wastewater treatment processes will be designed to accommodate the associated peak flows, including precipitation that falls on the area occupied by the aerated lagoon treatment system. The Draft EA Appendix B, Section 2.2 outlines the anticipated peak wastewater flows from the community, based on the applicable flow standard. The Draft EA Section 2.3.1, states the aerated lagoons will be lined with high density polyethylene liners to prevent water seepage through the bottom and sides of the lagoons. The Draft EA Appendix B, Section 5.3 shows the operational freeboard that will be available to contain and to equalize lagoon flows. In addition, the slow-rate land application groves will be designed to completely contain both peak effluent flows and precipitation from a 100-year, 24-hour storm event. A geotechnical engineering assessment of berm stability will be conducted during the design process. The tree groves will be designed in accordance with the EPA’s “Process Design Manual, Land Treatment of Municipal Wastewater Effluents”. Effluent will be applied at a hydraulic loading rate that is a small percentage of the percolation rate of the soil, ensuring sufficient capacity for assimilation of peak effluent flow rates and precipitation from the design storm event.
Final EA Section 2.3.1 will state the entire wastewater treatment and disposal facility would beenclosed with a six-foot-high chain-link fence to prevent public access at the gated access driveway entrance.
The proposed site plan is included in the Draft EA as Figure 2.3. As noted in Section 2.3.1, “disposal of the treated and disinfected effluent would be accomplished through land treatment in four groves of native, water-tolerant trees occupying a total area of approximately 8.0 acres.”This 8.0 acre planted area, combined with the sloping site topography, berms, and existing Cook pine trees (Araucaria columnaris) on Maile Street, will provide a visual buffer from both the
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Māmalahoa Highway and Maile Street. As outlined in Section 3.19.2 of the Draft EA, the Proposed Action is not expected to adversely affect the views or viewsheds identified in the County General Plan. The wastewater collection system would be installed below the streets and therefore would not impact views. Above-grade structures may include the operations building, headworks and UV cover structures, fuel storage tank and berms around the basins. The existing pine trees along Maile Street, most of which would remain with no changes, would continue to obstruct the viewplanes from Maile Street. The facility site would be adjacent (mauka) to, andvisible from, Māmalahoa Highway (State Route 11); however, impacts to the viewplane would be mitigated by the planted trees in the basins and by the rise in elevation between the highway and the facility.
The Draft EA Section 2.3.1 states the driveway access to the wastewater treatment and disposal facility will be located west (mauka) of the Maile Street and Māmalahoa Highway intersection. Appropriate signs identifying the plant will be posted at the driveway access.
This information will be included in the Final EA.
The Draft EA Section 3.14.2 states:
“Wastewater treatment plants can be a source of nuisance odors to the surrounding community if not properly designed or operated. Typically, nuisance odors are most commonly associated with anaerobic (without oxygen) conditions and with processing of residual solids. Incoming raw sewage flows to the proposed wastewater treatment and disposal facility would first be routed to the headworks, which is the facility where the solids are removed from the flows.
To mitigate potential nuisance odors, the headworks would be equipped with an odor control system with a granulated activated carbon (GAC) scrubber to remove odors. Apackage GAC scrubber passes the odorous air through a bed of activated carbon, which adsorbs the odorous constituents within the pore spaces of the carbon. The County currently operates GAC scrubbers at other facilities, and it has been proven to be an effective means of odor control both locally and nationwide. The treatment lagoons would be equipped with mechanical aerators capable of maintaining sufficiently aerobic (with oxygen) conditions within the water column, which would prevent nuisance odor conditions from occurring. The disposal groves would be irrigated with fully-treated and aerobic secondary effluent from the treatment process; irrigation with secondary effluent is not associated with development of nuisance odor conditions.”
This information will be repeated in the Final EA Section 3.14.2.
10349-01Letter to Mr. Walter T.L. and Ms. Debra A. Wong YuenPage 10March 6, 2020
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (63)March 6, 2020
Ms. Gwendolyn Sorensen P.O. Box 27Pāhala, Hawai‘i 96777
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻū, HawaiʻiResponse to Comment- November 2, 2018; 2:37 p.m.
Dear Ms. Sorensen:
Thank you for your November 2, 2018 2:37 p.m. comment letter regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
1. a.The proposed site plan is included in the Draft EA as Figure 2.3. As noted in Section 2.3.1, “disposal of the treated and disinfected effluent would be accomplished through land treatment in four groves of native, water-tolerant trees occupying a total area of approximately 8.0 acres.”This 8.0 acre planted area, combined with the sloping site topography and existing Cook pine trees (Araucaria columnaris) on Maile Street, will provide a visual buffer from both the Māmalahoa Highway and Maile Street. As outlined in Section 3.19.2 of the Draft EAthe Proposed Action is not expected to adversely affect the views or viewsheds identified in the County General Plan. The wastewater collection system would be installed below the streets and therefore would not impact views. Above-grade structures may include the operations building, headworks and UV cover structures, fuel storage tank, and low berms around the basins. The existing pine trees along Maile Street, most of which would remain with no changes, would continue to obstruct the viewplanes from Maile Street. The facility site would be adjacent (mauka) to, and visible from, Māmalahoa Highway (State Route 11); however, impacts to the viewplane would be mitigated by the planted trees in the basins and by the rise in elevation between the highway and the facility. The property will be fenced and driveway access will be gated to prevent public access along with appropriate signage.
The Draft EA Sections 2.5 and 2.7 provide information as to the issues related to the use of Site 9 including its visibility from the highway. Potentially, to maximize energy efficiency by taking advantage of gravity flow, the headworks, lagoons and the subsurface constructed wetlands could be sited in the upper portion of the site, or the area closest to the highway, without the benefit of viewplane mitigation by the planted trees in the basins and by the rise in elevation between the highway and the facility.”
10349-01Letter to Ms. Gwendolyn Sorensen Page 2March 6, 2020
1. b.The Draft EA Section 3.9.1 (a) states:
“The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM), Community Panel No. 155166 1800F, effective date September 29, 2017 shows 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.
On April 16, 2018, in response to the pre-assessment notification, the State of Hawai‘i Department of Land and Natural Resources Engineering Division stated the responsibility for conducting research as to the flood hazard designation for the project site lies with the project proponent. Also on April 16, 2018 and in response to the pre-assessment notification, the County of Hawai‘i Department of Public Works confirmed that the proposed treatment and disposal project site at Site 7 is designated as Zone X on the FIRM and is outside the 500-year floodplain.”
The relevant FIRM panel is reproduced in Appendix B as Figure 4-13.
This information will be repeated in the Final EA.
The Draft EA Section 3.23.2 (a) states:
“The proposed wastewater treatment and disposal facility would include an on-site drainage system to address stormwater surface runoff created by new impervious surfaces within the facility. The site would include a system to collect runoff via grated inlets or swales, and flows would be conveyed to on-site drainage detention systems, such as subsurface linear infiltration or depressed detention basins.”
This information will be repeated in the Final EA.
The preferred alternative (Site 7) slopes from approximately north to south (mauka to makai) such that, during rain events, surface flows pass through the existing orchard to the southern (makai) end where the flows eventually drain through the culvert located at the Maile Street-Māmalahoa Highway intersection to the areas below (makai) the highway. Most of the land surface area below the existing macadamia nut orchard contains little to no vegetation to absorb
10349-01Letter to Ms. Gwendolyn Sorensen Page 3March 6, 2020
or slow these flows. The gradient of Site 7 and surrounding area results in this natural pattern of surface flows which also existed when the area was planted in sugar cane and is not considered flooding.
Based on the roadway flooding concerns expressed by the community during the Pahala public meetings held in December 2017 and October 2018, the State of Hawai‘i Department of Transportation (DOT) Hawai‘i District office was contacted to discuss drainage at the treatmentand disposal facility project site and the culvert at the Maile Street and Māmalahoa Highway intersection. On a telephone call on February 20, 2019, the District office indicated the DOT owns and maintains the culvert at the Maile Street intersection, and that they have no record of the roadway being inundated by stormwater drainage during precipitation events at that location.
Stormwater runoff generated mauka of the treatment and disposal facility project site will be directed around the perimeter of the site via diversion swales that will convey flow back to the existing drainage pattern that flows to the existing culvert at Maile Street. During heavy rain events, stormwater may temporarily back up behind the culvert. There will be no changes to thisculvert and the proposed treatment and disposal facility will not be located within the area of the culvert.
As stated in the Draft EA, the on-site stormwater management system would meet the requirements of Hawai‘i County Code (HCC), Chapter 27 Floodplain Management, Section 20, Standards for subdivisions and other developments (e) which mandates a site drainage plan to “comply with sections 27-20(a) and (b) and section 27-24, and shall include a storm water disposal system to contain run-off caused by the proposed development, within the site boundaries, up to the expected [design] storm event, as shown in the department of public works “Storm Drainage Standards”.”
To meet the requirements of HCC, Chapter 27, Section 20 (f), the project “shall not alter the general drainage pattern above or below the development”. Thus, for the HCC design storm event, no increase in flow amount will be directed to either of the culverts at the highway as a result of the site development. A drainage report will be prepared during the design process to evaluate the improvements necessary to comply with HCC Chapter 27 requirements.
The wastewater treatment processes will be designed to accommodate the associated peak flows, including precipitation that falls on the area occupied by the aerated lagoon treatment system. The Draft EA Appendix B, Section 2.2 outlines the anticipated peak wastewater flows from the community, based on the applicable flow standard. The Draft EA Section 2.3.1, states the aerated lagoons will be lined to prevent water seepage through the bottom and sides of the lagoons. The Draft EA Appendix B, Section 5.3 shows the operational freeboard that will be available to contain and to equalize lagoon flows. In addition, the slow-rate land application groves will be designed to completely contain both peak effluent flows and precipitation from a 100-year, 24-hour storm event. A geotechnical engineering assessment of berm stability will be
10349-01Letter to Ms. Gwendolyn Sorensen Page 4March 6, 2020
conducted during the design process for any berms intended to act as secondary containment. The tree groves will be designed in accordance with the EPA’s “Process Design Manual, Land Treatment of Municipal Wastewater Effluents”. Effluent will be applied at a hydraulic loading rate that is a small percentage of the percolation rate of the soil, ensuring sufficient capacity for assimilation of peak effluent flow rates and precipitation from the design storm event.
2.The Draft EA Section 2.3.1 provides a detailed description of the proposed treatment and disposal system, descriptions of the various facilities and their functions, a schematic drawing of the various processes, the proposed site plan, and a description of the various areas which have the potential to be disturbed during construction. Further, Section 2.3.2 describes the wastewater collection system, including the streets where the system would be routed and the two phases for construction. Lastly, Section 2.3.3 describes closure of the two large capacity cesspools, as required by the US Environmental Protection Agency, and abandonment of the existing collection system.
The County’s intent, as stated in the June 22, 2017 US Environmental Protection Agency Region 9 Administrative Order on Consent is to provide an industry-standard wastewater collection system and a secondary treatment and disposal facility, a basic service to the Pāhala community, to eliminate underground injection from LCCs it operates to help protect underground drinking water sources. Closure of individual cesspools is mandated by legislation at the State level. In 2017, Act 125 was enacted by the Hawaiʻi State legislature requiring all cesspools, not exempted by the Department of Health, be upgraded or converted to septic systems, or aerobic treatment unit systems, or connected to sewage systems by January 1, 2050. Though closure of individual wastewater systems by the County is not part of the Proposed Action, this legislation will affect all parcels in Pāhala currently utilizing cesspools for sewage disposal.
3.The financial impact of the project on individual newly accessible property owners was raised by the community during the December 2017 public meetings as summarized in Section 7 of the Draft EA and again during the October 2018 meetings. Although not required by HawaiʻiAdministrative Rules (HAR) Title 11, Chapter 200, DEM 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 for the newly accessible residents of the Pāhala Community to pursue.
Programs discussed and included:
x US Department of Housing and Urban Development (HUD) with County of HawaiʻiOffice of Housing and Community Development Residential Repair Program -Community Block Grant Program, and
x US Department of Agriculture - Rural Development (USDA-RDA) Program.
10349-01Letter to Ms. Gwendolyn Sorensen Page 5March 6, 2020
As noted during the 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 Hawaiʻi Revised Statutes (HRS) Chapter §342D to establish a low interest loan program to offer financial assistance to cesspool owners to connect to wastewater treatment systems approved by the Department of Health was also discussed; however, this bill was subsequently not passed during the 2019 legislative session.
This information will be included in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (62)March 6, 2020
Mr. Prodincio FuerteP.O. Box 725 Pāhala, Hawai‘i 96777
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻū, HawaiʻiResponse to Comment - November 18, 2018
Dear Mr. Fuerte:
Thank you for your comment letter received on November 18, 2018 regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
The Draft EA Section 2.7 describes the site selection process, including the factors and their relative weights used to evaluate the various sites. Further, Section 2.7 describes the twenty-one criteria within four general categories (environmental, social and cultural; location and site; land use and availability; and collection system and service area) that were established and defined for the analysis. The Draft EA Appendix B, Section 8, provides additional information regarding the site selection process. As a result of this process, the County identified three sites (Sites 7, 8, and 9) as reasonable alternatives for construction of the wastewater treatment and disposal facility under the Proposed Action. The final scores for Sites 7, 8, and 9 were 4.33, 4.06, and 4.10 respectively, out of a total possible score of 5. Based on this analysis, Site 7 was selected as the Preferred Alternative. The site is easily accessible, has good soils for a land application system, and is close to the existing LCCs.
The Draft EA Section 2.5 describes Site 9 which is south (makai) of the Preferred Alternative Site 7. As outlined in Appendix B Section 8, Site 9 earned a lower ranking than Site 7 for the following criteria: presence of and/or proximity to archaeological/cultural sites, existing vehicle access, power and potable water availability, and distance from the area of the wastewater collection system. Site 7 had a lower ranking than Site 9 in one category: topography. With the distance between the two sites less than 300 feet, they were ranked equally for the criteria of proximity of treatment units to existing occupied buildings.
The Draft EA Sections 2.5 and 2.7 provide information as to the issues related to the use of Site 9. An unnamed stream near the upper portion of the parcel could affect the selectedconfiguration of the wastewater treatment facility and the land application groves. Potentially, to maximize energy efficiency by taking advantage of gravity flow, the headworks, lagoons and the
10349-01Letter to Mr. ProdincioFuerte Page 2 March 6, 2020
subsurface constructed wetlands could be sited in the upper portion of the site, or the area closest to the highway. In addition, since the site is located across Māmalahoa Highway from the Pāhala community, it would require construction of piping and other utilities within the highway ROW, and approval by the State of Hawaiʻi Department of Transportation. Site 9 would require additional access roads to facilitate both construction and operation of the treatment and disposal facility and a slightly longer transmission line given its increased distance from the existing LCCs.
This information will be included in the Final EA
The Draft EA Section 2.2 describes the purpose of the Pāhala Large Capacity Cesspool Replacement project is to close the Pāhala LCCs. The Draft EA Section 2.3.2 discusses the construction of a new sewer collection system in the Pāhala community to replace the existing system of substandard gravity lines that currently conveys sewage to the two LCCs. As described in Section 6.2.1, the current collection system includes facilities located in the backyards of many parcels. Where easements for the existing collection system aren’t accessible, the County must obtain permission from individual landowners to enter them, through private property, to inspect, maintain, repair or replace existing sewer facilities: all activities essential to an efficient,functioning system. The Draft EA Section 2.3.2 states the new collection system would be subject to the County of Hawaiʻi Code (HCC) Chapter 21, Sewers, specifically, Article 2 (Public Sewers), Section 21-5, which 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.
Each adjacent lot will be provided with a lateral connection to the sewer main as required by HCC and standards. Under the Preferred Alternative, the design of the new collection system would extend between street intersections and include sewer service stub-outs (the lateral connection to the sewer main) to the lot lines of adjacent properties, including the newly accessible, to accommodate their eventual connection. Accordingly, to close the existing LCCs, there will be additional properties in Pāhala that would be required to connect to the new wastewater collection system, at their expense, after it becomes operational. Such properties are near the existing service area but are presently connected to individual wastewater systems. To conform to the stated section of HCC, the respective, newly accessible property owners would be responsible for the design, permitting and completion of sewer service connections between the County stub-outs and improvements for stated uses on their property, as well as for the proper closure of their individual wastewater systems. The Draft EA Figure 2.6 shows the area of the community serviced by the current and proposed collection systems.
10349-01Letter to Mr. Prodincio Fuerte Page 3March 6, 2020
All accessible properties will be required to connect to the new wastewater collection system in accordance with Hawaii County Code, Chapter 21, Article 2, Section 21-5. However, the County entered into an agreement with C. Brewer (in April 2007) to eliminate LCCs from the existing community sewer systems and connect properties discharging to them to new County collection, treatment and disposal systems. Once the actual costs are determined, County Council action is still required to approve the expenditures.
This information will be included in the Final EA.
The County’s intent, as stated in the June 22, 2017 US Environmental Protection Agency Region 9 Administrative Order on Consent, is to provide an industry-standard wastewater collection system and a secondary treatment and disposal facility, a basic service to the Pāhala community, to eliminate underground injection from LCCs it operates to help protect underground drinking water sources.
The Draft EA Section 2 provides the scope of the Proposed Action. The Draft EA Section 2.3.1 provides a detailed description of the proposed treatment and disposal system, descriptions of the various facilities and their functions, a schematic drawing of the various processes, the proposed site plan, and a description of the various areas which have the potential to be disturbed during construction. Further, Section 2.3.2 describes the wastewater collection system, including the streets where the system would be routed and the two phases for construction. Lastly, Section 2.3.3 describes closure of the two large capacity cesspools, as required by the US Environmental Protection Agency, and abandonment of the existing collection system. Figure 2.6 shows the extent of the proposed collection system and preferred wastewater treatment and disposal facility location within the community.
Although not a comment specific to the content of the Draft EA, information regarding project schedules, including US Environmental Protection Agency (USEPA) compliance dates, project updates and milestones can be found on the USEPA website: https://www.epa.gov/uic/county-hawaii-administrative-order-consent-closure-cesspools-pahala-and-naalehu
Closure of individual cesspools is mandated by legislation at the State level. In 2017, Act 125 was enacted by the Hawaiʻi State legislature requiring all cesspools, not exempted by the Department of Health, be upgraded or converted to septic systems, or aerobic treatment unit systems, or connected to sewage systems by January 1, 2050. Though closure of individual wastewater systems by the County is not part of the Proposed Action, this legislation will affect all parcels in Pāhala currently utilizing cesspools for sewage disposal.
The Draft EA Section 6.2.2 discusses the Ka‘ū Community Development Plan (CDP): “Section 5 of the CDP prioritizes improvements in infrastructure, facilities, and services, including Section 5.8 applicable to … Environmental management facilities, including expanded sewer lines, …”. Policy 120 is to “Extend the primary wastewater collection lines in Pāhala and
10349-01Letter to Mr. Prodincio Fuerte Page 4March 6, 2020
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 accommodating the Pāhala community. Similarly, the treatment and disposal facility has been designed not to preclude accommodating wastewater flows from the collection system from the Pāhala community.
Further, the Draft EA, Appendix B, Section 5.6 provides information related improvements needed to wastewater services to the Pāhala community as envisioned in the CDP. Appendix B, Section 5.6.2 states:
“To accommodate the flow increase anticipated from the full buildout of the Pāhala wastewater collection system, the WWTP will require facility upgrades. Therecommended upgrades include headworks and odor control expansion within the14.9-acre site. Additionally, the lagoon system will require modifications. Lagoon 1 will beconverted to a complete mix aerated lagoon environment to accommodate wastewatertreatment needs. In a complete mix aerated lagoon, sufficient mixing energy is providedto maintain the lagoon solids in suspension always. A completely mixed aerated lagoon system performs as an activated sludge process without solid recycle. The higher mixingenergy, as compared to a partial mix lagoon,creates greater opportunity for contactbetween the naturally-occurring micro-organisms in the lagoon and dissolved organicmatter. As a result, complete mix lagoons provide greater levels of treatment within a smaller volume than partial mix lagoons. However, facilities must be provideddownstream of complete mixed lagoons to allow removal of settleable solids from thewater column. To provide a place for solid settling, lagoons 2 through 4 will continue toact as partial mix aerated lagoons downstream of the complete mix lagoon 1. Lagoon 4will require no aeration and will continue to be covered to deprive algae of sunlight andallow suspended solids to settle out of the system effluent. Utilizing this lagoon systemapproach, thePāhala WWTP will require modification at full buildout flow, but is notanticipated to expand beyond the initial build 14.9-acre site.”
This information will be repeated in the Final EA.
The Draft EA Section 2.3 states that under the Preferred Alternative, the County of Hawaiʻi would acquire, or otherwise obtain the right to develop and use, a portion of the 42.5-acre Site 7 then construct a new secondary wastewater treatment and disposal facility within a portion of the parcel (see Figure 2.3). Further, as stated in Section 2.3.1:
“The County would work with the current landowner to subdivide the 42.5-acre parcel into two parcels: 1) a 14.9-acre parcel that would be owned by the County; and 2) a 27.6-acre parcel that would include a 25-foot-wide by 1,500-foot-long utility easement and
10349-01Letter to Mr. Prodincio Fuerte Page 5March 6, 2020
would continue to be owned by the current owner. See Figure 2.3 for a preliminary site plan showing the proposed location of the treatment and disposal facility within the southeast portion of Site 7.”
The Final EA will note, the County is working with the current landowner, BP Bishop Estate Trustees (Kamehameha Schools), to subdivide the 42.5-acre parcel (Tax Map Key (TMK): 9-6-002:018) to acquire the property.
The Draft EA Section 2.10.2 states:
“Construction of the portions of the collection system located within County ROWs would not require further land transfer approvals. As previously discussed, two short segments of the planned collection system would be located with privately owned parcels. The County would obtain easements from the land owner(s) as part of the construction process. The Hawaiʻi County Code Chapter 23, Subdivisions, states that all subdivision plats and all streets or ways within the County created for the purpose of partitioning land shall be approved by the County Planning Department Director.”
Future sewer main extensions and subdivisions will be accommodated, as capacity allows, on a first come, first served basis.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (59)March 6, 2020
Mr. Larry Navarro ldnava1@gmail.com
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻū, HawaiʻiResponse to Comment - November 19, 2018 11:27 a.m.
Dear Mr. Navarro:
Thank you for your November 19, 2018 11:27 a.m.comment message regarding the County of Hawaiʻi Department of Environmental Management (DEM) Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our response follows:
The Draft EA Section 2.3.2 states the new collection system would be subject to the County of Hawaiʻi Code (HCC) Chapter 21, Sewers, specifically, Article 2 (Public Sewers), Section 21-5,which 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.”
Further:
“(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.”
The financial impact of the project on individual newly accessible property owners was raised by the community during the December 2017 public meetings as summarized in Section 7 of the Draft EA. Although not required by Hawaii Administrative Rules (HAR) Title 11, Chapter 200, DEM voluntarily convened two additional public meetings on October 9, 2018 and March 21,
10349-01Letter to Mr. Larry Navarro Page 2March 6, 2020
2019 to gain further input from newly accessible property owners and present funding options for them to pursue.
The Draft EA Section 7 will be revised to add that the County held additional meetings in Pāhala including one to provide information on financing sources available to owners of parcels which would become accessible to the County collection system. The purpose of the March 21, 2019 meeting was to fulfill a County commitment made in October, 2018 to research financing options available to the newly accessible residents of the Pahala Community. At the meeting, DEM provided the preliminary results of the County investigation into funding sources and options available for newly accessible property owners once the new treatment and disposal facility and the wastewater collection system have been designed, permitted and constructed.
Programs discussed included:
x US Department of Housing and Urban Development (HUD) with County of Hawaii Office of Housing and Community Development Residential Repair Program -Community Block Grant Program, and
x US Department of Agriculture - Rural Development (USDA-RDA) Program.
As noted during the presentation, these programs may change in the coming years, and additional options may be added to this preliminary list. Hawaii Legislature, Senate Bill 221 SD1, which could amend Hawaii Revised Statutes (HRS) Chapter §342D to establish a low interest loan program to offer financial assistance to cesspool owners to connect to wastewater treatment systems approved by the Department of Health was also discussed; however, this bill was subsequently not passed during the 2019 legislative session.
This information will be included in the Final EA.
Some ways to stay informed about the project include:
x The County will submit the Final EA to the State of Hawaii Department of Health Office of Environmental Quality Control (OEQC), which facilitates Hawaii’s environmental review process and announces the availability of EAs for public review and comment in
The Environmental Notice (TEN). Issues of TEN can be found on the OEQC website at:http://health.hawaii.gov/oeqc/.
x The Draft EA and other project information can be found on the County of Hawaii website at: http://www.hawaiicounty.gov/dem-wastewater-division.x Information regarding project schedules, including US Environmental Protection Agency (USEPA) compliance dates, project updates and milestones can be found on the USEPA website at: https://www.epa.gov/uic/county-hawaii-administrative-order-consent-closure-cesspools-pahala-and-naalehu.
10349-01Letter to Mr. Larry Navarro Page 3March 6, 2020
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (60)March 6, 2020
Ms. Lisa Gollin, PhDlxgollin@hawaii.edu
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻū, HawaiʻiResponse to Comment - November 19, 2018; 11:46 a.m.
Dear Dr. Gollin:
Thank you for your November 19, 2018 11:46 a.m. comment message regarding the County of Hawaiʻi Department of Environmental Management (DEM) Draft Environmental Assessment(EA) for thePāhala Large Capacity Cesspool Replacement project. Our response follows:
The Draft EA Preface states: The DEM has determined that the requirements of Hawaii Revised Statutes, Chapter 343, can be fulfilled by preparing an EA with FONSI. A Final Environmental Assessment (EA) will be issued for this project. As such, a cultural impact assessment will not be included.
The Draft EA Summary states: No significant environmental impacts are anticipated from construction and use of the collection system and the wastewater treatment and disposal facility.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (61)March 6, 2020
Ms. Tanya Ibarara tibarara2000@gmail.com
Subject: Draft Environmental Assessment for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻū, HawaiʻiResponse to Comment - December 3, 2018; 8:19: a.m.
Dear Ms. Ibarra:
Thank you for your December 3, 2018 8:19 a.m. comment message regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
COMMUNITY INPUT ON THE PROJECT
On April 25, 2010, a community meeting sponsored by Councilman Guy Enriques was held at the Pāhala Community Center to discuss the Nā‘ālehu and Pāhala Large Capacity Cesspool Replacement project. As part of the meeting,an informational handout prepared by the County’s Wastewater Division provided a brief history of the project documenting that, in 2004, Mayor Kim’s office used a ballot system to get input from property owners regarding different wastewater treatment/disposal alternatives for those property owners connected to the LCCs who would no longer be served by the C. Brewer system after LCC closure. As reported in the Draft EA Section 2.1.4, 87 percent of the returned ballots were in favor of the installation of a new sewer collection system and a treatment and disposal system to be operated and maintained by the County. The handout indicated that Mayor Kim’s office advised the property owners the County would move forward with new systems for Nā‘ālehu and Pāhala on November 5, 2004.Additionally, the handout stated public meetings were held in both Nā‘ālehu and Pāhala inNovember 2006 to discuss the wastewater system alternatives. The handout included that adequate land for the treatment and disposal system had not been identified in Pāhala. The handout also stated that all properties accessible to the new sewer system would be required to connect in accordance with Hawaii County Code Chapter 21.
The Draft EA Section 2.9 discusses the relationship between the current project and the 2007 Final EA for the Naalehu-Pāhala Large Capacity Cesspool (LCC) Conversion project. As stated in Section 2.9:
“After the issuance of the Final EA and Negative Declaration/FONSI in 2007, the County conducted additional study and evaluation of the proposed LCC conversion project. The
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County eventually concluded that the LCC conversion project described in the 2007 Final EA would not meet the need to provide a collection system and a treatment and disposal facility, close the LCCs, and provide for the future needs of the Pāhala community. This determination was based on several factors…”
REASON FOR THE PROJECT
The Draft EA Section 2.2 describes the purpose of the Pāhala Large Capacity Cesspool Replacement project is to close the Pāhala LCCs. The Draft EA Section 2.3.2 discusses the construction of a new sewer collection system in the Pāhala community to replace the existing system of substandard gravity lines that currently conveys sewage to the two LCCs. As described in Section 6.2.1, the current collection system includes facilities located in the backyards of many parcels. Where easements for the existing collection system aren’t accessible, the County must obtain permission from individual landowners to enter them, through private property, to inspect, maintain, repair or replace existing sewer facilities: all activities essential to an efficient, functioning system. The Draft EA Section 2.3.2 states the new collection system would be subject to Hawaiʻi County Code (HCC) Chapter 21, Sewers. Specifically, Article 2 (Public Sewers), Section 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.”
Each adjacent lot will be provided with a lateral connection to the sewer main as required by HCC and standards. Under the Preferred Alternative, the design of the new collection system would extend between street intersections and include sewer service stub-outs (the lateral connection to the sewer main) to the lot lines of adjacent properties, including the newly accessible, to accommodate their eventual connection. Accordingly, to close the existing LCCs, there will be additional properties in Pāhala that would be required to connect to the new wastewater collection system, at their expense, after it becomes operational. Such properties are near the existing service area but are presently connected to individual wastewater systems. To conform to the stated section of HCC, the respective, newly accessible property owners would be responsible for the design, permitting and completion of sewer service connections between the County stub-outs and improvements for stated uses on their property, as well as for the proper closure of their individual wastewater systems. The Draft EA Figure 2.6 shows the area of the community serviced by the current and proposed collection systems.
The financial impact of the project on individual newly accessible property owners was raised by the community during the December 2017 public meetings as summarized in Section 7 of the Draft EA. Although not required by Hawaii Administrative Rules (HAR) Title 11, Chapter 200, DEM voluntarily convened two additional public meetings on October 9, 2018 and March 21,
10349-01Letter to Ms. Tanya IbararaPage 3March 6, 2020
2019 to gain further input from newly accessible property owners and present funding options for them to pursue.
The Draft EA Figure 2.2 shows the collection system on the various streets within the community. The Draft EA Section 2.2 states the Pāhala Large Capacity Cesspool Replacement project is to provide infrastructure necessary to enable the County to comply with the Safe Drinking Water Act and Administrative Order on Consent between the County and the Environmental Protection Agency with respect to closure of the Pāhala large capacity cesspools.
The extent of the collection system is to ensure the parcels connected to the former C. Brewer system will have access to the treatment and disposal facility, so the large capacity cesspools can be closed.
The Draft EA Section 6.2.2 discusses the Ka‘ū Community Development Plan (CDP): “Section 5 of the CDP prioritizes improvements in infrastructure, facilities, and services, including Section 5.8 which is applicable to … Environmental management facilities, including expanded sewer lines, …”. Policy 120 is to “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 accommodating the Pāhala community. Similarly, the treatment and disposal facility has been designed not to preclude accommodating the wastewater flows from the collection system from the Pāhala community.
It is conventional to extend a utility between street intersections to minimize the number of manholes required. As stated in the Draft EA, the collection system is routed within the County right-of-way for ease of access for construction and maintenance.
WATER LINE/SEWER LINE PLACEMENT
On April 5, 2018, the County of Hawaiʻi Department of Water Supply (DWS) provided the following (See the Draft EA Appendix A):
“The Department requests that the construction plans show, and the proposed sewer lines be installed with, the proper horizontal and vertical clearances from our existing water system facilities and concrete jacketing at waterline crossings, where necessary, as recommended by the Department's Water System Standards.
In addition, backflow prevention devices must be installed where there are connections to our water system at wastewater processing and treatment facilities”.
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The detailed design will be informed by and the construction documents will reference the DWS Water System Standards.
The above information will be included in Section 2.3.2 of the final EA.
ERRORS IN THE PROPOSAL
Neither the geographical size nor population of Pahala affect the Purpose and Need for Action as outlined in the Draft EA Section 2.2 The purpose is to close the County-operated LCCs Section 2.1.1 will be revised to state: “The Ka‘ū district includes several communities, including the town of Pāhala. Pāhala had a population of approximately 1,341 persons in 2016.”
PLACEMENT OF THE FIRST PHASE OF THE SEWER PROJECT
Please refer to the above response under heading REASON FOR THE PROJECT.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (68)March 6, 2020
Ms Dorothy KaluaP.O. Box 626PāhalaHawai‘i 96777
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻū, HawaiʻiResponse to Comment - December 4, 2018
Dear Ms. Kalua:
Thank you for your December 4, 2018 comment letter regarding the regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool (LCC) Replacement project. Our responses follow
The Draft EA Section 2.7 describes the site selection process, including the factors and their relative weights used to evaluate the various sites. Further, Section 2.7 describes the twenty-one criteria within four general categories (environmental, social and cultural; location and site; land use and availability; and collection system and service area) that were established and defined for the analysis. The Draft EA Appendix B, Section 8, provides additional information regarding the site selection process. As a result of this process, the County identified three sites (Sites 7, 8, and 9) as reasonable alternatives for construction of the wastewater treatment and disposal facility under the Proposed Action. The final scores for Sites 7, 8, and 9 were 4.33, 4.06, and 4.10 respectively, out of a total possible score of 5. Based on this analysis, Site 7 was selected as the Preferred Alternative. The site is easily accessible, has good soils for a land application system, and is close to the existing LCCs. .
The Draft EA Section 2.5 describes Site 9, which is south (makai) of the Preferred Alternative Site 7. As outlined in Appendix B Section 8, Site 9 earned a lower ranking than Site 7 for the following criteria: presence of and/or proximity to archaeological/cultural sites, existing vehicle access, power and potable water availability, and distance from the area of the wastewater collection system. Site 7 had a lower ranking than Site 9 in one category: topography. With the distance between the two sites less than 300 feet, they were ranked equally for the criteria of proximity of treatment units to existing occupied buildings.
The Draft EA Sections 2.5 and 2.7 provide information as to the issues related to the use of Site 9. An unnamed stream near the upper portion of the parcel could affect the selected configuration of the wastewater treatment facility and the land application groves. Potentially, to maximize energy efficiency by taking advantage of gravity flow, the headworks, lagoons and the
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subsurface constructed wetlands could be sited in the upper portion of the site, or the area closest to the highway. In addition, since the site is located across Māmalahoa Highway from the Pāhala community, it would require construction of piping and other utilities within the highway ROW and approval by the State of Hawaiʻi Department of Transportation. Site 9 would require additional access roads to facilitate both construction and operation of the treatment and disposal facility and a slightly longer transmission line given its increased distance from the existing LCCs.
This information will be included in the Final EA.
The County is aware of two existing culverts that allow stormwater to flow across the Māmalahoa Highway in the vicinity of the project.
The Draft EA Section 3.9.1 (a) states:
“The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM), Community Panel No. 155166 1800F, effective date September 29, 2017 shows 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.
On April 16, 2018, in response to the pre-assessment notification, the State of Hawai‘i Department of Land and Natural Resources Engineering Division stated the responsibility for conducting research as to the flood hazard designation for the project site lies with the project proponent. Also on April 16, 2018 and in response to the pre-assessment notification, the County of Hawai‘i Department of Public Works confirmed that the proposed treatment and disposal Site 7 is designated as Zone X on the FIRM and is outside the 500-year floodplain.”
The relevant FIRM panel is reproduced in Appendix B as Figure 4-13.
This information will be repeated in the Final EA.
The Draft EA Section 3.23.2 (a) states:
“The proposed wastewater treatment and disposal facility would include an on-site drainage system to address stormwater surface runoff created by new impervious surfaces within the facility. The site would include a system to collect runoff via grated inlets or swales, and flows would be conveyed to on-site drainage detention systems, such as subsurface linear infiltration or depressed detention basins.”
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This information will be repeated in the Final EA.
The preferred alternative (Site 7) slopes from approximately north to south (mauka to makai) such that, during rain events, surface flows drain through the existing orchard to the southern (makai) end where the flows eventually drain through the culvert located at the Maile Street-Māmalahoa Highway intersection to the areas below (makai) the highway. Most of the land surface area below the existing macadamia nut orchard contains little to no vegetation to absorb or slow these flows. The gradient of Site 7 and surrounding area results in this natural pattern of surface flows which also existed when the area was planted in sugar cane and is not considered flooding.
Based on the roadway flooding concerns expressed by the community during the Pahala public meetings held in December 2017 and October 2018, the State of Hawai‘i Department of Transportation (DOT) Hawai‘i District office was contacted to discuss drainage at the treatment and disposal facility project site and the culvert at the Maile Street and Māmalahoa Highway intersection. On February 20, 2019, the District office confirmed via telephone that the DOT owns and maintains the culvert at the Maile Street intersection, and that they have no record of the roadway being inundated by stormwater drainage during precipitation events at that location.
Stormwater runoff generated mauka of the treatment and disposal facility project site will be directed around the perimeter of the site via diversion swales that will convey flow back to the existing drainage pattern that flows to the existing culvert at Maile Street. During heavy rain events, stormwater may temporarily back up behind the culvert. There will be no changes to this culvert and the proposed treatment and disposal facilities will not be located within the area of the culvert.
As stated in the Draft EA, the on-site stormwater management system would meet the requirements of Hawai‘i County Code (HCC), Chapter 27 Floodplain Management, Section 20, Standards for subdivisions and other developments (e) which mandates a site drainage plan to “comply with sections 27-20(a) and (b) and section 27-24, and shall include a storm water disposal system to contain run-off caused by the proposed development, within the siteboundaries, up to the expected [design] storm event as shown in the Department of Public Works “Storm Drainage Standards”.
To meet the requirements of HCC, Chapter 27, Section 20 (f), the project site “shall not alter the general drainage pattern above or below the development”. Thus, for the HCC design storm event, no increase in flow amount will be directed to either of the culverts at the highway as a result of the site development. A drainage report will be prepared during the design process to evaluate the improvements necessary to comply with HCC Chapter 27 requirements.
The wastewater treatment processes will be designed to accommodate the associated peak flows, including precipitation that falls on the area occupied by the aerated lagoon treatment system.
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The Draft EA Appendix B, Section 2.2 outlines the anticipated peak wastewater flows from the community, based on the applicable flow standard. The Draft EA Section 2.3.1 states the aerated lagoons will be equipped with high-density polyethylene liners to prevent water seepage through the bottom and sides of the lagoons. The Draft EA Appendix B, Section 5.3 shows the operational freeboard that will be available to contain and to equalize lagoon flows. In addition, the slow-rate land application groves will be designed to completely contain both peak effluent flows and precipitation from a 100-year, 24-hour storm event. A geotechnical engineering assessment of berm stability will be conducted during the design process. The tree groves will be designed in accordance with the EPA’s “Process Design Manual, Land Treatment of Municipal Wastewater Effluents”. Effluent will be applied at a hydraulic loading rate that is a small percentage of the percolation rate of the soil, ensuring sufficient capacity for assimilation of peak effluent flow rates and precipitation from the design storm event.
This information will be included in the Final EA.
The former Hilo Wastewater Treatment Plant (WWTP) at Keaukaha is not currently in use as a County WWTP, nor was it similar to the wastewater treatment and disposal facilities proposed for this project. Facilities at TMK 2-1-011:004 are currently owned by the State of Hawaiʻi,University of Hawaiʻi, as the Pacific Aquaculture Coastal Resource Center.
The Draft EA Section 3.14.2 states:
“Wastewater treatment plants can be a source of nuisance odors to the surrounding community if not properly designed or operated. Typically, nuisance odors are most commonly associated with anaerobic (without oxygen) conditions and with processing of residual solids. Incoming raw sewage flows to the proposed wastewater treatment and disposal facility would first be routed to the headworks, which is the facility where the solids are removed from the flows.
To mitigate potential nuisance odors, the headworks would be equipped with an odor control system with a GAC scrubber to remove odor. A package GAC scrubber passes the odorous air through a bed of activated carbon, which adsorbs the odorous constituents within the pore spaces of the carbon. The County currently operates GAC scrubbers at other facilities, and it has been proven to be an effective means of odor control both locally and nationwide. The treatment lagoons would be equipped with mechanical aerators capable of maintaining sufficiently aerobic (with oxygen) conditions within the water column, which would prevent nuisance odor conditions from occurring. The disposal groves would be irrigated with fully-treated and aerobic secondary effluent from the treatment process; irrigation with secondary effluent is not associated with development of nuisance odor conditions.”
This information will be repeated in the Final EA Section 3.14.2.
10349-01Letter to Ms Dorothy KaluaPage 5March 6, 2020
The Draft EA Section 3.15 references a November 2016 archaeological field inspection report that states, while the 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 parcel (which includes Site 7), as well as evidence from plantation-era documents that the opening of a lava tube containing human remains once existed in the southeastern corner of the parcel, indicate that further archaeological studies may be necessary. The Final EA will clarify that the report also stated it would be advisable to limit the development footprint to exclude the southeastern corner of the 42.5-acre parcel. This area, which is presently not used as a macadamia nut orchard, but forms part of the macadamia nut processing plant complex, is the location of a known (but sealed) lava tube opening that local informants have indicated is linked to tubes that possess traditional human burials. Further, by excluding this section of the parcel, it will be possible to avoid at least one known historic property. The Draft EA Figure 2.3 provides the Preliminary Site Plan for the new treatment and disposal facility, which shows the 14.9-acre project site has been developed to exclude the area in the southeastern corner identified as the location of the sealed lava tube opening.
The complete document is available for download from the County’s website at: http://records.co.hawaii.hi.us/weblink/1/edoc/100962/Draft%20Archeological%20Inventory%20Survey%20-%20Pahala%20WWTP%20and%20Sewer%20System.pdf
Between September 18, 2018 and January 10, 2019, a team of qualified archaeologists conducted a pedestrian survey of the proposed project site and completed subsurface trenching to determine the presence of archaeological resources. The work was undertaken in accordance with the State of Hawaii Department of Land and Natural Resources State Historic Preservation Division (SHPD) requirements, with the archaeological inventory survey (AIS) approach accepted by SHPD in their August 20, 2018 letter. The results of the survey and subsurface trenching showed no burials or lava tube openings were present. The AIS completed in March 2019 documents that a sealed lava tube is located east of the proposed wastewater treatment and disposal facility project site, outside the proposed property boundary, and outside of the area of potential effect considered in consultation with the SHPD.
A geophysical survey of the proposed project area will be performed during detailed design with the specific intent to locate subsurface voids (such as lava tubes) present beneath the site that may impact design and construction of the new wastewater treatment, disposal and collection systems.
This information will be included in the final EA.
10349-01Letter to Ms Dorothy KaluaPage 6March 6, 2020
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (67; 69;70)March 6, 2020
Ms. Terri L. Napeahi, Secretary Pele Defense FundP.O. Box 4969Hilo, Hawai‘i 96720
Subject: Draft Environmental Assessment for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻū, HawaiʻiResponse to Comment- December 10, 2018
Dear Ms. Napeahi:
Thank you for your hand delivered December 10, 2018 comment letter regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. This responds to duplicate letters to Mayor Kim and the Department of Environmental Management.
Our responses follow:
The Draft EA Section 2.7 describes the site selection process, including the factors and their relative weights used to evaluate the various sites. Further, Section 2.7 describes the twenty-one criteria within four general categories (environmental, social and cultural; location and site; land use and availability; and collection system and service area) that were established and defined for the analysis. The Draft EA Appendix B, Section 8, provides additional information regarding the site selection process. As a result of this process, the County identified three sites (Sites 7, 8, and 9) as reasonable alternatives for construction of the wastewater treatment and disposal facility under the Proposed Action. The final scores for Sites 7, 8, and 9 were 4.33, 4.06, and 4.10 respectively, out of a total possible score of 5. Based on this analysis, Site 7 was selected as the Preferred Alternative. The site is easily accessible, has good soils for a land application system, and is close to the existing LCCs.
The Draft EA Section 2.5 describes Site 9, which is south (makai) of the Preferred Alternative Site 7. As outlined in Appendix B Section 8, Site 9 earned a lower ranking than Site 7 for the following criteria: presence of and/or proximity to archaeological/cultural sites, existing vehicle access, power and potable water availability, and distance from the area of the wastewater collection system. Site 7 had a lower ranking than Site 9 in one category: topography. With the distance between the two sites less than 300 feet, they were ranked equally for the criteria of proximity of treatment units to existing occupied buildings.
10349-01Letter to Ms. Terri L. NapeahiPage 2March 6, 2020
The Draft EA Sections 2.5 and 2.7 provide information as to the issues related to the use of Site 9.An unnamed stream near the upper portion of the parcel could affect the selected configuration of the wastewater treatment facility and the land application groves. Potentially, to maximize energy efficiency by taking advantage of gravity flow, the headworks, lagoons and the subsurface constructed wetlands could be sited in the upper portion of the site, or the area closest to the highway.In addition, since the site is located across Māmalahoa Highway from the Pāhala community, it would require construction of piping and other utilities within the highway ROW and approval by the State of Hawaiʻi Department of Transportation. Site 9 would require additional access roads to facilitate both construction and operation of the treatment and disposal facility and a slightly longer transmission line given its increased distance from the existing LCCs.
This information will be included in the Final EA.
Flooding
1. The Draft EA Section 3.9.1 (a) states:
“The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM),Community Panel No. 155166 1800F, effective date September 29, 2017 shows 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-1is very close to the edge of the 500-year floodplain.
On April 16, 2018, in response to the pre-assessment notification, the State of Hawai‘i Department of Land and Natural Resources Engineering Division stated the responsibility for conducting research as to the flood hazard designation for the project site lies with the project proponent. Also on April 16, 2018 and in response to the pre-assessment notification, the County of Hawai‘i Department of Public Works confirmed that the proposed treatment and disposal project site at Site 7 is designated as Zone X on the FIRM and is outside the 500-year floodplain.”
The relevant FIRM panel is reproduced in Appendix B as figure 4-13.
This information will be repeated in the Final EA.
10349-01Letter to Ms. Terri L. NapeahiPage 3March 6, 2020
The Draft EA Section 3.23.2 (a) states:
“The proposed wastewater treatment and disposal facility would include an on-site drainage system to address stormwater surface runoff created by new impervious surfaces within the facility. The site would include a system to collect runoff via grated inlets or swales, and flows would be conveyed to on-site drainage detention systems, such as subsurface linear infiltration or depressed detention basins.”
This information will be repeated in the Final EA.
The preferred alternative (Site 7) slopes from approximately north to south (mauka to makai) such that, during rain events, surface flows drain through the existing orchard to the southern (makai) end where the flows eventually drain through the culvert located at the Maile Street-Māmalahoa Highway intersection to the areas below (makai) the highway. Most of the surface area below the existing macadamia nut orchard contains little to no vegetation to absorb or slow these flows. The gradient of Site 7 and surrounding area results in this natural pattern of surface flows which also existed when the area was planted in sugar cane and is not considered flooding.
Based on the roadway flooding concerns expressed by the community during the Pāhalapublic meetings held in December 2017 and October 2018, the State of Hawai‘i Department of Transportation (DOT) Hawai‘i District office was contacted to discuss drainage at the treatment and disposal facility project site and the culvert at the Maile Street and Māmalahoa Highway intersection. On February 20, 2019, the District office confirmed via telephone that the DOT owns and maintains the culvert at the Maile Street intersection, and that they have no record of the roadway being inundated by stormwater drainage during precipitation eventsat that location.
Stormwater runoff generated from mauka of the treatment and disposal facility project site will be directed around the perimeter of the site via diversion swales that will convey flow back to the existing drainage pattern that flows to the existing culvert at Maile Street. During heavy rain events, stormwater may temporarily back up behind the culvert. There will be no changes to this culvert and the proposed treatment and disposal facilities will not be located within the area of the culvert.
As stated in the Draft EA, the on-site stormwater management system would meet the requirements of Hawai‘i County Code (HCC) Chapter 27 Floodplain Management Section 20, Standards for subdivisions and other developments (e) which mandates a site drainage plan to “comply with sections 27-20(a) and (b) and section 27-24, and shall include a storm water disposal system to contain run-off caused by the proposed development, within the site boundaries, up to the expected [design] storm event as shown in the department of public works “Storm Drainage Standards”.
10349-01Letter to Ms. Terri L. NapeahiPage 4March 6, 2020
Adherence to HCC Chapter 27 Section 20 (f) will ensure the treatment and disposal facility shall not alter the general drainage pattern above or below the development. Thus, for the HCC design storm event, no increase in flow amount will be directed to either of the culverts at the highway as a result of the site development. A drainage report will be prepared during the design process to evaluate the improvements necessary to comply with HCC Chapter 27 requirements.
The facilities related to the wastewater treatment processes will be designed to accommodate the associated peak flows, including precipitation that falls on the area occupied by the aerated lagoon treatment system. The Draft EA Appendix B, Section 2.2 outlines the anticipated peak wastewater flows from the community, based on the applicable flow standard. The Draft EA Section 2.3.1 states the aerated lagoons will be lined to prevent water seepage through the bottom and sides of the lagoons. The Draft EA Appendix B, Section 5.3 shows the operational freeboard that will be available to contain and to equalize lagoon flows. In addition, the slow-rate land application groves will be designed to completely contain both peak effluent flows and precipitation from a 100-year, 24-hour storm event. A geotechnical engineering assessment of berm stability will be conducted during the design process for any berms intended to act as secondary containment. The tree groves will be designed in accordance with the EPA’s “Process Design Manual, Land Treatment of Municipal Wastewater Effluents”. Effluent will be applied at a hydraulic loading rate that is a small percentage of the percolation rate of the soil, ensuring sufficient capacity for assimilation of peak effluent flow rates and precipitation from the design storm event.
This information will be included in the Final EA.
2. See 1 above. Based on this analysis, the project will not contribute to an increase in road closures due to flooding.
3. See 1 above. As a result, heavy debris generated from the proposed project will be designed to be retained onsite.
4. The Draft EA Section 3.15 references a November 2016 archaeological field inspection report that states, while the 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 parcel (which includes Site 7), as well as evidence from plantation-era documents that the opening of a lava tube containing human remains once existed in the southeastern corner of the parcel, indicate that further archaeological studies may be necessary. The Final EA will clarify that the report also stated it would be advisable to limit the development footprint to exclude the southeastern corner of the 42.5-acre parcel. This area, which is presently not used as a macadamia nut orchard, but forms part of the macadamia nut processing plant complex, is the location of a known (but sealed) lava tube
10349-01 Letter to Ms. Terri L. Napeahi Page 5March 6, 2020
opening that local informants have indicated is linked to tubes that possess traditional human burials. Further, by excluding this section of the parcel, it will be possible to avoid at least one known historic property. The Draft EA Figure 2.3, which provides the Preliminary Site Plan for the new treatment and disposal facility, shows the 14.9-acre project site has been developed to exclude the area in the southeastern corner identified as the location of the sealed lava tube opening.
Between September 18, 2018 and January 10, 2019,a team of qualified archaeologists conducted a pedestrian survey of the proposed project site and completed subsurface trenching to determine the presence of archaeological resources. The work was undertaken in accordance with the State of Hawaii Department of Land and Natural Resources State Historic Preservation Division (SHPD) requirements, with the archaeological inventory survey (AIS) approach accepted by SHPD in their August 20, 2018 letter. The results of the survey and subsurface trenching showed no burials or lava tube openings were identified on-site. The AIS submitted to SHPD in March 2019 documents that a sealed lava tube opening is located east of the proposed wastewater treatment and disposal facility project site, outside the proposed property boundary, and outside of the area of potential effect considered in consultation with SHPD.
The complete document is available for download from the County’s website at:http://records.co.hawaii.hi.us/weblink/1/edoc/100962/Draft%20Archeological%20Inventory%20Survey%20-%20Pahala%20WWTP%20and%20Sewer%20System.pdf
A geophysical survey of the proposed project area will be performed during detailed design with the specific intent to locate subsurface voids (such as lava tubes) present beneath the site that may impact design and construction of the new wastewater treatment, disposal and collection systems.
Based on information in 1 and above, excessive damage to lava tubes and burials will not result from construction of the collection system or construction of the treatment and disposal facility at the proposed project Site 7.
This information will be included in the final EA.
5. The Draft EA Figure 2.3 shows the intersection of Maile Street and Māmalahoa Highway liesat about 580 feet above mean sea level (MSL). The Draft EA Figure 2.2 shows the PāʻauʻauGulch crosses under Māmalahoa Highway near the hospital about 0.88 miles north of thatintersection and lies at approximately 780 feet MSL or about 200 feet higher in elevationthan the culvert at the Maile Street and Māmalahoa Highway intersection. Due to thisdistance and the elevation difference, surface flows at Site 7 would not affect the gulch.Similarly, the Kaimani Street and Māmalahoa Highway intersection lies about 0.84 miles
10349-01Letter to Ms. Terri L. NapeahiPage 6March 6, 2020
north of the proposed facility site and at about 780 feet MSL. Surface flows at the facility would also not affect that intersection. Figures 2.2 and 2.3 will be repeated in the Final EA.
Based on this information and 1 above, development of the treatment and disposal facility is not anticipated to create restrictions related to access to hospital and emergency facilities.
6. See 1 and 5 above. In accordance with Hawaii Fire Department requirements, Fire Department access and water supply to the proposed Site 7 will be designed to comply with Chapter 18 of NFPA 2006 Uniform Fire Code as amended by Hawaii County.
Section 106
1. See 4 above in Flooding section. Geophysical and geotechnical subsurface testing will be completed for the Pāhala Large Capacity Cesspool Replacement Project.
2. See 4 above in Flooding section.
Hook Ups
1. The Draft EA Section 2.1.4 states:
“Around 2006, C. Brewer requested 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 in 2007,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.”
The agreements are not pertinent to the content requirements of the Pāhala Large Capacity Cesspool Replacement Project Draft EA.
2. The Draft EA Section 2.3 states, the County would acquire, or otherwise obtain the right to develop and use, a portion of the 42.5-acre Site 7, then construct a new secondary wastewater treatment and disposal facility within a portion of the parcel. The Final EA will note, the County is working with the current landowner, BP Bishop Estate Trustees (Kamehameha Schools), to subdivide the 42.5-acre parcel (Tax Map Key (TMK): 9-6-002:018) to acquire the property by means of the method they prefer. Sites 7, 8 and 9 would all involve a similar property acquisition process, as all are currently owned by the same entity. Additional property acquisition is not anticipated for the Preferred Action beyond that outlined inSection 2.3.
10349-01Letter to Ms. Terri L. NapeahiPage 7March 6, 2020
3. The County’s intent, as stated in the June 22, 2017 US Environmental Protection Agency Region 9 Administrative Order on Consent is to provide an industry-standard wastewater collection system and a secondary treatment and disposal facility, a basic service to the Pāhala community, to eliminate underground injection from LCCs it operates to help protect underground drinking water sources.
In order to meet the intent as stated in the 2017 AOC, the County has committed to perform the following actions for the Pāhala Large Capacity Cesspool Replacement project:
i. Construct a secondary wastewater treatment facility;ii. Replace the wastewater collection system serving Pāhala Community; andiii. Close the Pāhala community cesspools.
Completion of the above actions includes connecting those properties currently served by the LCCs to the proposed new wastewater collection, treatment and disposal system. Once the actual costs are determined, County Council action is still required to approve the expenditures.
The Draft EA Section 2.2 describes the purpose of the Pāhala Large Capacity Cesspool Replacement project is to close the County-operated Pāhala LCCs. The Draft EA Section 2.3.2 discusses the construction of a new sewer collection system in the Pāhala community to replace the existing system of substandard gravity lines that currently conveys sewage to the two LCCs. As described in Section 6.2.1, the current collection system includes facilities located in the backyards of many parcels. Where easements for the existing collection system aren’t accessible, the County must obtain permission from individual landowners to enter them, through private property, to inspect, maintain, repair or replace existing sewer facilities: all activities essential to an efficient, functioning system. The Draft EA Section 2.3.2 states the new collection system would be subject to the County of Hawaiʻi Code (HCC) Chapter 21, Sewers, specifically, Article 2 (Public Sewers), Section 21-5, whichstates 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.”
Each adjacent lot will be provided with a lateral connection to the sewer main as required by HCC and standards. Under the Preferred Alternative, the design of the new collection system would extend between street intersections and include sewer service stub-outs (the lateral connection to the sewer main) to the lot lines of adjacent properties, including the newlyaccessible, to accommodate their eventual connection. Accordingly, to close the existing LCCs, there will be additional properties in Pāhala that would be required to connect to the
10349-01Letter to Ms. Terri L. NapeahiPage 8March 6, 2020
new wastewater collection system, at their expense, after it becomes operational. Such properties are near the existing service area but are presently connected to individual wastewater systems. To conform to the stated section of HCC, the respective, newly accessible property owners would be responsible for the design, permitting and completion of sewer service connections between the County stub-outs and improvements for stated uses on their property, as well as for the proper closure of their individual wastewater systems.The Draft EA Figure 2.6 shows the area of the community serviced by the current and proposed collection systems.
4. This is not a comment pertinent to the content requirement of the Draft EA.
5. See 3 above.
6. The Draft EA Section 2.1.3 states:
“In 1999, EPA promulgated 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 CFR § 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. Cesspools can release disease-causing pathogens and other pollutants (e.g., nitrates) into groundwater aquifers, streams, and eventually the ocean, thus leading to public health and environmental concerns.”
In June 2017, EPA and the County entered into an Administrative Order on Consent (AOC) to close the County-operated LCCs serving the Pāhala Community by June 2021.”
40 C.F.R. § 144.88 applies to all existing LCCs across the nation. Closure of individual cesspools is mandated by legislation at the State level. In 2017, Act 125 was enacted requiring all cesspools, not exempted by the Department of Health, be upgraded or converted to septic systems, or aerobic treatment unit systems, or connected to sewage systems by January 1, 2050. Though closure of individual wastewater systems by the County is not part of the Proposed Action,this legislation will affect all parcels in Pāhala currently using cesspools for sewage disposal.
7. No groundwater quality data is available in the vicinity of the existing LCCs. The Draft EA Section 2.2 states:
“The purpose of the actions considered in this Environmental Assessment (EA) is to provide the infrastructure necessary to enable the County to comply with the SDWA and fulfill the compliance provisions of the AOC between EPA and the County with respect to closure of the Pāhala LCCs by June 2021.
10349-01Letter to Ms. Terri L. NapeahiPage 9March 6, 2020
The need for action is driven by the public health and environmental concerns associated with LCCs, as described in Section 2.1.3.” (See 6 above).
8. No.
Nuisance
1. The Draft EA Section 3.14.2 states:
“Wastewater treatment plants can be a source of nuisance odors to the surrounding community if not properly designed or operated. Typically, nuisance odors are most commonly associated with anaerobic (without oxygen) conditions and with processing of residual solids. Incoming raw sewage flows to the proposed wastewater treatment and disposal facility would first be routed to the headworks, which is the facility where the solids are removed from the flows.
To mitigate potential nuisance odors, the headworks would be equipped with an odor control system with a granulated activated carbon (GAC) scrubber to remove odors. A GAC scrubber passes the odorous air through a bed of activated carbon, which adsorbs the odorous constituents within the pore spaces of the carbon. The County currently operates GAC scrubbers at other facilities, and it has been proven to be an effective means of odor control both locally and nationwide. The treatment lagoons would be equipped with mechanical aerators capable of maintaining sufficiently aerobic (with oxygen) conditions within the water column, which would prevent nuisance odor conditions from occurring. The disposal groves would be irrigated with fully-treated and aerobic secondary effluent from the treatment process; irrigation with secondary effluent is not associated with development of nuisance odor conditions.”
This information will be repeated in the Final EA Section 3.14.2.
2. The proposed site plan is included in the Draft EA as Figure 2.3. As noted in Section 2.3.1, “disposal of the treated and disinfected effluent would be accomplished through land treatment in four groves of native, water-tolerant trees occupying a total area of approximately 8.0 acres.” This 8.0 acre planted area, combined with the sloping site topography and existing Cook pine trees (Araucaria columnaris) on Maile Street, will provide a visual buffer from both the Māmalahoa Highway and Maile Street. As outlined in Section 3.19.2 of the Draft EA, the Proposed Action is not expected to adversely affect the views or viewsheds identified in the County General Plan. The wastewater collection system would be installed below the streets and therefore would not impact views. Above grade structures may include the operations building, headworks and UV cover structures, fuel storage tank, and low berms around the groves. The existing pine trees along Maile Street, most of which would remain with no changes, would continue to obstruct the viewplanes
10349-01Letter to Ms. Terri L. NapeahiPage 10March 6, 2020
from Maile Street. The facility site would be adjacent (mauka) to, and visible from, Māmalahoa Highway (State Route 11); however, impacts to the viewplane would be mitigated by the planted trees in the basins and by the rise in elevation between the highway and the facility.
The Draft EA Section 2.3.1 states the driveway access to the wastewater treatment and disposal facility will be located west (mauka) of the Maile Street and Māmalahoa Highway intersection. Appropriate signs identifying the facility will be posted at the driveway access.
This information will be repeated in the Final EA.
3. The County’s intent, as stated in the June 22, 2017 US Environmental Protection Agency Region 9 Administrative Order on Consent is to provide an industry-standard wastewater collection system. The new sewer will replace the old, and there will be less likelihood of pests attracted to the modern, intact system.
4. The aerated lagoon plant design will not result in the migration of aerosols outside of the site boundaries. In addition, disinfection processes selectively kill pathogens or render them incapable of reproduction or harm to humans. As outlined in the Draft EA Appendix B Section 3.2, continuous disinfection of the treated effluent willbe provided to protect human health and the environment. The land application groves will incorporate a distribution system at the ground surface which will not produce aerosols (Appendix B, section 4.5.1).
Natural Disasters
1. The County will develop a facility management plan in accordance with applicable rules and regulations.
2. Seismic loading, including earthquake and soil loads, will be taken into account during detailed design. The Draft EA Section 3.4.2 states:
“Hawai‘i County Code Chapter 5 (Building), Section 5.3 indicates the “International Building Code, 2006 Edition” (IBC) – copyrighted and published in 2006 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 events. The seismic hazard characteristics described in the IBC are based on the seismic zone and proximity of the site to active seismic sources.
10349-01Letter to Ms. Terri L. NapeahiPage 11March 6, 2020
The wastewater treatment and disposal facility would be designed and constructed to meet the requirements of the 2006 IBC and Hawai‘i County Code 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, emergency generator diesel fuel, or disinfection chemicals from the facility during a seismic event.”
3. See 1 in Flooding above.
4. Hazards related to hurricanes, such as wind, rain, and flood loads, will be taken into account during detailed design. Applicable regulations and standards, including IBC 2006, will be adhered to.
5. The Draft EA Section 3.22.2 states:
“The proposed wastewater treatment and disposal facility would require potable water and fire protection lines from the end of the existing DWS system to the preferred location of the headworks [and] operations building”
All alternatives would be designed according to NFPA 820 “Standard for Fire Protection in Wastewater Treatment and Collection Facilities.” In accordance with Hawaii Fire Department requirements, Fire Department access and water supply to the proposed Site 7will be designed to comply with Chapter 18 of NFPA 2006 Uniform Fire Code as amended by Hawaii County.
This information will be included in the Final EA Section 3.22.2.
6. The Draft EA, Appendix B, Section 4 describes the facility, and contains preliminary design information, including redundant equipment and processes. The Draft EA, Section 3.24.2 states: “A land-line and/or cellular telephone telemetry system would be used to connect the wastewater treatment and disposal facility to DEM and facilitate communication with staff.” As outlined in the Draft EA, Appendix B, Section 4.6.6, this system will have an auto-dialer to inform operators of alarm conditions. In addition, the treatment processes will be appropriately designed to have capacity to accommodate upset conditions, including pump and other equipment failures and operational procedures in place to address mechanical and electrical outages. “A standby power system would be provided by a diesel generator and aboveground fuel tank with capacity to support three consecutive days of operation. An electrical service panel would be equipped with a manual transfer switch and generator receptacle. This would provide a connection to a trailer-mounted generator, in the event of [standby] generator failure….”
10349-01Letter to Ms. Terri L. NapeahiPage 12March 6, 2020
7. The proposed facility will be managed in accordance with County of Hawaii policies and procedures in the event of a labor disruption.
8. See 6 above.
9. Operation of the sewer system will not require a water source external to the proposed treatment and disposal facility. As stated in the Draft EA Section 2.3.1, “A 25-foot-wide by 1,500-foot-long easement located along the northern edge of the parc el would be used to provide access to utilities from Maile Street to the treatment and disposal facility. The easement would contain the incoming sewer line from the collection system, potable water line…”
Figure 2.3 shows the potential location of a fire hydrant. The Draft EA Section 3.22.2 states:“The proposed wastewater treatment and disposal facility would require potable water and fire protection lines from the end of the existing DWS system to the preferred location of the headworks [and] operations building.” Further: “As required by DWS, construction plans would show the estimated maximum daily water usage calculations prepared by a professional engineer licensed in the State of Hawaiʻi. After review of the calculations, DWS would determine if enough water is available and a water commitment could be issued.”
The above information will be repeated in the Final EA.
Applicable portions of the above will be repeated or included in the Final EA.
The signed petition will be included in the Final EA. Please refer to the response to the 10/25/18 comment letter submitted by the Pele Defense Fund for additional information.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC
10349-01Letter to Ms. Terri L. NapeahiPage 13March 6, 2020
P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (73)March 6, 2020
Ms. Ngaire GilmourP.O. Box 84396-3190 Pakalana St.Pāhala, Hawaiʻi 96777
ngaire.joy@gmail.com
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻū, HawaiʻiResponse to Comment - December 10, 2018 5:01 p.m.
Dear Ms. Gilmour:
Thank you for your December 10, 2018 5:01 p.m. comment message regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
1.As outlined in the Draft EA, Section 2.3.1, the Proposed Alternative does not include utilizing alternative energy systems such as photovoltaic solar or wind as a total replacement for connection to the HELCO grid due to:
x the need for consistent power supply;x up front capital cost;x insufficient space on the 14.9-acre proposed site to accommodate alternative energy systems;
x the objective to minimize the amount of land area removed from agricultural production; and x EPA-enforced project deadlines.
Emergency backup power is required whether alternative or traditional energy systems are utilized. Partial augmentation of traditional power utilizing photovoltaic solar panel arrays on the headworks and operations building rooftops, however, is feasible and will be further analyzed during the detailed design phase after loads and demand patterns are better understood. Additional alternative energy systems can be added in the future if prioritized and funded by County Council, and the proposed electrical systems will be designed to accept or be adaptable to additional alternative energy input.
10349-01Letter to Ms. Ngaire GilmourPage 2March 6, 2020
Methane gas is generated at wastewater treatment plants using a process called anaerobic digestion. The proposed wastewater treatment plant (WWTP) is too small for anaerobic digestion to be economical. The dry weather design flow to the Pahala WWTP is 190,000 gallons per day, and anaerobic digestion is only economically attractive for WWTPs that treat at least 5 to 10 million gallons per day. In addition, the anaerobic digestion process requires primary clarifiers as part of the liquid treatment process, but primary clarifiers tend to be odorous in tropical climates, due to the relatively high wastewater temperatures. The proposed alternative relies on natural treatment systems that require relatively low energy input. Additional detail regarding the preliminary analysis of alternative energy options can be found in the Final EA, Appendix B.
This information will be included in the Final EA
2.The Draft EA Section 2.7 describes the site selection process, including the factors and their relative weights used to evaluate the various sites. Further, Section 2.7 describes the twenty-one criteria within four general categories (environmental, social and cultural; location and site; land use and availability; and collection system and service area) that were established and defined for the analysis. The Draft EA Appendix B, Section 8, provides additional information regarding the site selection process. As a result of this process, the County identified three sites (Sites 7, 8, and 9) as reasonable alternatives for construction of the wastewater treatment and disposal facility under the Proposed Action. The final scores for Sites 7, 8, and 9 were 4.33, 4.06, and 4.10 respectively, out of a total possible score of 5. Based on this analysis, Site 7 was selected as the Preferred Alternative. The site is easily accessible, has good soils for a land application system, and is close to the existing LCCs.
The Draft EA Section 2.5 describes Site 9, which is south (makai) of the Preferred Alternative Site 7. As outlined in Appendix B Section 8, Site 9 earned a lower ranking than Site 7 for the following criteria: presence of and/or proximity to archaeological/cultural sites, existing vehicle access, power and potable water availability, and distance from the area of the wastewater collection system. Site 7 had a lower ranking than Site 9 in one category: topography. With the distance between the two sites less than 300 feet, they were ranked equally for the criteria of proximity of treatment units to existing occupied buildings.
The Draft EA Sections 2.5 and 2.7 provide information as to the issues related to the use of Site 9. An unnamed stream near the upper portion of the parcel could affect the selected configuration of the wastewater treatment facility and the land application groves. Potentially, to maximize energy efficiency by taking advantage of gravity flow, the headworks, lagoons and the subsurface constructed wetlands could be sited in the upper portion of the site, or the area closest to the highway. In addition, since the site is located across Māmalahoa Highway from the Pāhala community, it would require construction of piping and other utilities within the highway ROW and approval by the State of Hawaiʻi Department of Transportation. Site 9 would require
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additional access roads to facilitate both construction and operation of the treatment and disposal facility and a slightly longer transmission line given its increased distance from the existing LCCs.
This information will be included in the Final EA.
The Draft EA Section 3.15 references a November 2016 archaeological field inspection report that states, while the 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 parcel (which includes Site 7), as well as evidence from plantation-era documents that theopening of a lava tube containing human remains once existed in the southeastern corner of the parcel, indicate that further archaeological studies may be necessary. The Final EA will clarify that the report also stated it would be advisable to limit the development footprint to exclude the southeastern corner of the 42.5-acre parcel. This area, which is presently not used as a macadamia nut orchard, but forms part of the macadamia nut processing plant complex, is the location of a known (but sealed) lava tube opening that local informants have indicated is linked to tubes that possess traditional human burials. Further, by excluding this section of the parcel, it will be possible to avoid at least one known historic property. The Draft EA Figure 2.3 provides the Preliminary Site Plan for the new treatment and disposal facility, which shows the 14.9-acre project site has been developed to exclude the area in the southeastern corner identified as the location of the sealed lava tube opening.
Between September 18, 2018 and January 10, 2019 a team of qualified archaeologists conducted a pedestrian survey of the proposed project site and completed subsurface trenching to determine the presence of archaeological resources. The work was undertaken in accordance with the State of Hawaii Department of Land and Natural Resources State Historic Preservation Division (SHPD) requirements, with the archaeological inventory survey (AIS) approach accepted by SHPD in their August 20, 2018 letter. The results of the survey and subsurface trenching showed no burials or lava tube openings were present on-site. The AIS submitted to SHPD in March 2019 documents that a sealed lava tube opening is located east of the proposed wastewater treatment and disposal facility project site, outside the proposed property boundary, and outside of the area of potential effect considered in consultation with the SHPD.
A geophysical survey of the proposed project area will be performed during detailed design with the specific intent to locate subsurface voids (such as lava tubes) present beneath the site that may impact design and construction of the new wastewater treatment, disposal and collection systems.
This information will be included in the Final EA.
The Draft EA Section 3.15 provides information on the archaeological and cultural resources related to the Pāhala Large Capacity Cesspool Replacement project. The Draft EA Section 3.15
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states, on March 29, 2018, consultation was initiated for the project under the National Historic Preservation Act. The Draft EA Section 10 provides a list a list of the consulted parties. The Final EA Section 3.15 will include that the list of Native Hawaiian Organizations (NHO) was generated by the EPA from the U.S. Department of the Interior, Office of Native Hawaiian Relations, Native Hawaiian Organization (NHO) Notification List for NHPA Section 106 and HRS Chapter 6E compliance. Letters were sent to 14 NHOs during the pre-assessment consultation. No responses were received from these organizations.
The HRS Chapter 6E determination and Section 106 review packet were submitted to SHPD with a draft archaeological inventory survey (AIS) on March 13, 2019. SHPD response is pending. The Draft EA Section 3.15.2 states that prior to finalization of this EA and initiation of the Proposed Action, the Environmental Protection Agency (EPA) and the County of Hawai‘i will conclude consultation with SHPD in accordance with Section 106 of the NHPA and will incorporate additional impact avoidance and minimization measures as necessary to result in a finding of no adverse effects to historic properties.
The Final EA Section 7 will be include that on September 26, 2018, a public notice was published in the Hawaii Tribune Herald and West Hawaii Today newspapers. The public notice was to advertise the October 10, 2018, public information meeting conducted by the County in the Pāhala at the Ka‘ū Gym Multi-Purpose Conference Room to discuss the availability of the Draft EA and process for submitting comments. The notice stated that the second part of the meeting would address Section 106 of the National Historic Preservation Act of 1966, as amended (2006),involving consultation with Native Hawaiian Organizations and the Native Hawaiian descendants with ancestral lineal or cultural ties to, cultural knowledge or concerns for, and cultural religious attachment to the proposed project area. Eight persons placed their names on a sign in sheet at the October 10, 2018 public meeting to contribute during the second part of the meeting dedicated to the Section 106 consultation. No comments or information were forthcoming during the Section 106 portion of the meeting.
3. a) and b)The Draft EA Section 2.2 describes the purpose of the Pāhala Large Capacity Cesspool Replacement project is to close the Pāhala large capacity cesspools (LCC).The County’s intent, as stated in the June 22, 2017 US Environmental Protection Agency Region 9 Administrative Order on Consent is to provide an industry-standard wastewater collection system and a secondary treatment and disposal facility, a basic service to the Pāhala community, to eliminate underground injection from LCCs it operates to help protect underground drinking water sources.
The Draft EA Section 2.3.2 discusses the construction of a new sewer collection system in the Pāhala community to replace the existing system of substandard gravity lines that currently conveys sewage to the two LCCs. As described in Section 6.2.1, the current collection system includes facilities located in the backyards of many parcels. Where easements for the existing
10349-01Letter to Ms. Ngaire GilmourPage 5March 6, 2020
collection system aren’t accessible, the County must obtain permission from individual landowners to enter them, through private property, to inspect, maintain, repair or replace existing sewer facilities: all activities essential to an efficient, functioning system. As a result, the proposed new collection system would consist of a total of approximately 12,150 linear feet (LF) (2.3 miles) of corrosion-resistant polyvinyl chloride (PVC) piping located almost entirely within the right of way (ROW) of eight public streets.
The extent of the collection system is to ensure the parcels connected to the former C. Brewer system will have access to the treatment and disposal facility so the large capacity cesspools can be closed. It is conventional to extend the utility to the nearest intersection to minimize the number of manholes.
The Draft EA, Section 2.3.2, states the new collection system would be subject to the Hawaiʻi County Code (HCC) Chapter 21, Sewers, specifically, Article 2 (Public Sewers), Section 21-5,which 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.”
All accessible properties will be required to connect to the new wastewater collection system in accordance with Hawaii County Code, Chapter 21, Article 2, Section 21-5. However, the County entered into an agreement with C. Brewer (in April 2007) to eliminate LCCs from the existing community sewer systems and connect properties discharging to them to new County collection, treatment and disposal systems. Once the actual costs are determined, County Council action is still required to approve the expenditures.
Each adjacent lot will be provided with a lateral connection to the sewer main as required by HCC and standards. Under the Preferred Alternative, the design of the new collection system would extend between street intersections and include sewer service stub-outs (the lateral connection to the sewer main) to the lot lines of adjacent properties, including the newly accessible, to accommodate their eventual connection. Accordingly, to close the existing LCCs, there will be additional properties in Pāhala that would be required to connect to the new wastewater collection system, at their expense, after it becomes operational. Such properties are near the existing service area but are presently connected to individual wastewater systems. To conform to the stated section of HCC, the respective, newly accessible property owners would be responsible for the design, permitting and completion of sewer service connections between the County stub-outs and improvements for stated uses on their property, as well as for the proper closure of their individual wastewater systems. The Draft EA Figure 2.6 shows the area of the community serviced by the current and proposed collection systems.
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The financial impact of the project on individual newly accessible property owners was raised by the community during the December 2017 public meetings as summarized in Section 7 of the Draft EA. Although not required by Hawaii Administrative Rules (HAR) Title 11, Chapter 200, DEM voluntarily convened two additional public meetings on October 9, 2018 and March 21, 2019 to gain further input from newly accessible property owners and present funding options for them to pursue.
The Draft EA Section 7 will be revised to add that the County held additional meetingsin Pāhala including one to provide information on financing sources available to owners of parcels which would become accessible to the County collection system. The purpose of the March 21, 2019 meeting was to fulfill a County commitment made in October, 2018 to research financing options available to the newly accessible residents of the Pahala Community. At the meeting, DEM provided the preliminary results of the County investigation into funding sources and options available to newly accessible property owners once the new treatment and disposal facility and wastewater collection system have been designed, permitted and constructed.
Programs discussed included:
x US Department of Housing and Urban Development (HUD) with County of Hawaii Office of Housing and Community Development Residential Repair Program -Community Block Grant Program, and
x US Department of Agriculture - Rural Development (USDA-RDA) Program.
As noted during the presentation, these programs may change in the coming years, and additional options may be added to this preliminary list. Hawaii Legislature, Senate Bill 221 SD1, which could amend Hawaii Revised Statutes (HRS) Chapter §342D to establish a low interest loanprogram to offer financial assistance to cesspool owners to connect to wastewater treatment systems approved by the Department of Health was also discussed; however, this bill was subsequently not passed during the 2019 legislative session.
This information will be included in the Final EA.
Closure of individual cesspools is mandated by legislation at the State level. In 2017, Act 125 was enacted by the Hawaiʻi State legislature requiring all cesspools, not exempted by the Department of Health, be upgraded or converted to septic systems, or aerobic treatment unit systems, or connected to sewage systems by January 1, 2050. Though closure of individual wastewater systems by the County is not part of the Proposed Action, this legislation will affect all parcels in Pāhala currently utilizing cesspools for sewage disposal.
The Draft EA Section 6.2.2 discusses the Ka‘ū Community Development Plan (CDP): “Section 5 of the CDP prioritizes improvements in infrastructure, facilities, and services, including Section 5.8 which applicable to … Environmental management facilities, including expanded
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sewer lines, …”. Policy 120 is to “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 accommodating the Pāhala community. Similarly, the treatment and disposal facility has been designed not to preclude accommodating the wastewater flows from the collection system from the Pāhala community.
This information will be included in the Final EA.
The Draft EA Section 3.16 provides information on the socioeconomic characteristics of the Pāhala community.
The Draft EA Section 5.7 Environmental Justice Executive Order 12898 will be revised as follows
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 2017 American Community Survey (ACS) (5-Year Estimates) is the most recent information related to socioeconomic conditions in the state and County. The 2017 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 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. Pāhala has more households in the “less than $24,999” income bracket (33.7 percent) than the County as a whole (26.3 percent).
Overall, Pāhala is characterized by a racial composition that includes a greater proportion of minorities (92.1 percent non-White) than the County at large (66.8 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
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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 Hawai‘i County, although Pāhala has a higher proportion of individuals in the “Under 5 to 19” age category (28.5 percent) compared to the County as a whole (24.4 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. The design and location of the proposed wastewater treatment and disposal 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.
This information will be included in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (74)March 6, 2020
Mr. Keoni Fox48-472 Kamehameha HighwayKaneohe, Hawai‘i 96744
Subject: Draft Environmental Assessment for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of,Kaʻū, HawaiʻiResponse to Comment - December 10, 2018; 5:34 p.m.
Dear Mr. Fox:
Thank you for your December 10, 2018 5:34 p.m. comment message regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our response follows:
The Draft EA Section 3.15 references a November 2016 archaeological field inspection report that states, while the 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 parcel (which includes Site 7), as well as evidence from plantation-era documents that the opening of a lava tube containing human remains once existed in the southeastern corner of the parcel, indicate that further archaeological studies may be necessary. The Final EA will clarify that the report also stated it would be advisable to limit the development footprint to exclude the southeastern corner of the 42.5-acre parcel. This area, which is presently not used as a macadamia nut orchard, but forms part of the macadamia nut processing plant complex, is the location of a known (but sealed) lava tube opening that local informants have indicated is linked to tubes that possess traditional human burials. Further, by excluding this section of the parcel, it will be possible to avoid at least one known historic property. The Draft EA Figure 2.3, whichprovides the Preliminary Site Plan for the new treatment and disposal facility, shows the 14.9-acre project site has been developed to exclude the area in the southeastern corner identified as the location of the sealed lava tube opening.
Between September 18, 2018 and January 10, 2019 a team of qualified archaeologists conducted a pedestrian survey of the proposed project site and completed subsurface trenching to determine the presence of archaeological resources. The work was undertaken in accordance with the State of Hawaii Department of Land and Natural Resources State Historic Preservation Division (SHPD) requirements, with the archaeological inventory survey (AIS) approach accepted by SHPD in their August 20, 2018 letter. The results of the survey and subsurface trenching showed no burials or lava tube openings were identified on-site. The AIS submitted to SHPD in March 2019 documents that a sealed lava tube opening is located east of the proposed wastewater
10349-01Letter to Mr. Keoni FoxPage 2March 6, 2020
treatment and disposal facility project site, outside the proposed property boundary, and outside of the area of potential effect considered in consultation with the SHPD.
The complete document is available for download from the County’s website at: http://records.co.hawaii.hi.us/weblink/1/edoc/100962/Draft%20Archeological%20Inventory%20Survey%20-%20Pahala%20WWTP%20and%20Sewer%20System.pdf
A geophysical survey of the proposed project area will be performed during detailed design with the specific intent to locate subsurface voids (such as lava tubes) present beneath the site that may impact design and construction of the new wastewater treatment, disposal and collection systems.
This information will be included in the Final EA.
The Draft EA Section 2.3.1 states the aerated lagoons will be lined to prevent water seepage through the bottom and sides of the lagoons. Thus, untreated wastewater will not enter the ground beneath the WWTP. In addition, the preferred alternative (Site 7) slopes from approximately north to south (mauka to makai) such that, during rain events, surface flows pass through the existing orchard to the southern (makai) end where the flows eventually drain through the culvert located at the Maile Street-Māmalahoa Highway intersection to the areas below (makai) the highway. The gradient of Site 7 and surrounding area results in this naturalpattern of surface flows which also existed when the area was planted in sugar cane.
The Draft EA Summary shows the HawaiʻiIsland Burial Council was consulted as part of the Draft EA preparation process. The Draft EA Section 3.15 states, on March 29, 2018, consultation was initiated for the project under the National Historic Preservation Act. The Draft EA Section 10 provides a list of the consulted parties. The Final EA Section 3.15 include that the list of Native Hawaiian Organizations (NHO) was generated by the EPA from the U.S. Department of the Interior, Office of Native Hawaiian Relations, Native Hawaiian Organization (NHO) Notification List for HRS Chapter 6E and NHPA Section 106 compliance. Letters were sent to 14 NHOs during the pre-assessment consultation. No responses were received from these organizations.
The HRS Chapter 6E determination and Section 106 review packet were submitted to SHPD with a draft AIS on March 13, 2019. SHPD response is pending. The Draft EA Section 3.15.2, states thatprior to finalization of this EA and initiation of the Proposed Action, EPA and the County of Hawai‘i will conclude consultation with SHPD in accordance with Section 106 of the NHPA and will incorporate additional impact avoidance and minimization measures as necessary to result in a finding of no adverse effects to historic properties.
The Final EA Section 7 will include that on September 26, 2018, a public notice was published in the Hawaii Tribune Herald and West Hawaii Today newspapers. The public notice was to
10349-01Letter to Mr. Keoni FoxPage 3March 6, 2020
advertise the October 10, 2018 public information meeting conducted by the County in Pāhala at the Ka‘ū Gym Multi-Purpose Conference Room to discuss the availability of the Draft EA process for submitting comments. The notice stated that the second part of the meeting would address Section 106 of the National Historic Preservation Act of 1966, as amended (2006)involving consultation with Native Hawaiian Organizations and the Native Hawaiian descendants with ancestral lineal or cultural ties to, cultural knowledge or concerns for, and cultural religious attachment to the proposed project area. Eight persons placed their names on a sign in sheet at the beginning of the October 10, 2018 meeting to contribute during the second part of the meeting dedicated to the Section 106 consultation. No comments or information were forthcoming during the Section 106 portion of the meeting.
The above will be repeated or included in the Final EA as applicable.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (76)March 6, 2020
Dr. B Noelani Hong, PhD, OTR/LP.O. Box 64Volcano, Hawaiʻi 96785
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻū, HawaiʻiResponse to Comment - October 28, 2018
Dear Dr. Hong:
Thank you for your October 28, 2018 comment letter regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
The Draft EA Section 3.9.1 (a) states:
“The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM), Community Panel No. 155166 1800F, effective date September 29, 2017 shows 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.
On April 16, 2018, in response to the pre-assessment notification, the State of Hawai‘i Department of Land and Natural Resources Engineering Division stated the responsibility for conducting research as to the flood hazard designation for the project site lies with the project proponent. Also on April 16, 2018 and in response to the pre-assessment notification, the County of Hawai‘i Department of Public Works confirmed that the proposed treatment and disposal project site is designated as Zone X on the FIRM and is outside the 500-year floodplain.”
The relevant FIRM panel is reproduced in Appendix B as Figure 4-13.
10349-01Letter to Dr. B Noelani Hong, PhD, OTR/LPage 2March 6, 2020
This information will be repeated in the Final EA.
The Draft EA Section 3.23.2 states:
“The proposed wastewater treatment and disposal facility would include an on-site drainage system to address stormwater surface runoff created by new impervious surfaces within the facility. The site would include a system to collect runoff via grated inlets or swales, and flows would be conveyed to on-site drainage detention systems, such as subsurface linear infiltration or depressed detention basins.”
This information will be repeated in the Final EA.
The preferred alternative (Site 7) slopes from approximately north to south (mauka to makai) such that, during rain events, surface flows drain through the existing orchard to the southern (makai) end where the flows eventually drain through the culvert located at the Maile Street-Māmalahoa Highway intersection to the areas below (makai) the highway. Most of the land surface area below the existing macadamia nut orchard contains little to no vegetation to absorb or slow these flows. The gradient of Site 7 and surrounding area results in this natural pattern of surface flows which also existed when the area was planted in sugar cane and is not considered flooding.
Based on the roadway flooding concerns expressed by the community during the Pahala public meetings held in December 2017 and October 2018, the State of Hawai‘i Department of Transportation (DOT) Hawai‘i District office was contacted to discuss drainage at the treatment and disposal facility project site and the culvert at the Maile Street and Māmalahoa Highway intersection. On February 20, 2019, the District office confirmed via telephone that the DOT owns and maintains the culvert at the Maile Street intersection, and that they have no record of the roadway being inundated at that location by stormwater drainage during precipitation eventsat that location.
Stormwater runoff generated mauka of the treatment and disposal facility project site will be directed around the perimeter of the site via diversion swales that will convey flows back to the existing drainage pattern that flows to the existing culvert at Maile Street. During heavy rain events, stormwater may temporarily back up behind the culvert. There will be no changes to this culvert and the proposed wastewater treatment and disposal facilities will not be located within the area of the culvert.
As stated in the Draft EA, the on-site stormwater management system will meet the requirements of Hawai‘i County Code (HCC), Chapter 27 Floodplain Management, Section 20, Standards for subdivisions and other developments (e) which mandates a site drainage plan to “comply with sections 27-20(a) and (b) and section 27-24, and shall include a storm water disposal system to contain run-off caused by the proposed development, within the site boundaries, up to the
10349-01Letter to Dr. B Noelani Hong, PhD, OTR/LPage 3March 6, 2020
expected [design] storm event as shown in the department of public works “Storm Drainage Standards”.
To meet the requirements of HCC, Chapter 27, Section 20 (f), the project site “shall not alter the general drainage pattern above or below the development”. Thus, for the HCC design storm event, no increase in flow amount will be directed to either of the culverts at the highway as a result of the site development. A drainage report will be prepared during the design process to evaluate the improvements that are necessary to comply with HCC Chapter 27 requirements.
The wastewater treatment processes will be designed to accommodate the associated peak flows, including precipitation that falls on the area occupied by the aerated lagoon treatment system. The Draft EA Appendix B, Section 2.2 outlines the anticipated peak wastewater flows from the community, based on the applicable flow standard. The Draft EA Section 2.3.1 states the aerated lagoons will be lined with to prevent water seepage through the bottom and sides of the lagoons. The Draft EA, Appendix B, Section 5.3 shows the operational freeboard that will be available to contain and to equalize lagoon flows. In addition, the slow-rate land application groves will be designed to completely contain both peak effluent flows and precipitation from a 100-year, 24-hour storm event. A geotechnical engineering assessment of berm stability will be conducted during the design process for any berms intended to act as secondary containment. The tree groves will be designed in accordance with the EPA’s “Process Design Manual, Land Treatment of Municipal Wastewater Effluents”. Effluent will be applied at a hydraulic loading rate that is a small percentage of the percolation rate of the soil, ensuring sufficient capacity for assimilation of peak effluent flow rates and precipitation from the design storm event.
Treatment process options are discussed in Section 2.8.2 of the DEA. In summary, any “type” of wastewater treatment process (such as e.g., aerated lagoons, activated sludge “mechanical” treatment plants, etc.) must incorporate both peak flows from the collection system and precipitation that falls on the exposed process components into the design. The proposed aerated lagoon system is a “flow through” process, not a storage reservoir. Wastewater from the community (including peak wet weather flows) will move through the lagoon system to the disposal system and will not be stored in the lagoons. The proposed aerated lagoon system will be lined and designed to have adequate freeboard to contain the required storm event and not overflow offsite. Further:
x stormwater flows generated outside of the treatment and disposal facility will be directed around the site;x an onsite stormwater collection and management system will contain runoff generated at the facility; and
x the proposed land application groves will be designed to completely contain both peak effluent flows and precipitation from a design storm event.
10349-01Letter to Dr. B Noelani Hong, PhD, OTR/LPage 4March 6, 2020
Because the above measures would be incorporated no matter what “type” of treatment process is chosen, flooding was not a criterion specifically evaluated as part of the treatment process selection.
This information will be included in the Final EA.
The Draft EA Section 2.7 describes the site selection process, including the factors and their relative weights used to evaluate the various sites. Further, Section 2.7 describes the twenty-one criteria within four general categories (environmental, social and cultural; location and site; land use and availability; and collection system and service area) that were established and defined for the analysis. The Draft EA Appendix B, Section 8, provides additional information regarding the site selection process. As a result of this process, the County identified three sites (Sites 7, 8, and 9) as reasonable alternatives for construction of the wastewater treatment and disposal facility under the Proposed Action. The final scores for Sites 7, 8, and 9 were 4.33, 4.06, and 4.10 respectively, out of a total possible score of 5. None of the three sites were located in Special Flood Hazard Areas as designated on the FIRM map in Appendix B. Based on this analysis, Site 7 was selected as the Preferred Alternative. The site is easily accessible, has good soils for a land application system, and is close to the existing LCCs.
This information will be included in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (1)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – September 24, 2018 8:57 a.m.
Dear Ms. Demoruelle:
Thank you for your September 24, 2018 8:57 a.m. comment message regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
#1. This is not a comment pertinent to the Draft EA for the Pāhala Large Capacity Cesspool Replacement project.
#2.The proposed Pāhala wastewater treatment plant (WWTP) 14.9-acre project site has been developed to provide the necessary land area for the facilities needed to treat the incoming flows and to dispose the treated effluent from the treatment processes. The proposed project site minimizes the use of the adjacent lands which contain a commercial macadamia orchard. A larger project site is not required. The special permit requirement applies to the proposed WWTP parcel only, not to the proposed utility easement. The County will apply for the required special permit through the Planning Commission.
Chapter 4 of the Draft EA discusses cumulative impacts, including the scope of the analysis.
#3 The June 7, 2018 letter is a designation letter from the US Environmental Protection (EPA) to the US Fish and Wildlife Services (FWS) to meet the requirements of 50 C.F.R. §402.28 for the Pāhala project. As stated in Section 3.12.2 of the Draft EA, prior to finalization of the EA, the EPA and County of Hawaiʻi will conclude consultation with the FWS. The Final EA will include the final consultation letter from FWS.
#4 On, November 7, 2018, the eleven copies of the Draft EA were hand delivered by the County of Hawaiʻi to the Pāhala Public Library and a similar number of copies to the Naalehu Public Library. The County of Hawaiʻi transmittal requested the library make the copies available for checkout. This information will be included Final EA, Section 7.
10349-01Letter to Ms. Sandra Demoruelle Page 2March 6, 2020
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (2)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – September 24, 2018 10:26 a.m.
Dear Ms. Demoruelle:
Thank you for your September 24, 2018 10:26 a.m. comment message regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
On, November 7, 2018, the County of Hawaiʻi hand delivered eleven copies of the Draft EA to the Pāhala Public Library and a similar number of copies to the Naalehu Public Library. The County of Hawaiʻi transmittal requested the library make the copies available for checkout. This information will be included in the Final EA Section 7.
Hawaii Revised Statutes (HRS) Chapter 343 Section 5 (a)(9)(A), states as follows: “(a) Except as otherwise provided, an environmental assessment (emphasis added) shall be required for actions that: ... (9) Propose any: (A) Wastewater treatment unit, except an individual wastewater system or a wastewater treatment unit serving fewer than fifty single-family dwellings or the equivalent…”. HAR Title 11, Chapter 200, which implements HRS Chapter 343, however, differentiates between “agency actions” that utilize state or county lands or funds and “applicant actions” for which an applicant must seek agency approval. Since the proposed action will utilize county lands and funds, it is an “agency action” requiring compliance with HRS Chapter 343 and HAR Title 11, Chapter 200, pursuant to which an environmental assessment is being prepared and processed.
Comment #5 - HRS 343-5 Applicability and requirements states under (c) (4) “A(n environmental impact) statement shall be required if the agency finds that the proposed action may have a significant effect on the environment…” The criteria by which the proposing agency makes the significance determination is provided in Hawaii Administrative Rules (HAR) Title 11 Section 200-12 (a) and (b) which states: “(a) In considering the significance of potential environmental effects, agencies shall consider the sum of the effects on the quality of the environment, and shall evaluate the overall and cumulative effects of an action. (b) In determining whether an action may have a significant effect on the environment, the agency shall
10349-01Letter to Ms. Sandra Demoruelle Page 2March 6, 2020
consider every phase of a proposed action, the expected consequences… and the…effects of the action.”
HAR Title 11-200-10Contents of an environmental assessment includes “(9) Findings and reasons supporting the agency determination or anticipated determination…”. The Draft EA provides this in Chapter 8 Findings and Determination. Neither HRS Chapter 343 nor HAR Title 11, Chapter 200 contain any requirement that all proposed wastewater systems require an EIS.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (3)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – September 24, 2018 11:15 a.m.
Dear Ms. Demoruelle:
Thank you for your September 24, 2018 11:15 a.m. comment message regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
Comment #1 - This is not a comment pertinent to the content requirements of the Draft (EA) for the Pāhala Large Capacity Cesspool Replacement project.
Your mailing address will be corrected.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (4)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – September 24, 2018 1:21 p.m.
Dear Ms. Demoruelle:
Thank you for your September 24, 2018 1:21 p.m. comment message regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our response follows:
This is not a comment pertinent to the Draft EA for the Pāhala Large Capacity Cesspool Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChangProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (5)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – September 25, 2018 8:32 a.m.
Dear Ms. Demoruelle:
Thank you for your September 25, 2018 8:32 a.m. comment message regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our response follows:
Comment #6 - The Draft EA Section 2.3.1 states that wastewater flow projections were developed for the treatment and disposal facility using the City and County of Honolulu wastewater standards, most recently updated in 2017. Based on these standards, the Pāhala treatment and disposal facility would be designed to provide an average dry weather flowcapacity of 190,000 gallons per day (gpd), which would be sufficient capacity to close the two LCCs. The Draft EA Appendix B contains additional detail on the flow projections. The corresponding peak day wet weather flow is 650,000 gpd. This information will be repeated in the Final EA.
Future sewer main extensions and subdivisions will be accommodated, as capacity allows, on a first come, first served basis. The Draft EA, Appendix B, states the wastewater treatment plant (WWTP) design will be expandable not to preclude treating future average dry weather flows up to 360,000 gpd (with a corresponding peak day wet weather flow of 1,260,000 gpd) to meet the future needs of the community, in accordance with the requirements established in the Kaʻu Community Development Plan Policy 120. The Draft EA, Appendix B states the proposed WWTP will accommodate modification within the proposed 14.9-acre site for the future expansion of the service area.
Hawaii Administrative Rules (HAR) Title 11-62 requires wastewater treatment works to be designed in accordance with county standards. If a county does not have design standards, then the design standards for the City and County of Honolulu shall be used. The County of Hawaiʻidoes not have design standards; therefore, the City and County of Honolulu standards are applicable to the Pahala WWTP. Application of the standards resulted in the flow capacities presented in the Draft EA Section 2.3.1. Additional detail is provided in the Draft EA Appendix B
10349-01Letter to Ms. Sandra Demoruelle Page 2March 6, 2020
Section 5.6.1. It should be noted that wastewater flows from a community are highly variable, and peak flow rates from small community wastewater collection systems are typically three to five times higher than the average flow rates. The City and County of Honolulu standards take this variability into account, and application of the standards results in conservatively-designed facilities that are protective of human health and the environment in anticipated operational conditions. This information will be included in the Final EA.
The Naalehu and Hilo projects are not the subject of the Pāhala Large Capacity Cesspool Replacement Draft EA.
The proposed treatment system for the Pāhala WWTP includes aerated lagoons that are more-energy efficient than conventional activated sludge wastewater treatment processes. The aerated lagoon process is less sensitive to underloading conditions than conventional activated sludge wastewater treatment processes and will provide excellent treatment performance during low flow conditions. The “negative removal efficiency” effect is not applicable to the aerated lagoon technology. The proposed WWTP does include a constructed wetland treatment system and the proposed land treatment tree groves provide an energy-efficient “natural” technology that will use sunlight, vegetation, and soil properties to achieve the desired results.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (6)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – September 25, 2018 9:39 a.m.
Dear Ms. Demoruelle:
Thank you for your September 25, 2018 9:39 a.m. message regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
The Draft EA Section 2.3.1 states the County would acquire or obtain the right to develop and use a 14.9-acre area for construction of a new secondary treatment and disposal facility. The Draft EA Section 2.10.3 states according to Chapter 205, Hawaii Revised Statutes (HRS), §205-4.5 (a) within the Agricultural District on lands with Land Study Bureau master productivity rating class A or B shall be restricted to the following permitted uses: (7) public, private and quasi-public utility lines. Thus, the 1,500-foot by 25-foot utility easement is a permitted use. The 14.9-acre area is the appropriate project size as it provides sufficient area to meet the current and future needs of the community that the WWTP will serve, while minimizing the impact to the adjacent macadamia nut farm. Further, as stated in the Draft EA Section 2.10.3, the County of Hawaiʻi Department of Environmental Management will submit a Special Permit application to the County of Hawaiʻi Planning Commission. This information will be repeated in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
10349-01Letter to Ms. Sandra Demoruelle Page 2March 6, 2020
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (7)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – September 25, 2018 12:28 p.m.
Dear Ms. Demoruelle:
Thank you for your September 25, 2018 12:28 p.m. comment message regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
On March 8, 2018, the US Environmental Protection Agency (EPA) notified various Native Hawaiian Organizations (NHOs) that the County of Hawaiʻi Department of Environmental Management (DEM) had been authorized to act in EPA’s behalf when initiating consultation under 54 U.S.C §300101 and 36 CFR §800.2(e)4 for the Pāhala Large Capacity Cesspool Replacement project. The NHOs to be notified were selected from those listed by the U.S. Department of the Interior, Office of Native Hawaiian Relations, Native Hawaiian Organization (NHO) Notification List, Updated December 14, 2017. On March 29, 2018, the DEM notified those on the list about the proposed Pāhala project and welcomed their comments under 54 U.S.C. §32706 also called Section 106 of the National Historic Preservation Act (NHPA). Further, the DEM letter requested the addressed organization, if acquainted with persons or organizations knowledgeable about the proposed project area, or any descendants with ancestral lineal or cultural ties or cultural knowledge or concerns, or religious attachment to the proposed project area, provide their names and contact information.
Notice of availability of the Draft EA was published on September 23, 2018. Subsequently on September 26, 2018, a public notice was published in the Hawaii Tribune Herald,West Hawaii
Today newspapers, and the online .Dµnj1HZV%ULHI.The public notice was to advertise the October 10, 2018 public information meeting conducted be the County in Pāhala to discuss the availability of the Draft EA and process for submitting comments. The notice stated that thesecond part of the meeting would address Section 106 of the NHPA involving consultation with NHOs and Native Hawaiian descendants with ancestral lineal or cultural ties or cultural knowledge or concerns, or religious attachment to the proposed project area. During the October 10th meeting attendees were invited to provide information about the proposed project area.
10349-01Letter to Ms. Sandra Demoruelle Page 2March 6, 2020
Subsequently, notice of availability of the Draft EA was republished on November 8, 2018 and the comment period ended on December 10, 2018.
Based on the above, the EPA and the DEM have provided the necessary notifications and the opportunities for comment to NHOs and Native Hawaiian descendants with ancestral lineal or cultural ties or cultural knowledge or concerns, or religious attachment to the project area.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (8)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – September 25, 2018 12:39 p.m.
Dear Ms. Demoruelle:
Thank you for your September 25, 2018 12:39 p.m. message regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our response follows:
The councilmember’s name will be corrected in the Final EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (9)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – September 28, 2018 9:54 a.m.
Dear Ms. Demoruelle:
Thank you for your September 28, 2018 9:54 a.m. message regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
Hawaii Administrative Rules (HAR) Title 11 Chapter 200 has no requirement for conducting a public meeting in conjunction with preparing an environmental assessment. The October 10, 2018 meeting was voluntarily sponsored by the County of HawaiʻiDepartment of Environmental Management (DEM) to encourage public participation in the environmental review process.
HAR 11-200-9.1(b) states that the “period for public review and for submitting writtencomments for both agency actions and applicant actions shall begin… Written comments to the proposing agency…shall be received or postmarked…” (emphasis added).
There is no provision for receiving oral comments in HAR 11-200. However, during the October 10, 2018 public meeting, the facilitator offered assistance by persons available at the meeting to put any oral comments attendees might wish to offer into writing.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
10349-01Letter to Ms. Sandra Demoruelle Page 2March 6, 2020
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (10)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – September 28, 2018 11:52 a.m.
Dear Ms. Demoruelle:
Thank you for your September 28, 2018 11:52 a.m. comment message regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
Please refer to Appendix E for additional information regarding this issue.
Hawaii Administrative Rules (HAR) Title 11 Chapter 200 has no requirement for conducting a public meeting in conjunction with preparing an environmental assessment. The October 10, 2018 meeting was voluntarily sponsored by the County of Hawaiʻi Department of Environmental Management (DEM) to encourage public participation in the environmental review process.
There is no provision for receiving oral comments in HAR 11-200. However, during the October 10, 2018 public meeting, the facilitator offered assistance by persons available at the meeting to put any oral comments attendees might wish to offer into writing.
HAR 11-200-9.1(b) states that the “period for public review and for submitting writtencomments for both agency actions and applicant actions shall begin… Written comments to the proposing agency…shall be received or postmarked… (emphasis added).
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
10349-01Letter to Ms. Sandra Demoruelle Page 2March 6, 2020
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (11)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – September 28, 2018 1:21 p.m.
Dear Ms. Demoruelle:
Thank you for your September 28, 2018 1:21 p.m. comment message regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Community Large Capacity Cesspool Replacement project. Our responses follow:
This is not a comment pertinent to the content requirements of the Draft EA for the Pāhala Large Capacity Cesspool Replacement project.
Formal police presence was not requested for the October 10, 2018 community information meeting.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (12)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – September 28, 2018 1:43 p.m.
Dear Ms. Demoruelle:
Thank you for your September 28, 2018 1:43 p.m. comment message regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our response follows:
HawaiʻiAdministrative Rules (HAR) Title 11 Chapter 200-10 Contents of an environmental assessment does not include a requirement for evaluating the fiscal impacts of a project on a County’s budget or ability to obtain funding.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref 13)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – September 29, 2018 5:50 p.m.
Dear Ms. Demoruelle:
Thank you for your September 29, 2018 5:50 p.m. comment message regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our response follows:
On September 12, 2018, the Draft EA for the Pāhala Large Capacity Cesspool Replacement project was filed with the State of Hawaii Department of Health Office of Environmental Quality Control (OEQC) under the filing dates schedule established by OEQC.
You have referenced an EIS-specific checklist. The most up-to-date guidance available for the EA process is available for download at: http://oeqc2.doh.hawaii.gov/OEQC_Guidance/Forms/AllItems.aspx
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref 14)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – October 1, 2018 10:29 a.m.
Dear Ms. Demoruelle:
Thank you for your October 1, 2018 10:29 a.m. comment message regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our response follows:
This is not a comment pertinent to the content requirements of the Draft EA for the Pāhala Large Capacity Cesspool Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (15)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – October 1, 2018 10:41 a.m.
Dear Ms. Demoruelle:
Thank you for your October 1, 2018 10:41 a.m. comment message regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
Hawaii Revised Statutes (HRS) Chapter 343 Section 5 (a)(9)(A), states as follows: “(a) Except as otherwise provided, an environmental assessment (emphasis added) shall be required for actions that: ... (9) Propose any: (A) Wastewater treatment unit, except an individual wastewater system or a wastewater treatment unit serving fewer than fifty single-family dwellings or the equivalent…”. Hawaii Administrative Rules (HAR) Title 11, Chapter 200, which implements HRS Chapter 343, however, differentiates between “agency actions” that utilize state or county lands or funds and “applicant actions” for which an applicant must seek agency approval. Since the proposed action will utilize county lands and funds, it is an “agency action” requiring compliance with HRS Chapter 343 and HAR Title 11, Chapter 200, pursuant to which an environmental assessment is being prepared and processed.
HRS 343-5 Applicability and requirementsstates under item (c) (4) “A(n environmental impact) statement shall be required if the agency finds that the proposed action may have a significant effect on the environment…” The criteria by which the proposing agency makes the significance determination is provided in HAR 11- 200-12 (a) and (b) which states: “(a) In considering the significance of potential environmental effects, agencies shall consider the sum of the effects on the quality of the environment, and shall evaluate the overall and cumulative effects of an action. (b) In determining whether an action may have a significant effect on the environment, the agency shall consider every phase of a proposed action, the expected consequences,… and the…effects of the action.”
HAR 11-200-10 Contents of an environmental assessment includes “(9) Findings and reasons supporting the agency determination or anticipated determination…” The Draft EA provides this
10349-01Letter to Ms. Sandra Demoruelle Page 2March 6, 2020
information in Chapter 8 Findings and Determination. Neither HRS Chapter 343 nor HAR Title 11, Chapter 200 contain any requirement that all proposed wastewater systems require an EIS.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (16)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – October 3, 2018 8:17 a.m.
Dear Ms. Demoruelle:
Thank you for your October 3, 2018 8:17 a.m. comment message regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
The explanation given at the meeting pertained to Hawaii Administrative Rules (HAR) Title 11 Chapter 200-9.1Public review and response requirements for draft environmental assessments for anticipated negative declaration determination and addenda to draft environmental assessments. HAR 11-200-9.1(b) states that the “period for public review and for submitting written comments for both agency actions and applicant actions shall begin… Written comments to the proposing agency…shall be received or postmarked… (emphasis added). While there is no provision for receiving oral comments in the rules, the facilitator offered assistance by persons available at the meeting to put any oral comments attendees might wish to offer into writing.
HAR 11-200 has no requirement for conducting a public meeting in conjunction with preparing an environmental assessment. The meeting was voluntarily sponsored by the County of Hawaii Department of Environmental Management (DEM) to encourage public participation in the environmental review process.
Hawaii Revised Statutes (HRS) Chapter 343 Section 5 (a)(9)(A), states as follows: “(a) Except as otherwise provided, an environmental assessment (emphasis added) shall be required for actions that: ... (9) Propose any: (A) Wastewater treatment unit, except an individual wastewater system or a wastewater treatment unit serving fewer than fifty single-family dwellings or the equivalent…”. HAR Title 11, Chapter 200, which implements HRS Chapter 343, however, differentiates between “agency actions” that utilize state or county lands or funds and “applicant actions” for which an applicant must seek agency approval. Since the proposed action will utilize county lands and funds, it is an “agency action” requiring compliance with HRS Chapter
10349-01Letter to Ms. Sandra Demoruelle Page 2March 6, 2020
343 and HAR Title 11, Chapter 200, pursuant to which an environmental assessment is being prepared and processed.
HRS 343-5 Applicability and requirements states under (c) (4) A(n environmental impact) statement shall be required if the agency finds that the proposed action may have a significant effect on the environment…” The criteria by which the proposing agency makes the significance determination is provided in Hawaii Administrative Rules (HAR) Title 11 Section 200-12 (a) and (b) which states:”(a) In considering the significance of potential environmental effects, agencies shall consider the sum of the effects on the quality of the environment, and shall evaluate the overall and cumulative effects of an action. (b) In determining whether an action may have a significant effect on the environment, the agency shall consider every phase of a proposed action, the expected consequences,… and the…effects of the action.
HAR 11-200-10 Contents of an environmental assessment includes “(9) Findings and reasons supporting the agency determination or anticipated determination…” The Draft EA provides this in Chapter 8 Findings and Determination. Neither HRS Chapter 343 nor HAR Title 11, Chapter 200 contain any requirement that all proposed wastewater systems require an EIS.
The reference to “twin projects less than 11 miles apart, should be considered together” apparently refers to the proposed wastewater treatment plant to serve the Naalehu community. HAR 11-200-7 Multiple or phased applicant or agency actionsstates that “A group of actions proposed by an agency or an applicant shall be treated as a single action when (1) The component actions are phases or increments of a larger total undertaking, (2) An individual project is a necessary precedent for a larger project; (3) An individual project represents a commitment to a larger project; or (4) The actions in question are essentially identical and a single statement will adequately address the impacts of each individual action and those of the group of actions as a whole.” The wastewater projects at Pāhala and Naalehu are not phases or increments of a larger total undertaking, are not precedents or commitments for a larger project, nor are they identical. Hence, there is no requirement to consider them in a single environmental review document.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
10349-01Letter to Ms. Sandra Demoruelle Page 3March 6, 2020
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (17)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – October 6, 2018 9:00 a.m.
Dear Ms. Demoruelle:
Thank you for your October 6, 2018 9:00 a.m. comment message regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follows:
This is not a comment pertinent to the content requirements of the Draft EA for the Pāhala Large Capacity Cesspool Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (18)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment –October 10, 2018 10:50 p.m.
Dear Ms. Demoruelle:
Thank you for your October 10, 2018 10:50 p.m. comment message regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
There is no requirement under Chapter 343, Hawaii Revised Statutes, as amended, or Hawaii Administrative Rules (HAR), Title 11, Chapter 200 that proposed wastewater treatment plants must be reviewed through an environmental impact statement (EIS). Pursuant to Section 11-200-11.1, “(a) After preparing an environmental assessment and reviewing public and agency comments, if any, applying the significance criteria in section 11-200-12, if the proposing agency…anticipates that the proposed action is not likely to have a significant effect, it shall issue a notice of determination which shall be an anticipated negative declaration subject to the public review provisions of section 11-200-9.1.” As stated in the Pāhala Large Capacity Cesspool Replacement Draft EA Preface, this Draft EA was published in compliance with HAR 11-200.
HAR 11-200-10, Contents of an environmental assessment, does not specify a number of pages for an EA.
Other references are not comments to content requirements of the Draft EA for the Pāhala Large Capacity Cesspool Replacement project.
We appreciate your participation in the Draft EA process.
10349-01Letter to Ms. Sandra Demoruelle Page 2March 6, 2020
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (19)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – October 12, 2018 10:20 a.m.
Dear Ms. Demoruelle:
Thank you for your October 12, 2018 10:20 a.m. comment message regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our response follows:
This is not a comment to content requirements of the Draft EA for the Pāhala Large Capacity Cesspool Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (20)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – October 13, 2018 8:51 a.m.
Dear Ms. Demoruelle:
Thank you for your October 13, 2018 8:51 a.m. comment message regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our response follows:
This is not a comment to the content requirements of the Draft EA for the Pāhala Large Capacity Cesspool Replacement project
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (21)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – October 21, 2018 4:12 p.m.
Dear Ms. Demoruelle:
Thank you for your October 21, 2018 4:12 p.m. comment message regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our response follows:
This is not a comment to the content requirements of the Draft EA for the Pāhala Large Capacity Cesspool Replacement project
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (22)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – October 24, 2018 4:03 p.m.
Dear Ms. Demoruelle:
Thank you for your October 24, 2018 4:03 p.m. comment message regarding the County of HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
The County is aware of two existing culverts that allow stormwater to flow across the Māmalahoa Highway in the vicinity of the project. The first is a box culvert located at the intersection with Maile Street that conveys stormwater under the highway. The second culvert is located approximately 600 feet east of the Maile Street intersection and was used to conveysugar mill flume water across the highway for disposal.
The Draft EA Section 3.9.1 (a) states:
“The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM), Community Panel No. 155166 1800F, effective date September 29, 2017 shows 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-1is very close to the edge of the 500-year floodplain.
On April 16, 2018, in response to the pre-assessment notification, the State of Hawai‘i Department of Land and Natural Resources Engineering Division stated the responsibility for conducting research as to the flood hazard designation for the project site lies with the project proponent. Also on April 16, 2018 and in response to the pre-assessment notification, the
10349-01Letter to Ms. Sandra Demoruelle Page 2March 6, 2020
County of Hawai‘i Department of Public Works confirmed that the proposed treatment and disposal project site at Site 7 is designated as Zone X on the FIRM and is outside the 500-year floodplain.”
The relevant FIRM panel is reproduced in Appendix B as Figure 4-13.
This information will be repeated in the Final EA.
The Draft EA Section 3.23.2 (a), states:
“The proposed wastewater treatment and disposal facility would include an on-site drainage system to address stormwater surface runoff created by new impervious surfaces within the facility. The site would include a system to collect runoff via grated inlets or swales, and flows would be conveyed to on-site drainage detention systems, such as subsurface linear infiltration or depressed detention basins.”
This information will be repeated in the Final EA.
The preferred alternative (Site 7) slopes from approximately north to south (mauka to makai)such that, during rain events, surface flows pass through the existing orchard to the southern (makai) end where the flows eventually drain through the culvert located at the Maile Street-Māmalahoa Highway intersection to the areas below (makai) the highway. Most of the land surface area below the existing macadamia nut orchard contains little to no vegetation to absorb or slow these flows. The gradient of Site 7 and surrounding area results in this natural pattern of surface flows which also existed when the area was planted in sugar cane and is not considered flooding.
Based on the roadway flooding concerns expressed by the community during the Pahala public meetings held in December 2017 and October 2018, the State of Hawai‘i Department of Transportation (DOT) Hawai‘i District office was contacted to discuss drainage at the treatment and disposal facility project site and the culvert at the Maile Street and Māmalahoa Highway intersection. On February 20, 2019, the District office confirmed via telephone that the DOT owns and maintains the culvert at the Maile Street intersection, and that they have no record of the roadway being inundated by stormwater drainage during precipitation events at that location.
Stormwater runoff generated mauka of the treatment and disposal facility project site will be directed around the perimeter of the site via diversion swales that will convey flow back to the existing drainage pattern that flows to the existing culvert at Maile Street. During heavy rain events, stormwater may temporarily back up behind the culvert. There will be no changes to this culvert and the proposed treatment and disposal facility will not be located within the area of the culvert.
10349-01Letter to Ms. Sandra Demoruelle Page 3March 6, 2020
As stated in the Draft EA, the on-site stormwater management system would meet the requirements of Hawai‘i County Code (HCC), Chapter 27 Floodplain Management, Section 20, Standards for subdivisions and other developments (e) which mandates a site drainage plan to “comply with sections 27-20(a) and (b) and section 27-24, and shall include a storm water disposal system to contain run-off caused by the proposed development, within the site boundaries, up to the expected [design] storm event, as shown in the department of public works “Storm Drainage Standards”.”
To meet the requirements of HCC, Chapter 27, Section 20 (f), the project “shall not alter the general drainage pattern above or below the development”. Thus, for the design storm event, no increase in flow amount will be directed to either of the culverts at the highway as a result of the site development. A drainage study will be prepared during the design process to evaluate the improvements necessary to comply with HCC Chapter 27 requirements.
The wastewater treatment processes will be designed to accommodate the associated peak flows, including precipitation that falls on the area occupied by the aerated lagoon treatment system. The Draft EA Appendix B, Section 2.2 outlines the anticipated peak wastewater flows from the community, based on the applicable flow standard. The Draft EA Section 2.3.1, states the aerated lagoons will be lined to prevent water seepage through the bottom and sides of the lagoons. The Draft EA Appendix B, Section 5.3 shows the operational freeboard that will be available to contain and to equalize lagoon flows. In addition, the slow-rate land application groves will be designed to completely contain both peak effluent flows and precipitation from a 100-year, 24-hour storm event. A geotechnical engineering assessment of berm stability will be conducted during the design process. The tree groves will be designed in accordance with the EPA’s “Process Design Manual, Land Treatment of Municipal Wastewater Effluents”. Effluent will be applied at a hydraulic loading rate that is a small percentage of the percolation rate of the soil, ensuring sufficient capacity for assimilation of peak effluent flow rates and precipitation from the design storm event.
This information will be included in the Final EA
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
10349-01Letter to Ms. Sandra Demoruelle Page 4March 6, 2020
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (39)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – October 23, 2018 2:48 p.m.
Dear Ms. Demoruelle:
Thank you for your October 23, 2018 2:48 p.m. comment message regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
This is not a comment to the content requirements of the Draft EA for the Pāhala Large Capacity Cesspool Replacement project.
The attachment comments will be addressed under a separate cover.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (46)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588 Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – October 31, 2018 8:03 p.m.
Dear Ms. Demoruelle:
Thank you for your October 31, 2018 8:03 p.m. comment message regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our response follows:
This is not a comment pertinent to the content requirements of the Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng Project Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWD K. Rao, EPA C. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (45)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588 Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻū, HawaiʻiResponse to Comment – October 31, 2018 8:13 p.m.
Dear Ms. Demoruelle:
Thank you for your October 31, 2018 8:13 p.m. comment message regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our response follows:
Hawaiʻi Administrative Rules (HAR) Title 11 Chapter 200-10 Contents of an environmental assessment does not include a requirement for evaluating the fiscal impacts of a project on a County’s budget or ability to obtain funding.
The Nāʻālehu project is not the subject of the Draft EA for the Pāhala Large Capacity Cesspool Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Earl Matsukawa, AICPProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWD K. Rao, EPA C. Lekven, BC
B. Rosenberg, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (48) March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588 Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – October 31, 2018 11:39 a.m.
Dear Ms. Demoruelle:
Thank you for your October 31, 2018 11:39 a.m. comment message regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our response follows:
This is not a comment pertinent to the content requirements of the Draft EA for the Pāhala Large Capacity Cesspool Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng Project Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWD K. Rao, EPA C. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (47)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment –October 31, 2018 12:41 p.m.
Dear Ms. Demoruelle:
Thank you for your October 31, 2018 12:41 p.m. comment message regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our response follows:
This is not a comment pertinent to the content requirements of the Draft EA for the Pāhala LargeCapacity Cesspool Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (49)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588 Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – October 26, 2018 11:12 a.m.
Dear Ms. Demoruelle:
Thank you for your October 26, 2018 11:12 a.m. comment message regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our response follows:
This is not a comment pertinent to the content requirements Draft EA for the Pāhala Large Capacity Cesspool Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng Project Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWD K. Rao, EPA C. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (50)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – November 2, 2018 12:22 p.m.
Dear Ms. Demoruelle:
Thank you for your November 2, 2018 12:22 p.m. comment message regarding the County HawaiʻiDepartment of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our response follows:
This is not a comment pertinent to the content requirements of the Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (51)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588 Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – November 5, 2018 9:26 a.m.
Dear Ms. Demoruelle:
Thank you for your November 5, 2018 9:26 a.m. comment message regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project.
The Draft EA Appendix B Section 5.5 and Table 5.3 provides a conceptual planning level construction cost estimate of about $14.6 million for the secondary wastewater treatment and disposal facility only. Table 5.3 does not reflect the total cost of the Proposed Action and does not include planning, design, land acquisition, the collection system or past project costs. As stated in the Draft EA Section 2.1.2, the project may be funded by the State of Hawaiʻi Department of Health Clean Water State Revolving Fund which authorizes low interest loans for the construction of publicly owned wastewater treatment works and an EPA Special Appropriation Grant. This information will be included in the Final EA.
Hawaiʻi Administrative Rules (HAR) Title 11 Chapter 200-10 Contents of an environmental assessment does not include a requirement for evaluating the fiscal impacts of a project on a County’s budget or ability to obtain funding.
The cost estimate for the Nā‘ālehu project is not pertinent to the content requirements for the Draft EA for the Pāhala Large Capacity Cesspool Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng
10349-01Letter to Ms. Sandra Demoruelle Page 2March 6, 2020
Project Manager cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (52)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – November 6, 2018 11:51 a.m.
Dear Ms. Demoruelle:
Thank you for your November 6, 2018 11:51 a.m. comment message regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our response follows:
This is not a comment pertinent to the content requirements of the Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project.
The Draft EA Section 2.4 to 2.8 provides an evaluation of siting, treatment, and effluent management alternatives
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (53)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588 Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement Project District of Kaʻu, HawaiʻiResponse to Comment – November 8, 2018 11:52 a.m.
Dear Ms. Demoruelle:
Thank you for your November 8, 2018 11:52 a.m. comment message regarding the County Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project.
The Office of Environmental Quality Control The Environmental Notice dated November 8, 2018 indicated under status that the proponent is republishing the draft EA originally published September 23, 2018 and provided the following project description:
The County of Hawaiʻi Department of Environmental Management proposes to construct wastewater system improvements replacing the large capacity cesspools (LCCs) currently serving Pāhala, in order to comply with U.S. Environmental Protection Agency (EPA) regulations. The project improvements would include a new wastewater collection system located primarily within public streets in the Pāhala community, and a treatment and disposal system on land to be acquired by the County (TMK: 9-6-002: 018). The project would be partially funded by an EPA grant and by the Clean Water State Revolving Fund loan program. The proposed wastewater collection system is described in the Draft EA, and the existing LCCs and associated collection system would be abandoned.
A link was provided in the November 8 2018 TEN to the Draft EA:http://oeqc2.doh.hawaii.gov/EA_EIS_Library/2018-11-08-HA-Republished-DEA-Pahala-Community-Large-Capacity-Cesspool-Replacement.pdf. Section 2 of the Draft EA is the project description.
The Office of Environmental Quality Control The Environmental Notice dated September 23, 2018 provided the following project description:
10349-01Letter to Ms. Sandra Demoruelle Page 2March 6, 2020
The project improvements would include a new wastewater collection system located primarily within public streets in the Pāhala community, and a treatment and disposal system on land to be acquired by the County (TMK: 9-6-002: 018). The project would be partially funded by an EPA grant and by the Clean Water State Revolving Fund loan program.
The collection system would consist of approximately 12,120 linear feet of 8 to 12-inch diameter underground gravity flow piping in Maile,ʻIlima, Huapala,Hīnano, Hala, Puahala and Pīkake Streets. The treatment and disposal facility would occupy about 14.9 acres and consist of a headworks and an odor control unit, an operations building, four lined aerated lagoons, a subsurface flow constructed wetland to remove nitrogen with an adjacentdisinfection system to remove pathogens, and four slowrate land treatment basins for further treatment and disposal of the treated effluent. A perimeter security fence would enclose the entire facility. The existing LCCs and associated wastewater collection system would be abandoned.
The Purpose and Need for Action is included in the Draft EA Section 2.2.
HawaiʻiRevised Statutes (HRS) Chapter 343 Section 5 (a)(9)(A), states as follows: “(a) “Except as otherwise provided, an environmental assessment shall be required for actions that: (1) Propose the use of state or county lands or the use of state or county funds…” as well as, “(9) Propose any: (A) Wastewater treatment unit…”
The County of Hawaiʻi is the Proposing Agency for the Pāhala Large Capacity Cesspool Replacement Project.
HawaiʻiRevised Statutes (HRS) Section 343-5 Applicability and requirements states under item (c) (4) “A(n environmental impact) statement shall be required if the agency finds that the proposed action may have a significant effect on the environment…” The criteria by which the proposing agency makes the significance determination is provided in Hawaiʻi Administrative Rules (HAR) Title 11 Section 200-12 (a) and (b) which states: “(a) In considering the significance of potential environmental effects, agencies shall consider the sum of the effects on the quality of the environment, and shall evaluate the overall and cumulative effects of an action. (b) In determining whether an action may have a significant effect on the environment, the agency shall consider every phase of a proposed action, the expected consequences,… and the…effects of the action.”
HAR Section 11-200-10 Contents of an environmental assessment includes “(9) Findings and reasons supporting the agency determination or anticipated determination…” The Draft EA provides this in Chapter 8 Findings and Determination. Neither HRS Chapter 343 nor HAR Title 11, Chapter 200 contain any requirement that all proposed wastewater systems require an Environmental Impact Statement (EIS).
10349-01Letter to Ms. Sandra Demoruelle Page 3March 6, 2020
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (54) March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588 Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement Project District of Kaʻu, HawaiʻiResponse to Comment – November 13, 2018 12:40 p.m.
Dear Ms. Demoruelle:
Thank you for your November 13, 2018 12:40 p.m. comment message regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
This is not a comment pertinent to the content requirements of the Draft EA for the Pāhala Large Capacity Cesspool Replacement project.
The Nā‘ālehu project PER is not part of the Draft EA for the Pāhala Large Capacity Cesspool Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng Project Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWD K. Rao, EPA C. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (57)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – November 16, 2018 10:03 a.m.
Dear Ms. Demoruelle:
Thank you for your November 16, 2018 10:03 a.m. comment message regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our response follows:
The Draft EA Section 3.13.2 states:
“On April 23, 2018, as part of the pre-assessment consultation process, the FWS provided a letter (01EPIF00-2018-TA-0275) with information on various avoidance and minimization measures to avoid adverse impacts to listed species (see Appendix A).”
“Prior to finalization of this EA and initiation of the Proposed Action, EPA and the County of Hawai‘i will conclude consultation with FWS in accordance with Section 7 of the Endangered Species Act and will incorporate additional impact avoidance and minimization measures as necessary to result in a finding of Not Likely to Adversely Affect (NLAA) protected species.”
On December 21, 2018, the designated non-Federal representative for consultations under Section 7 of the Endangered Species Act, on behalf of the United States Environmental Protection Agency (EPA) and the County of Hawaiʻi, requested concurrence from the U.S. Fish and Wildlife Service (FWS) that the Pāhala Community Large Capacity Cesspool Replacement project is not likely to adversely affect federally-listed threatened and endangered species or critical habitat.
On February 19, 2019, the FWS provided a letter (REF 01EPIF00-2018-TA-0275; 01EPIF00-2019-I-0153) 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
10349-01 Letter to Ms. Sandra Demoruelle Page 2March 6, 2020
insignificant and therefore we concur that the Pahala Large Capacity Cesspool 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.”
This information will be included in the Final EA Section 3.13.2 and Appendix C.
The Nā‘ālehu wastewater treatment plant PER is not a part of the Draft EA for the Pāhala Large Capacity Cesspool Replacement project. Comments related to that document are not pertinent to the content requirements of the Draft EA for the Pāhala Large Capacity Cesspool Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola Cheng Project Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWD K. Rao, EPA C. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (58)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – November 2, 2018 12:14 p.m.
Dear Ms. Demoruelle:
Thank you for your November 2, 2018 12:14 p.m. comment message regarding the County HawaiʻiDepartment of Environmental Management’s (DEM) Draft Environmental Assessment(EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
Hawaii Revised Statutes (HRS) Section 343-5 Applicability and requirements (a) states “Except as otherwise provided, an environmental assessment shall be required for actions that: (1) Propose the use of state or county lands or the use of state or county funds…” as well as, “(9) Propose any: (A) Wastewater treatment unit…”
However, Hawaii Administrative Rules (HAR) Title 11, Chapter 200, which implements HRS Chapter 343, differentiates between “agency actions” - those proposed by an agency to utilize state or county lands or funds; and, “applicant” actions” – those for which an applicant requires approval from an agency.
The Pāhala Large Capacity Cesspool Replacement project is a proposal by an agency (DEM) to use County funding, thereby “triggering” the need for an EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
10349-01Letter to Ms. Sandra Demoruelle Page 2March 6, 2020
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (64)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588 Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement Project District of Kaʻu, HawaiʻiResponse to Comment – December 10, 2018 2:36 p.m.
Dear Ms. Demoruelle:
Thank you for your December 10, 2018 2:36 p.m. comment message regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
Hawaii Administrative Rules (HAR) 11-62-24 (b) requires County wastewater treatment works to be designed in accordance with County standards. If a county does not have design standards, then the design standards for the City and County of Honolulu shall be used. The County of Hawaii does not have design standards; therefore, the City and County of Honolulu standards are applicable to the Pāhala WWTP. The Draft EA Section 2.3.1 states that wastewater flow projections were developed for the treatment and disposal facility using the City and County of Honolulu wastewater standards, most recently updated during 2017. Based on these standards, the Pāhala treatment and disposal facility would be designed to provide an average dry weather flow capacity of 190,000 gallons per day (gpd), which would be sufficient capacity to allow closure of the two LCCs. The Draft EA Appendix B contains additional detail on the flow projections. The corresponding design peak day wet weather flow is 650,000 gpd. Future sewer main extensions and subdivisions will be accommodated, as capacity allows, on a first come, first served basis. Further, the wastewater treatment plant (WWTP) design will be expandable to not preclude treating future average dry weather flows up to 360,000 gpd (with a corresponding peak day wet weather flow of 1,260,000 gpd) to meet the future needs of the community in accordance with the requirements established in the Ka‘ū Community Development Plan Policy 120. This information will be repeated in the Final EA.
It should be noted that wastewater flows from a community are highly variable, and peak flow rates from small community wastewater collection systems are typically three to five times higher than the average flow rates. The City and County of Honolulu standards take this variability into account, and application of the standards results in conservatively-designed facilities that are protective of human health and the environment in anticipated operational conditions.
10349-01Letter to Ms. Sandra Demoruelle Page 2March 6, 2020
This information will be added to the Final EA.
Package plants are pre-manufactured treatment facilities that may be used to treat wastewater in small communities, or on individual properties. Typical flows for this technology range between 10,000 and 250,000 gallons per day (Metcalf and Eddy, 1991). Although they have the advantage of a small footprint and associated capital cost, these plants have limited storage and equalization capacity, require the addition of chemicals, and are operationally complex. They are energy intensive, and the solids produced must be properly handled and disposed. Package plants do not commonly achieve denitrification or phosphorus removal without supplemental unit processes. Often, package plants utilize proprietary equipment adding to operational costs and equipment availability issues when replacements are unavailable or the equipment becomesobsolete.
Because of the need for daily operations and maintenance, on-site chemical storage and chemical addition, mechanical complexity, lack of operational flexibility under changing conditions, energy consumption, and sludge handling concerns, package plants were removed from consideration for the Proposed Action.
The above information will be included in the Final EA, Section 2.8.2
Regardless of the treatment process, the proposed treatment facility will require a method to dispose of the treated effluent. As outlined in the Draft EA section 2.3.1, the Proposed Alternative will utilize a land application system. As stated in the Draft EA Section 2.8.3, several effluent management options were evaluated for feasibility as an alternative to land application. Options removed from consideration included ocean discharge, injection wells, water recycling, and drain (leach) field. Additional detail can be found in the Draft EA Appendix B, Section 3.1.6.
The Naalehu PER is not the subject of the Draft EA for the Pāhala Large Capacity Cesspool Replacement project.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
10349-01Letter to Ms. Sandra Demoruelle Page 3March 6, 2020
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (65) March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588 Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement Project District of Kaʻu, HawaiʻiResponse to Comment – December 10, 2018 3:01 p.m.
Dear Ms. Demoruelle:
Thank you for your December 10, 2018 3:01 p.m. comment message regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our response follows:
The Draft EA Section 3.15 states, on March 29, 2018, consultation was initiated for the project under the National Historic Preservation Act. The Draft EA Section 10 provides a list of the consulted parties. The Final EA Section 3.15 will include that the list of Native Hawaiian Organizations (NHO) was generated by the EPA from the U.S. Department of the Interior, Office of Native Hawaiian Relations, Native Hawaiian Organization (NHO) Notification List for NHPA Section 106 and HRS Chapter 6E compliance. Letters were sent to 14 NHOs during the pre-assessment consultation. No responses were received from these organizations.
On March 13, 2019, the HRS Chapter 6E determination and Section 106 review packet were submitted to SHPD along with a draft Archeological Inventory Survey (AIS). The SHPD response is pending. The Draft EA Section 3.15.2 states that prior to finalization of this EA and initiation of the Proposed Action, the Environmental Protection Agency (EPA) and the County of Hawai‘i will conclude consultation with SHPD in accordance with Section 106 of the NHPA and will incorporate additional impact avoidance and minimization measures as necessary to result in a finding of no adverse effects to historic properties.
The Final EA Section 7 will include that on September 26, 2018, a public notice was published in the Hawaii Tribune Herald and West Hawaii Today newspapers. The public notice was to advertise the October 10, 2018, public information meeting conducted by the County in the Pāhala at the Ka‘ū Gym Multi-Purpose Conference Room to discuss the availability of the Draft EA and process for submitting comments. The notice stated the second part of the meeting would address Section 106 of the National Historic Preservation Act of 1966, as amended (2006) involving consultation with Native Hawaiian Organizations and the Native Hawaiian descendants with ancestral lineal or cultural ties to, cultural knowledge or concerns for, and
10349-01Letter to Ms. Sandra Demoruelle Page 2March 6, 2020
cultural religious attachment to the proposed project area. Eight persons placed their names on a sign in sheet at the October 10, 2018 public meeting to contribute during the second part of the meeting dedicated to the Section 106 consultation. No comments or information were forthcoming during the Section 106 portion of the meeting.
The Naalehu projects are not the subject of the Pahala Large Capacity Cesspool Replacement Project Draft EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (66)March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588 Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement Project District of Kaʻu, HawaiʻiResponse to Comment – December 10, 2018 3:29 p.m.
Dear Ms. Demoruelle:
Thank you for your December 10, 2018 3:29 p.m. comment message regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
Hawaii Administrative Rules (HAR) 11-62-24 (b) requires County wastewater treatment works to be designed in accordance with County standards. If a county does not have design standards, then the design standards for the City and County of Honolulu shall be used. The County of Hawaii does not have design standards; therefore, the City and County of Honolulu standards are applicable to the Pāhala WWTP. The Draft EA Section 2.3.1 states that wastewater flow projections were developed for the treatment and disposal facility using the City and County of Honolulu wastewater standards, most recently updated in 2017. Based on these standards, the Pāhala treatment and disposal facility would be designed to provide an average dry weather flow capacity of 190,000 gallons per day (gpd) which would be sufficient capacity to allow closure of the two LCCs. The Draft EA Appendix B contains additional detail on the flow projections. The corresponding design peak day wet weather flow is 650,000 gpd. Future sewer main extensions and subdivisions will be accommodated, as capacity allows, on a first come, first served basis. Further, , the wastewater treatment plant (WWTP) design will be expandable to not preclude treating future average dry weather flows up to 360,000 gpd (with a corresponding peak day wet weather flow of 1,260,000 gpd) to meet the future needs of the, in accordance with the requirements established in the Kaʻū Community Development Plan Policy 120.
Further, The Draft EA, Appendix B states the proposed treatment facility will accommodate modification within the proposed 14.9-acre site for the future expansion of the service area.
It should be noted that wastewater flows from a community are highly variable, and peak flow rates from small community wastewater collection systems are typically three to five times higher than the average flow rates. The City and County of Honolulu standards take this variability into account, and application of the standards results in conservatively-designed
10349-01Letter to Ms. Sandra Demoruelle Page 2March 6, 2020
facilities that are protective of human health and the environment in anticipated operational conditions. This information will be added to the Final EA.
Package plants are pre-manufactured treatment facilities that may be used to treat wastewater in small communities or on individual properties. Typical flows for this technology range between 10,000 and 250,000 gallons per day (Metcalf and Eddy, 1991). Although they have the advantage of a small footprint and associated capital cost, these plants have limited storage and equalization capacity, require the addition of chemicals, and are operationally complex. They are energy intensive, and the solids produced must be properly handled and disposed. Package plants do not commonly achieve denitrification or phosphorus removal without additional unit processes. Often, package plants utilize proprietary equipment adding to operational costs and equipment availability issues when replacements are unavailable or the equipment becomesobsolete.
Because of the need for daily operations and maintenance, on-site chemical storage and chemical addition, mechanical complexity, lack of operational flexibility under changing conditions, energy consumption and sludge handling concerns, packaged plants were removed from consideration for the Proposed Action.
The above information will be included in the Final EA, Section 2.8.2
Regardless of the treatment process, the proposed treatment facility will require a method to dispose of the treated effluent. As outlined in the Draft EA section 2.3.1, the Proposed Alternative will utilize a land application system. As stated in the Draft EA Section 2.8.3, several effluent management options were evaluated for feasibility as an alternative to land application. Options removed from consideration included ocean discharge, injection wells, water recycling, and drain (leach) field. Additional detail can be found in the Draft EA Appendix B, Section 3.1.6.
The Naalehu project is not the subject of the Pāhala Large Capacity Cesspool Replacement Project Draft EA.
We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
10349-01Letter to Ms. Sandra Demoruelle Page 3March 6, 2020
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (75) March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588 Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement Project District of Kaʻu, HawaiʻiResponse to Comment – December 10, 2018 4:38 p.m.
Dear Ms. Demoruelle:
Thank you for your December 10, 2018 4:30 p.m. facsimile comment message regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment(EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow:
Pages 1 to 13 This is not a comment pertinent to the contents of the Draft EA for the Pāhala Large Capacity Cesspool Replacement project.
Page 14 The treatment and disposal facility for the Pāhala Large Capacity Cesspool Replacement project will not provide treated effluent to reuse quality which could be used to irrigate macadamia nut trees. This information will be repeated in the Final EA.
Pages 15 to 19 This is not a comment pertinent to the contents of the Draft EA for the Pāhala Large Capacity Cesspool Replacement project.
Project information, including US Environmental Protection Agency (USEPA) compliance dates, project updates, schedules and milestones can be found on the USEPA website at: https://www.epa.gov/uic/county-hawaii-administrative-order-consent-closure-cesspools-pahala-and-naalehu.
We appreciate your participation in the Draft EA process.
10349-01Letter to Ms. Sandra Demoruelle Page 2March 6, 2020
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
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1907 S. Beretania Street, Suite 400 •Honolulu, Hawaii •96826 •(808) 946-2277
10349-01 ref (23a) March 6, 2020
Ms. Sandra Demoruelle P.O. Box 588 Naalehu, HI 96772
Subject: Draft Environmental Assessment (EA) for thePāhala Large Capacity Cesspool Replacement ProjectDistrict of Kaʻu, HawaiʻiResponse to Comment – USPS October 23, 2018
Dear Ms. Demoruelle:
Thank you for your October 23, 2018 comments sent via the US Postal Service (USPS)regarding the County of Hawaiʻi Department of Environmental Management Draft Environmental Assessment (EA) for the Pāhala Large Capacity Cesspool Replacement project. Our responses follow (note that the page numbers referenced are “as received” with Page 1 being the first page of your comment submittal):
Pages 2-4:
The Draft EA Section 2.7 provides a the discussion of the criterion used to evaluate various sites for the treatment and disposal facility, including appropriate site characteristics, site accessibility as it relates to the various requirements of the Administrative Order on Consent, and environmental impacts. Further, the Draft EA Section 2.8 discusses the various site alternatives which were considered for the PER and then no longer considered as they contained “fatal flaws”.
This information will be repeated in the Final EA.
Section 2.1.4 of the Draft EA provides a history of wastewater management for Pāhala. As stated, in 2003 C. Brewer requested assistance from the County to close their large capacity cesspools as required by the Environmental Protection Agency. Section 2.14 discussed that, around 2006, C. Brewer requested that the County construct and maintain a new and improved sewer system for the Pāhala community. A County Council Resolution approved the C. Brewer request. In anticipation of C. Brewer's dissolution, the company proposed, and the County agreed in April 2007, to enter into a formal agreement to construct and maintain a new and improved community sewer system or assume maintenance and required service of the existing systems by April 30, 2010. The Final EA will clarify that 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 for specific private properties in Pāhala and
10349-01Letter to Ms. Sandra Demoruelle Page 2March 6, 2020
Nāʻālehu. It was agreed, if the County did not complete its’ portion of the work by April 30, 2010, it 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, the project includes connecting these C. Brewer laterals, which may now need to be replaced.
As outlined in the Draft EA Section 2.1.3, the County has been discussing the need for a new collection system, treatment and disposal facility to replace the existing collection system and large capacity cesspools (LCCs), with the community since 2004.
On December 13, 2008 and April 25, 2010, community meetings sponsored by Councilman Guy Enriques were held at the Nā‘ālehu and Pāhala Community Centers, respectively, to discuss the Nā‘ālehu and Pāhala Large Capacity Cesspool Replacement project. As part of the meetings, an informational handout prepared by the County Wastewater Division, provided a history of the project documenting that, in 2004, Mayor Kim’s office used a ballot system to get input from property owners regarding different wastewater treatment/disposal alternatives for those property owners connected to the LCCs who would no longer be served by the C. Brewer system after LCC closure. As reported in the Draft EA Section 2.1.4, 87 percent of the returned ballots were in favor of the installation of a new sewer collection system and a treatment and disposal system to be operated and maintained by the County. The handouts indicated that Mayor Kim’s office advised the property owners the County would move forward with a new system for Nā‘ālehu and Pāhala on November 5, 2004. Additionally, the handouts stated that public meetings were held in both Nā‘ālehu and Pāhala in November 2006 to discuss the wastewater system alternatives and the biggest challenge to date had been finding suitable land for siting a wastewater treatment/disposal facility in Pāhala. The handouts also stated that all properties that become accessible to the new sewer system would be required to connect in accordance with Hawaiʻi County Code Chapter 21.
This information will be included in the Final EA.
The Draft EA Sections 4.1.1 Past, Present, and Reasonably Foreseeable Actions, 4.1.2 Actions Considered but Excluded from Analysis, 6.2.2 Ka‘ū Community Development Plan, and 7 Public Participation, references the Ka‘ū Community Development Plan (CDP) as considered in the preparation of the Draft EA.
The Ka‘ūCDP Policy 90 states “Implement protocols for receiving community input at meetings in Ka‘ū during capital project siting and design.
Notwithstanding that the Ka‘ū Community Development Plan was adopted in October 2017 (Ordinance No. 2017-66), the information above shows the County presented information to and received input from the Pāhala Community at meetings in Ka‘ū during project siting and conceptual design.
10349-01Letter to Ms. Sandra Demoruelle Page 3March 6, 2020
Pages 4-6
The Nāʻālehu WWTP and Lono Kona project comments are not pertinent to the content of the Draft EA for the Pāhala Large Capacity Cesspool Replacement project.
Page 7: There is no requirement to publish notices of public meetings like the “talk story” sessions you mentioned in the Office of Environmental Quality Control (OEQC) The Environmental Notice.OEQC may publish such notices on a space available basis.
Page 8-9:HawaiʻiRevised Statutes (HRS) Section 343-5 Applicability and requirements states under item (c) (4) “A(n environmental impact) statement shall be required if the agency finds that the proposed action may have a significant effect on the environment…” The criteria by which the proposing agency makes the significance determination is provided in Hawaiʻi Administrative Rules (HAR) Title 11 Section 200-12 (a) and (b) which states: “(a) In considering the significance of potential environmental effects, agencies shall consider the sum of the effects on the quality of the environment, and shall evaluate the overall and cumulative effects of an action. (b) In determining whether an action may have a significant effect on the environment, the agency shall consider every phase of a proposed action, the expected consequences,… and the…effects of the action.”
HAR Section 11-200-10 Contents of an environmental assessment includes “(9) Findings and reasons supporting the agency determination or anticipated determination…” The Draft EA provides this in Chapter 8 Findings and Determination. Neither HRS Chapter 343 nor HAR Title 11, Chapter 200 contain any requirement that all proposed wastewater systems require an Environmental Impact Statement (EIS).
The Nāʻālehu WWTP comments are not pertinent to the content of the Draft EA for the Pāhala Large Capacity Cesspool Replacement project.
See EPA response to comment section.
Retained to address EA required for CIP.
HRS §343-5-1 states (a) Except as otherwise provided, an environmental assessment shall be required for actions that: (1) Propose the use of state or county lands or the use of state or county funds, other than funds to be used for feasibility or planning studies for possible future programs or projects that the agency has not approved, adopted, or funded. The CIP program reviewed annually by the County Council is not yet funded when passed.
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HAR 11-200-2 definition states: "Action" means any program or project to be initiated by an agency or applicant. Further, HAR 11-200 states "Agency" means any department, office, board, or commission of the state or county government which is part of the executive branch of that government. The County Council is part of the legislative, not the executive, branch of the County.
Page 10: On March 15, 2018, the County mailed a letter stating a Draft EA is being prepared for the County the Pāhala Large Capacity Cesspool Replacement project along with Pre-Assessment documents to a total of 47 agencies, elected officials and utilities requesting comments prior to preparation of the Draft EA. In addition, on March 29, 2018, the County mailed Pre-Assessment documents to 14 Native Hawaiʻi an Organizations requesting comments prior to preparation of the Draft EA. The Draft EA Summary shows the list of those consulted prior to preparation of the Draft EA. The Draft EA Section 10 shows those agencies, elected officials, utilities and Native Hawaiʻi an Organizations that provided comments. Finally, the Draft EA Appendix A includes reproductions of the comments and responses to those making comments.
In addition, the County submitted required information and documents to the OEQC related to the Draft EA. Based on the County provided information, on September 23, 2018, notice of availability of the Draft EA was published in the Office of Environmental Quality Control The
Environmental Notice. Subsequently, on September 26, 2018, a public notice was published in the +DZDLұL7ULEXQH+HUDOG,:HVW+DZDLұL7RGD\newspapers, and the online .Dµnj1HZV%ULHIThe public notice was to announce the October 10, 2018 public information meeting to be conducted by the County in Pāhala to discuss the availability of the Draft EA and process for submitting comments. The notice stated that the second part of the October 10th meeting was to address Section 106 of the National Historic Preservation Act (NHPA) involving consultation with Native Hawaiʻian Organizations (NHOs) and Native Hawaiʻian descendants with ancestral lineal or cultural ties or cultural knowledge or concerns, or religious attachment to the proposed project area. During the October 10th meeting attendees were invited to provide information about the proposed project area.
On November 6, 2018, 11 copies of the Draft EA were delivered to the public libraries in Pāhala and Nāʻālehu. Subsequently, notice of availability of the Draft EA was republished on November 8, 2018 and the comment period ended on December 10, 2018. The Final EA will include the comments received and responses provided in Appendices F and G.
This information will be included in the Final EA.
The Draft EA for the Nāʻālehu project is not the subject of the Draft EA for the Pāhala Large Capacity Cesspool Replacement project.
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Page 11: The County Clerk has confirmed that Resolution 412 was not voted on by the County Council.
The Draft EA for the Pāhala Large Capacity Cesspool Replacement project was jointly prepared by the US Environmental Protection Agency (EPA) and the County of Hawaiʻi to address both the National Environmental Policy Act (NEPA) and Hawaiʻi Environmental Policy Act (HEPA). Please refer to Appendix F for EPA’s response. After the procedural requirements of Section 106 of the National Historic Preservation Act have been completed and comments to the Draft EA have been addressed, the EPA and the County will issue a Finding of No Significant Impact and Final EA.
See response to Page 8 above.
Page 12: HAR 11-200-7 Multiple or phased applicant or agency actionsstates that “A group of actions proposed by an agency or an applicant shall be treated as a single action when (1) The component actions are phases or increments of a larger total undertaking, (2) An individual project is a necessary precedent for a larger project; (3) An individual project represents a commitment to a larger project; or (4) The actions in question are essentially identical and a single statement will adequately address the impacts of each individual action and those of the group of actions as a whole.” The wastewater projects at Pāhala and Nāʻālehu are not phases or increments of a larger total undertaking, are not precedents or commitments for a larger project, nor are they identical. Hence, there is no requirement to consider them in a single environmental review document.
See responses to Pages 2-4 and 10 above. The Draft EA Section 7 also documents the 5 public meetings held in Pāhala December 12, 13 and 14, 2017 to discuss the Pāhala Large Capacity Cesspool Replacement project.
On September 10, 2018, letters containing information on the availability of the Draft EA, the comment period, and the October 10, 2018 meeting were mailed to property owners with C. Brewer lines and newly-accessible property owners. On October 26, 2018 letters were mailed to property owners with C. Brewer lines and newly-accessible property owners informing them of the extension of the public comment period to December 10, 2018.
This information will be included in the Final EA.
The Draft EA Section 7 will be revised to add that, on March 21, 2019, the County held another meeting in Pāhala which included a presentation to provide information on financing sources available to owners of parcels which would become accessible to the new County collection system. The purpose of the meeting was to fulfill a County commitment made in October, 2018
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to research financing options available to the newly accessible residents of the Pāhala Community by March, 2019.See also response to Page 4 above.
The Draft EA, Section 2.8.2(a), discusses use of a community septic tank.
Further details for the use of community septic tanks are also provided in the Draft EA, Appendix B, Section 7.5.1 and 7.5.2, including the need for a Department of Health (DOH) variance from HAR 11-62-23.1 requirements (which must be renewed every five years), and the need to provide for additional flow.
Page 13, A and attachment A Page 31: HRS Chapter 343 Section 5 (a)(9)(A), states as follows: “(a) Except as otherwise provided, an environmental assessment (emphasis added) shall be required for actions that: ... (9) Propose any: (A) Wastewater treatment unit, except an individual wastewater system or a wastewater treatment unit serving fewer than fifty single-family dwellings or the equivalent…”. HAR Title11, Chapter 200, which implements HRS Chapter 343, however, differentiates between “agency actions” that utilize state or county lands or funds and “applicant actions” for which an applicant must seek agency approval. Since the proposed action will utilize county lands and funds, it is an “agency action” requiring compliance with HRS Chapter 343 and HAR Title 11, Chapter 200, pursuant to which an environmental assessment is being prepared and processed.
Thus, the project description published by the OEQC in the September 23, 2018 issue of The
Environmental Notice OEQC was correct.
Page 13 B and Attachment B Pages 32-34:HAR Title 11 Chapter 200-10 Contents of an environmental assessment does not include a requirement for evaluating the fiscal impacts of a project on a County’s budget or ability to obtain funding.
Page 13 C and Attachment D Page 35: The public outreach subcontractor did not prepare the Draft EA.
Page 13 D and Attachment D Pages 36-42: This is not a comment pertinent to the content requirements of the Draft EA for the Pāhala Large Capacity Cesspool Replacement project; the Draft EA Section 5 includes federal cross cutter analysis for both the Pāhala Large Capacity Cesspool Conversion and Pāhala Wastewater Collection System parts that may also be funded by the State of Hawaiʻi DOH Clean Water State Revolving Fund (CWSRF).
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Page 13 E and Attachment E Page 43: This is not a comment pertinent to the content requirements of the Draft EA for the Pāhala Large Capacity Cesspool Replacement project.
Page 14 F and Attachment F Page 44:The Kealakehe Aeration Upgrade project is not a comment pertinent to the content requirements of the Draft EA for the Pāhala LCC Replacement project.
The Draft EA Appendix B is a Preliminary Engineering Report for the wastewater treatment plant. Table 5.3, Section 5.5 of Appendix B provides a conceptual planning level construction cost estimate of about $14.6 million for the secondary wastewater treatment and disposal facility only. Table 5.3 does not reflect the total cost of the Proposed Action and does not include planning, design, land acquisition, the collection system or past project costs. As stated in the Draft EA Section 2.1.2, the project may be funded by the State of HawaiʻiDepartment of Health Clean Water State Revolving Fund which authorizes low interest loans for the construction of publicly owned wastewater treatment works and an EPA Special Appropriation Grant. This information will be included in the Final EA.
The Final EA will include the Final PER and related construction cost estimates for the PāhalaLCC Replacement project.
See also responses to Pages 8-9, 12, 13 A and 13 D above.
Page 14 G and Attachment G Pages 45-48: The Elementary School Complex, the portion of campus closest to the treatment and disposal facility within the Ka‘ū High and Pāhala Elementary School campus, lies more than ½ mile directly or about 1 miles away from the proposed treatment and disposal facility by road. From the school, one must travel on a portion of the school parcel and on 5 streets to reach the fenced wastewater treatment and disposal facility. The intervening streets access or abut residential parcels and other land uses. The distance and intervening land uses show the treatment and disposal facility is not located in close proximity to a school facility. This information will be included in the Final EA.
Page 14 H and Attachment H Pages 49-50: The Draft EA Section 4 discusses the Cumulative effects of the project.
The Nāʻālehu WWTP and its’ proximity to the Nāʻālehuschool are not comments pertinent to the content requirements of the Draft EA for the Pāhala Large Capacity Cesspool Replacement project.
See response to Page 14 G above
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Page 14 I and Attachment I Pages 51-59: The Draft EA Section 2.8 discusses wastewater treatment alternatives. Effluent flows greater than 1,000 gallons per day are subject to Hawaiʻi’s Underground Injection Control (UIC) rules. Use of a small capacity system to treat the wastewater generated by each privately-owned parcel in the community currently served by the County operated LCCs would likely necessitate siting multiple units within private property. As outlined in the Draft EA, Appendix B Section 7.5.4, issues associated with individual wastewater systems include:
x locating the treatment units within developed private parcels, many of which are small (less than 10,000 square feet) and significantly improved;
x insufficient land area within developed private parcels to effectively use/dispose of treated effluent without impacting adjacent parcels; andxsoil conditions and subsurface geology unsuitable for effluent disposal compliant with HAR 11-62-34 requirements, potentially necessitating import fill soils or elevated mound systems.
This information will be repeated in the Final EA.
Additional issues that would need to be addressed include: access for equipment, ownership of the units, and operation and maintenance of the units in this remote location.
This information will be added to the Final EA, Section 2.8.2.
The financial impact of the project on individual newly accessible property owners was raised by the community during the December 2017 public meetings as summarized in Section 7 of the Draft EA and again during the October 10, 2018 meeting. Although not required by HAR Title 11, Chapter 200, the Department of Environmental Management (DEM) voluntarily convened an additional public meeting on March 21, 2019 to gain further input from newly accessible property owners and fulfill a commitment made in October 2018 to research and provide financing options available for the newly accessible residents of the Pāhala Community to pursue.
Programs discussed included:
x US Department of Housing and Urban Development (HUD) with County of HawaiʻiOffice of Housing and Community Development Residential Repair Program -Community Block Grant Program, and x US Department of Agriculture - Rural Development (USDA-RDA) Program.
As noted during the 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 Chapter §342D to establish a low interest loan program offering financial
10349-01Letter to Ms. Sandra Demoruelle Page 9March 6, 2020
assistance to cesspool owners to connect to wastewater treatment systems approved by the Department of Health was also discussed; however, this bill was subsequently not passed during the 2019 legislative session.
This information will be included in the Final EA.
Page 15 J and Attachment J Page 60: The proposed Pāhala wastewater treatment plant (WWTP) 14.9-acre project site has been developed to provide the necessary land area for the facilities needed to treat the incoming flows and to dispose the treated effluent from the treatment processes. The proposed project site minimizes the use of the adjacent lands which contain a commercial macadamia orchard. A larger project site is not required. The special permit requirement applies to the proposed WWTP parcel only, not to the proposed utility easements. The Draft EA Section 2.10.1 states the County will apply for the required special permit through the Planning Commission.
Pages 17- 30: See response to Pages 2-15 above.
Page 31-62 (Marked A-J): These are duplicates of some of your other comments, attached as reference material supporting the comments provided on pages 13-15 and duplicated on pages 28-30, to which we’ve responded. Responses to each were sent to you under separate cover and will also be included in Appendix G of the Final EA.
For clarity:
Page 31 is Attachment A for both Pages 13 and 28: See response to Page 13 A above.
Pages 32-34 are Attachment B for both Pages 13 and 28: See response to Page 13 B above.
Page 35 is Attachment C for both Pages 13 and 28: See response to Page 13 C above.
Pages 36-42 are Attachment D for both Pages 13 and 28: See response to Page 13 D above.
Page 43 is Attachment E for both Pages 13 and 28: See response to Page 13 E above.
Page 44 is Attachment F for both Pages 14 and 29: See response to Page 14 F above.
Pages 45-48 is Attachment G for both Pages 14 and 29: See response to Page 14 G above.
Pages 49-50 are Attachment H for both Pages 14 and 29: See response to Page 14 H above.
Pages 51-59 are Attachment I for both Pages 14 and 29: See response to Page 14 I above.
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Pages 60-62 are Attachment J for both Pages 15 and 30: See response to Page 15 J above.
Page 63: The Pāhala and Nāʻālehu communities are not a single community, but rather are two distinct communities that are located in different drainage basins. The Pāhala community is located about 11 miles north of the Nāʻālehu community. The US Geological Survey topographic maps show the two communities are separated by five drainage gulches: Hionamoa, Moaula, Punaluu, Nicole and Hulea. The topographic map shows these five gulches drain in a generally west to east direction. These same maps show the Alapai Gulch located adjacent to the western edge of the Nāʻālehu community drains from north to south. Thus, the distance, separation and topographic configuration of Hawaiʻi Island shows the two communities are not a single entity subject to a single project under federal and State environmental laws, including analysis of impacts.
The Pāhala and Nāʻālehu LCC Replacement Projects are not connected to each other and arephysically separated by a distance of 11 miles. Separate EA processes are being conducted for each community’s project. Cumulative impacts will be considered for connected projects as required by HRS 343.
Consultation and informational meetings such as the ones held regarding connected actions within appropriate geographic boundaries for this project on October 8 through 10, 2018 are not mandated by and do not violate NEPA.
Pages 64 to 66: On October 19, 2018, the US EPA replied to this request stating, there was no rationale provided why the request for “consulting party” status was appropriate for this project. As such, the request for “consulting party” status under the National Historic Preservation Act was denied. Further, the EPA stated the Nāʻālehu LCC replacement is a separate project that is not part of the proposed action currently subject to environmental review by EPA. Comments regarding the NāʻālehuLCC Replacement project are not pertinent to the content requirements for the Pāhala LCC Replacement Project Draft EA.
Page 67: EPA has provided a response to your request under NEPA and the National Historic Preservation Act requirements. HRS 343 and HAR 11 200 have no requirements or definitions related to consulted party status for an EA.
Pages 68 to 96: These are duplicates of some of your other comments, to which we’ve responded. Responses to each were sent to you under separate cover and will also be included in Appendix E of the Final EA.
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We appreciate your participation in the Draft EA process.
Sincerely,
Keola ChengProject Manager
cc: W. Kucharski, COH DEMD. Beck, COH WWDS. Mendonca, COH WWDK. Rao, EPAC. Lekven, BC P. Goodwin, ERG
PAHALA 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 ............................................................ 1
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)............................................... 39
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) ................................................................................ 50
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 .......................................................................... 81
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
6.2 Action Items under the Preferred Alternative ..................................................... 95
7. Consultation .......................................................................................... 97
7.1 Early Consultation ........................................................................................... 97
7.2 Community Outreach ...................................................................................... 98
7.3 Draft EID Public Review Period ......................................................................... 99
7.4 Amended EID Public Review Period .................................................................. 99
8. References ............................................................................................. 100
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List of Figures
Figure 1 Location Map ........................................................................................ 7
Figure 2 Alternative 1 Site Plan ......................................................................... 10
Figure 3 WWTP Overall Site Plan ....................................................................... 13
Figure 4 WWTP Operations Building Floor Plan ................................................... 14
Figure 5 In-Channel Cylindrical System .............................................................. 15
Figure 6 Aerated Grit Chamber .......................................................................... 16
Figure 7 Granular Activated Carbon Scrubber ..................................................... 17
Figure 8 Calcium Hypochlorite Feed System ....................................................... 18
Figure 9 Subsurface Drip Concept for Pāhala ...................................................... 20
Figure 10 Alternative 2 Site Plan ......................................................................... 25
Figure 11 Alternative 3 and 4 Site Plan ................................................................ 27
Figure 12 Typical Septic Tank System .................................................................. 30
Figure 13 Typical IWS with Absorption Tank ........................................................ 32
Figure 14 Typical IWS with Seepage Pit ............................................................... 33
List of Tables
Table 1.1 IWS Percolation Rate and Required Area ............................................... 34
Table 5.1 Demographic, Economic and Social Characteristics of Pāhala and Hawai'i
County ............................................................................................... 86
List of Appendices
A.Preliminary Engineering Report
B.Archeological Literature Review ReportC. Early Consultation Comments and Responses
D.Public Outreach Materials
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1.Introduction
1.1 Background
The Revised Administrative Order on Consent (Revised AOC) (Docket No. SDWA-UIC-AOC-2017-
0002, effective date August 22, 2022 Large Capacity Cesspool Closure (LCC) requirements for
Pāhala outlines that an Environmental Information Document (EID) must be prepared by the
County of Hawai'i for US Environmental Protection Agency (EPA) approval within 180 days of the
approval of the Pāhala Preliminary Engineering Report (PER), to meet Federal Environmental
Review Requirements.
The Revised 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 Revised 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 Revised 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 PreservationAct 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.
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
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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 Revised AOC and the No Action
alternative be evaluated for implementation in the Pāhala community.
This project may be funded by the State of Hawaiʻi Department of Health (DOH) Clean Water
State Revolving Fund (CWSRF) Program. 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 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.
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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)9-6-002:024 (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
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
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.
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5 Pāhala Large Capacity Cesspool Closure
Environmental Information Document
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 revised AOC that became effective on August 22, 2022 requires the LCCs to be closed
no later than July 21, 2026.
As of August 22, 2022, the County of Hawai'i and the EPA voluntarily entered into a Revised
Administrative Order of Consent (Revised 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 Revised 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.
6 Pāhala Large Capacity Cesspool Closure
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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 Revised 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 Revised 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 Revised 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.
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8 Pāhala Large Capacity Cesspool Closure
Environmental Information Document
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
9 Pāhala Large Capacity Cesspool Closure
Environmental Information Document
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+ acres would remain as the macadamia orchard which would be a vailable 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
12 Pāhala Large Capacity Cesspool Closure
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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
13 Pāhala Large Capacity Cesspool Closure
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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
14 Pāhala Large Capacity Cesspool Closure
Environmental Information Document
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.
15 Pāhala Large Capacity Cesspool Closure
Environmental Information Document
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
Environmental Information Document
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.
17 Pāhala Large Capacity Cesspool Closure
Environmental Information Document
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
18 Pāhala Large Capacity Cesspool Closure
Environmental Information Document
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.
19 Pāhala Large Capacity Cesspool Closure
Environmental Information Document
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.
20 Pāhala Large Capacity Cesspool Closure
Environmental Information Document
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.
21 Pāhala Large Capacity Cesspool Closure
Environmental Information Document
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-inch diameter pipelines. The house laterals in
Pāhala connect to the 4-inch lines which discharge into the 6-inch lines that transmit the
untreated sewage 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 fractures, open joints, holes and sources of inflow. Smoke testing involves the
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 the ground
where sewer line tweaks or defects may exist. The purpose of the smoke is to assist in locati ng
pipe defects and the entry points of storm and other surface waters into the sewers.
Residents of the specific area for testing 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 Street. 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 the 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.
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23 Pāhala Large Capacity Cesspool Closure
Environmental Information Document
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 Revised AOC sets forth that the County Hawai‘i must administer a more active
management strategy than is typically found in Hawai'i IWS. The Revised 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;
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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.
Septic 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 soil 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 PER 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 perforated 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.
In December 2017, a total of five community outreach sessions were conducted in the Pāhala
community. A public information meeting for the Draft EA was held in October 2018. A total of five community outreach sessions to discuss the Revised AOC were conducted in the Pahala and
Naalehu communities between March 2022 and September 2023. The fifth session, held on
September 28, 2023, was conducted specifically to inform the community of the preparation of
this EID and the criteria of its analysis. A recording of the meeting and the presentation slides
are available for viewing on the CoH-DEM website.
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.
In December 2017, a total of five community outreach sessions were conducted in the Pāhala
community. A public information meeting for the Draft EA was held in October 2018. A total of
five community outreach sessions to discuss the Revised AOC were conducted in the Pahala and
Naalehu communities between March 2022 and September 2023. The fifth session, held on
September 28, 2023, was conducted specifically to inform the community of the preparation of
this EID and the criteria of its analysis. A recording of the meeting and the presentation slides
are available for viewing on the CoH-DEM website.
(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 restored 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.
Alternatives 3 and 4
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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
resources within the general Project Area on a seasonal basis. These introduced rodents are deleterious to native ecosystems and native faunal species.
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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 been slightly modified from the 2020 FEA; however the project area and activities remain
consistent.
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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. This 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,
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.
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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. 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.
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
National Historic Preservation Act (NHPA) – if triggered – and, to incorporate additional
impact avoidance and minimization measures if required for the construction of the IWS.
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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. Please let me know
if you need further adjustments or information.
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
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
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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 risk 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.
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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
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.
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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.
Alternative 2
Although the package plant in Alternative 2 would allow additional facilities, use 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.
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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
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.
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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.
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.
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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.
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 Revised AOC (Docket No. SDWA-UIC-AOC-2017-0002, effective date August 22, 2022) 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 Revised 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.
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 agreements, and compliance with current County and State codes.
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.
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,
including County Council approval and obtaining of new resolutions which could have severe
ramifications for the current project timeline.
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6.1.2 Community Preference
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.
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.
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. In addition to being considered a temporary means of
wastewater disposal, it is noted that the package plant facility and new collection system would
provide higher level of wastewater treatment. The package plant facility would provide
wastewater treatment and management within the community while the County remains
protective of public health and safety.
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;
3. Close and abandon two LCCs, according to DOH closure procedures; and
4. Abandon the existing wastewater collection system in place.
The current action items involve seeking the Mayor's concurrence with the Wastewater Division
Recommendation, approval from the DEM Director, and the establishment of a consultant
selection committee. The chosen consultant will be tasked with completing the WWTP design
and implementation plan within 6-7 months, followed by the wastewater collection system
design within the same timeframe. The project aims to adhere to a 2-year construction
schedule.
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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, 2023. No comments were received during the
second public and agency comment period for the subject EID.
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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.
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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.
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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.
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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
22
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Proposed PahalaWWTP Site
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PART B
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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
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Cultural Surveys Hawai‘i Job Code: HIONAMOA 5
LR for the Closure
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Figure 3. TMK: (3) 9-6-05 showing the project area (Hawai‘i TMK Service )
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Figure 5. Overall site plan for proposed package plant (courtesy of client)
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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 |
CHAIRPERSONBOARD OF LAND AND NATURAL RESOURCESCOMMISSION ON WATER RESOURCE MANAGEMENT
FIRST DEPUTY
DEPUTY DIRECTOR - WATER
AQUATIC RESOURCESBOATING AND OCEAN RECREATIONBUREAU OF CONVEYANCESCOMMISSION ON WATER RESOURCE MANAGEMENTCONSERVATION AND COASTAL LANDSCONSERVATION AND RESOURCES ENFORCEMENTENGINEERINGFORESTRY AND WILDLIFE
HISTORIC PRESERVATIONKAHOOLAWE ISLAND RESERVE COMMISSIONLANDSTATE 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
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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 HAWAII
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.pdfHawaiianhoarybat-HawaiianHoaryBat.pdfHawaiianseabirds-HawaiianPetrelAnd2MoreSpecies.pdfHawaiianwaterbirds-HawaiianDuckAnd3MoreSpecies.pdfPlant 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 Environmentsinto 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 theproposed project site, prior to project initiation. Repeat surveys again within 3 days ofproject initiation and after any subsequent delay of work of 3 or more days (during whichthe 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 broodsuntil the chicks/ducklings have fledged. Do not conduct potentially disruptiveactivities or habitat alteration within this buffer.o Have a biological monitor that is familiar with the species’ biology present onthe 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
JOSH GREEN, M.D. E a H KENNETH S. FINK, M.D,MGA, MPH
GOVERNOR OF HAWAII rr°j959"`s! . DIRECTOR OF HEALTH
KE KIA'AINA O KA MOKU'AINA O HAWAI'I y, KA LUNA HO'OKELE
v
STATE OF HAWAII
DEPARTMENT OF HEALTH
P.O. BOX 916
H I LO, HAWAII 96721-0916
MEMORANDUM
DATE: July 11, 2025
TO: Mr. Jeffrey W. Darrow
Planning Director, County of Hawaii
FROM: Eric Honda
District Environmental Health Program Chief
SUBJECT: Special Permit Application (PL-SPP-2025-000093)
Applicant: County of Hawaii, Department of Environmental Management
Request: To Allow the Construction and Operation of a New County
Wastewater Treatment Plant Facility
Tax Map Key: 3) 9-6-002:018 (por.), Pahala, Ka`u , Hawai`i
In most cases,the District Health Office will no longer provide individual comments to
agencies or project owners to expedite the land use review and process.
Agencies,project owners, and their agents should apply Department of Health"Standard
Comments"regarding land use to their standard project comments in their submittal.
Standard comments can be found on the Land Use Planning Review section of the
Department of Health website: hltps:Hhealth.hawaii.gov/epo/landuse/. Contact
information for each Branch/Office is available on that website.
Note: Agencies and project owners are responsible for adhering to all applicable
standard comments and obtaining proper and necessary permits before the
commencement of any work.
General summary comments have been included for your convenience. However, these
comments are not all-inclusive and do not substitute for review of and compliance with all
applicable standard comments for the various DOH individual programs.
Clean Air Branch
1. All project activities shall comply with the Hawaii Administrative Rules (HAR),
Chapters 11-59 and 11-60.1.
Jeffrey W. Darrow
July 28, 2025
Page 2 of 4
2. Control of Fugitive Dust: You must reasonably control the generation of all
airborne, visible fugitive dust and comply with the fugitive dust provisions of
HAR §11-60.1-33. Note that activities that occur near existing residences,
businesses,public areas, and major thoroughfares exacerbate potential dust
concerns. It is recommended that a dust control management plan be developed
which identifies and mitigates all activities that may generate airborne and visible
fugitive dust and that buffer zones be established wherever possible.
3. Standard comments for the Clean Air Branch
are at: hops://health.hawaii.gov/epo/landuse/
Clean Water Branch
1. All project activities shall comply with the HAR, Chapters 11-53, 11-54, and 11-55.
1. The following Clean Water Branch website contains
information for agencies and/or project owners who are
seeking comments regarding environmental compliance for
their projects with HAR, Chapters 11-53, 11-54, and 11-55:
https://health.hawaii.gov/cwb/clean-water-branch-home-
page/cwb- standard-comments/.
Hazard Evaluation & Emergency Response Office
1. A Phase I Environmental Site Assessment(ESA) and Phase II Site Investigation
should be conducted for projects wherever current or former activities on site may
have resulted in releases of hazardous substances, including oil or chemicals.
Areas of concern include current and former industrial areas, harbors, airports,
and formerly and currently zoned agricultural lands used for growing sugar,
pineapple or other agricultural products.
2. Standard comments for the Hazard Evaluation& Emergency Response Office
are at: https://health.hawaii.gov/epo/landuse/.
Indoor and Radiological Health Branch
1. Project activities shall comply with HAR Chapters 11-39, 11-45, 11-46, 11-501, 11-
502,
11-503, and 11-504.
2. Noise may be generated during demolition and/or construction. The
applicable maximum permissible sound levels, as stated in Title 11, HAR,
Chapter 11-46, "Community Noise Control,"shall not be exceeded unless a
noise permit is obtained from the Department of Health.
3. Construction/Demolition Involving Asbestos: If the proposed project includes
renovation/demolition activities that may involve asbestos,the applicant should
contact the Asbestos and Lead Section of the Branch at
hqps://health.hawaii.gov/irhb/asbestos/.
Safe Drinking Water Branch
Jeffrey W. Darrow
July 28, 2025
Page 3 of 4
1. Agencies and/or project owners are responsible for ensuring environmental
compliance for their projects in the areas of 1)Public Water Systems; 2)
Underground Injection Control; and 3) Groundwater and Source Water Protection
in accordance with HAR Chapters 11-19, 11-20, 11-21, 11-23, 11-23A, and 11-
25. They may be responsible for fulfilling additional requirements related to the
Safe Drinking Water program: hltps://health.hawaii.gov/sdwb/.
2. Standard comments for the Safe Drinking Water Branch can be
found at: https:Hhealth.hawaii._gov/ep/epo/landuse/.
Solid &Hazardous Waste Branch
1. Hazardous Waste Program - The state regulations for hazardous waste and used
oil are in HAR Chapters 11-260.1 to 11-279.1. These rules apply to the
identification, handling, transportation, storage, and disposal of regulated
hazardous waste and used oil.
2. Solid Waste Programs - The laws and regulations are contained in HRS Chapters
339D, 342G, 342H, and 342I, and HAR Chapters 11-58.1 and 11-282.
Generators and handlers of solid waste shall ensure proper recycling or disposal
at DOH-permitted solid waste management facilities. If possible,waste
prevention, reuse, and recycling are preferred options over disposal. The Office
of Solid Waste Management also oversees the electronic device recycling and
recovery law, the glass advanced disposal fee program, and the deposit beverage
container program.
3. Underground Storage Tank Program—The state regulations for underground
storage tanks are in HAR Chapter 11-280.1. These rules apply to the design,
operation, closure, and release response requirements for underground storage
tank systems, including unknown underground tanks identified during
construction.
4. Standard comments for the Solid& Hazardous Waste Branch can be
found at: hgps://health.hawaii.gov/epo/landuse/.
Wastewater Branch
For comments,please email the Wastewater Branch at.doh.wwbgdoh.hawaii.gov.
Sanitation/Local DOH Comments:
1. According to HAR §11-26-35,No person, firm, or corporation shall demolish or
clear any structure without first ascertaining the presence or absence of rodents
that may endanger public health by dispersal from such premises. Should any
such inspection reveal the presence of rodents, the rodents shall be eradicated
before demolishing or clearing the structure. A demolition permit is required prior
to demolition.
Jeffrey W. Darrow
July 28, 2025
Page 4 of 4
Other
1. CDC - Healthy Places - Healthy Community Design Checklist Toolkit
recommends that state and county planning departments, developers,planners,
engineers, and other interested parties apply these principles when planning or
reviewing new developments or redevelopment projects.
2. If new information is found or changes are made to your submittal, DOH reserves
the right to implement appropriate environmental health restrictions as required.
Should there be any questions on this matter,please contact the Department of
Health, Hawaii District Health Office, at(808) 933-0917.
O F JOSH GREEN,M.D.
t PAR 1..59y STATE OF HAWAII GOVERNOR
o OFFICE OF PLANNING STLOVERNOR
MARY ALICE EVANS
zo0 0
3J
235 South Beretania Street,6th Floor,Honolulu,Hawaii 96813 Telephone:808 587-2846
an ;av Mailing Address: P.O.Box 2359,Honolulu,Hawai`i96804 Fax: 808)587-2824
Web: https:Hplanning.hawaii.gov/
Coastal Zone
Management DTS 202507100911NA
Program Transmitted via email
Environmental Review July 28, 2025
Program
Land Use Commission Mr. Jeffrey Darrow, Director
County of Hawaii Planning Department
Land Use Division East Hawaii Office
101 Pauahi Street, Suite 3
Special Plans Branch Hilo, Hawaii 96720
State Transit-Oriented
Development Dear Mr. Darrow:
Statewide Geographic Subject: Response to Special Permit Application
Information system Construction and Operation of a New County Wastewater
Statewide Treatment Plant Facility
Sustainability Branch Pahala, Ka`u, Hawaii
TMK: (3) 9-6-002:018 (por.)
Thank you for the opportunity to review the Special Permit Application for
the Pahala Large Capacity Cesspool (LCC) Closure project, submitted by the County
of Hawaii Department of Environmental Management(DEM). According to the
subject Special Permit Application, the purpose for the proposed action is to close
the two large capacity cesspools to comply with the requirements and mandates of
the Safe Drinking Water Act(SDWA) and Amended Administrative Order of
Consent(AOC) between the U.S. Environmental Protection Agency and the County
of Hawaii, and provide a SDWA-compliant solution with a proposed wastewater
treatment plant(WWTP) and new collection system for handling wastewater
generated by the Pahala Community.
We appreciate the comprehensive details provided in the application,
including the project background, the selected Alternative 1 (package plant and new
collection system), and the extensive community engagement efforts that have led to
the current proposal. The shift from the initial aerated open lagoons concept due to
community unreceptiveness demonstrates a valuable responsiveness to local input.
Based on our review, we offer the following comments and areas of consideration:
1. Environmental Protection Measures, particularly for Avian Species: The
document appropriately identifies the presence of endangered Hawaiian
Petrel and threatened Newell's Shearwater in the general area, necessitating
impact avoidance measures" such as down-shielding lights and avoiding
nighttime construction. We emphasize the critical importance of strictly
Mr. Jeffrey Darrow
July 28, 2025
Page 2
adhering to these measures and implementing robust monitoring protocols to ensure the
protection of these sensitive avian species throughout all phases of the project, from
construction through operation. Any changes to the project plan should be re-evaluated
for potential impacts on these species.
2. Mitigation of Archaeological Discoveries: The completion of an Archaeological
Inventory Survey (AIS) is a positive step. However, the possibility of encountering
previously undiscovered archaeological sites or human remains during construction
remains a valid concern. We recommend a clear and detailed contingency plan within
the construction management framework, beyond simply ceasing work, that outlines
immediate actions, communication protocols with the State Historic Preservation
Division (SHPD), and potential mitigation strategies to minimize delays and ensure the
respectful treatment of any cultural resources encountered.
3. State Land Use: The proposed WWTP project site, approximately 3.8 miles from the
nearest shoreline, is located on land designated as "Agricultural" by the State Land Use
Commission. As illustrated by Figure 3.2 of the Final Environmental Assessment, the
Land Study Bureau classified the agricultural land where the proposed WWTP is situated
with an overall productivity rating of Class B (good) for approximately 50 percent and
Class D (poor)for the remaining 50 percent.
The WWTP site is not actively used for agricultural production and lacks existing
agricultural improvements. It is noted that approximately 10 acres of the 14.9-acre land
would remain as the macadamia nut orchard, while about 4.0 acres would require
removal of the existing macadamia nut orchard to accommodate the proposed WWTP
facilities.
Pursuant to Hawaii Revised Statutes § 205-6, the County Planning Commissions may
permit certain unusual and reasonable uses within agricultural districts in cases where
non-agricultural uses are necessary and reasonable. According to the information
provided in the subject Special Permit Application, the Office of Planning and
Sustainable Development(OPSD) concurs that the proposed wastewater treatment and
disposal facility will not significantly interfere with ongoing agricultural activity in the
region and will be necessary and reasonable to serve the Pahala Community to align with
SDWA's mandates and the Amended AOC.
4. Long-Term Financial Planning and Affordability: The mention of"higher capital and
operation and maintenance (O&M) costs" for the selected membrane bioreactor(MBR)
technology, and the provision of"financing options for newly accessible property
owners," underscores the significant financial investment associated with this project.
Mr. Jeffrey Darrow
July 28, 2025
Page 3
We encourage the County to ensure long-term financial sustainability for the operation
and maintenance of the new facility, and to continue to explore and communicate
affordable and equitable financing solutions for residents connecting to the new system,
particularly for low-income households.
5. Future Capacity Planning: While the current design accommodates existing and newly
accessible parcels, it would be prudent to consider a long-term master plan for
wastewater infrastructure in Pahala that accounts for potential future population growth
and development beyond the immediate scope of this project. Proactive planning for
future capacity needs can prevent costly upgrades or expansions in the decades to come.
If you have any questions regarding this comment letter,please contact Seiji Ogawa,
Land Use Division, seiji.ogawa@hawaii.gov, (808) 587-2898 and reference DTS
202507100911NA.
Mahalo,
MnA kU_
Mary Alice Evans
Director
DEPARTMENT OF WATER SUPPLY • COUNTY OF HAWAII
345 KEKUANAO'A STREET, SUITE 20 • HILO, HAWAII 96720
TELEPHONE (808) 961-8050 • FAX (808) 961-8657
April 5, 2018
Mr. Earl Matsukawa
Wilson Okamoto Corporation
1907 South Beretania Street, Suite 400
Honolulu, HI 96826
Dear Mr. Matsukawa:
Subject: Pre -Environmental Assessment Consultation
Pahala Villages Large Capacity Cesspool Conversion Replacement
Pahala, Ka`n, Island of Hawaii, Hawaii
Tax Map Key (3) 9-6-002:018
This is in response to your Pre -Environmental Assessment letter dated March 15, 2018.
Please be informed that the subject parcel does not have an existing water service with the Department as the
parcel is beyond the service limits of the Department's existing water system. The nearest point of connection is
from an existing 6 -inch waterline at the intersection ofHuapala Street and Maile Street, approximately 2,000
feet northeast of the property.
The Department would request estimated maximum daily water usage calculations, prepared by a professional
engineer, licensed in the State of Hawai`i, for review. After review of the calculations, the Department will
determine if water is available and a water commitment can be issued, the water commitment deposit amount,
facilities charges due, and water system improvements and other conditions for final approval.
The Department requests that the construction plans show, and the proposed sewer lines be installed with, the
proper horizontal and vertical clearances from our existing water system facilities and concrete jacketing at
waterline crossings, where necessary, as recommended by the Department's Water System Standards.
In addition, backflow prevention devices must be installed where there are connections to our water system at
wastewater processing and treatment facilities.
Should there be any questions, please contact Mr. Ryan Quitoriano of our Water Resources and Planning Branch
at 961-8070, extension 256.
Sincerely yours,
Keith K. Okamoto, P.E.
Manager -Chief Engineer
RQ:dmj
copy - County of Hawai`i, Department of Environmental Management, Wastewater Division,
Water, Ourfllost Precious resource ... 7(a WaiA nine .. .
The Department of Water Supply is an Equal Opportunity provider and employer.