HomeMy WebLinkAboutAmendment to Special Management Area Permit No.221
Prepared for:
Amendment to
Special Management
Area Permit No. 221
Prepared by:
Hu Honua Bioenergy Facility
Pepeekeo, Hawaii
January 2010
TABLE OF CONTENTS
1.Filing Fee
2.Application
After TOC
3.Background
1
A.EA/EIS Under HRS 343 1
B.Written Description of Proposed Project 2
Summary of Proposed Improvements 2
Statement of Objectives 5
Reason for Request 5
C.Description of Property and Surroundary Area6
D.Statement of Valuation of Proposed Use, Activity, or Operation7
E.State/County Plans Affecting the Subject Request
F.A Written Statement Discussing The Proposed Development In Relation To The
Objectives And Policies As Provided By Chapter 205A, HRS, And The Special
Management Area Guidelines 7
G.Surrounding Zoning and Land Uses10
H.Flood Insurance Rate Map (FIRM) Designation10
I.Archelogical Resources 10
J.Floral and Faunal Resources 11
K.Valued Cultural Resources 11
L.Public Access 11
M.Description of Access to the Area11
N.Traffic Impacts12
O.Availability of Utilities12
P.Any Information as to the Areas of Critical Concern Delineated by Director 13
4.Anticipated Impacts
A.Description of Environmental Setting 14
B.Relationship if the Proposed Action to Land Use Plans, Policies, and
Control of the Affected Area 14
C.Probable Impact of the Propose Action16
D.Any Probable Adverse Environmental Effect Which Cannot be Avoided 17
E.Alternatives to the Proposed Project 17
F.Mitigation Measures Proposed to Minimize Impact 17
G.Any Irreversible Commitments to Resources18
5.Preliminary Site Plan
18
6.Full Size Plot Plan
18
7.Shoreline Survey
18
8.Multi-Unit Residential Scale Model
18
9.List of Names, addresses and tax map key of surroundling owners
18
10.Other Plans or Additional Information
19
FIGURES
(Provided after Application Text)
Figure 1 -Location of the facility on a USGS quadrangle
Figure 2 -Site location on aerial photograph of the area
Figure 3 -County TMK Map. The subject parcel is Lot 104 on Tax Map Key (TMK) 2-8-08
Figure 4 –Aerial photograph of plant as it existed in 1993 (Source –ERM Phase II)
Figure 5 –Aerial photograph of plant as it exists today (Source –ERM Phase II)
Figure 6 –Illustration of facilities of time from 1950 to 2008 (Source –ERM Phase II)
Figure 7 –Site plan showing existing and former buildings
Figure 8 –General Plan
Figure 9 –County Zoning
ATTACHMENTS
Attachment 1 –Letter from Hawaii Department of Health, HRS 343 Determination
Attachment 2 –Supplemental Environmental Report
Attachment 3 –Petition in Support of the Hu Honua Project
Attachment 4 –Hu Honua Advertisement in Hawaii Tribune Herald, June 2009
Attachment 5 -Existing SMA Permit No. 221 and Prior SMA Permits for the Subject Site
Attachment 6 – Pepeekeo Point Shoreline Declaration of Covenants, Conditions & Restrictions
Attachment 7 – Flood Insurance Rate Map Designation
Attachment 8 – Request to DLNR for “No Effect” Letter
Attachment 9 – Pages From Site Lease
Attachment 10 –Letter from Hawaii Department of Health, Existing Air Permit Valid
Attachment 11 – Letter from Hawaii Department of Health, New Air Permit Application “Deemed
Complete”
Attachment 12 – Request for Waiver of Requirement to Conduct Shoreline Survey
Attachment 13 –List of Surrounding Property Owners
SPECIAL MANAGEMENT AREA USE PERMIT
COUNTY OF HAWAII
PLANNING DEPARTMENT
APPLICANT:
Hu Honua Bionenergy, LLC
APPLICANTS SIGNATURE: ______________________ DATE:
January 15, 2010
ADDRESS:
Site: 28-283 Sugar Mill Road Mailing: City Financial Tower
Pepeekeo, HI 96723 201Merchant St, Suite 1830
Honolulu, HI 96813
LIST APPLICANTS INTEREST IF NOT OWNER:
Lessee
LIST PRINCIPAL(S) INCLUDING NAMES OF MAIN OFFICERS:
Michael Falcone, CEO
Richard McQuain, President
Jeffrey Muller, Executive VP, Secretary & Treasurer
Phone: (Bus)
(808) 521-1600 (Res)(808) 545-2759 (Fax) (808) 521-1603
LANDOWNER(S):
Maukaloa Farms, LLC
LANDOWNER SIGNATURE(S):
Maukaloa Farms Officer: Date:
______________________________________
LANDOWNER(S) ADDRESS:
Maukaloa Farms, LLC
PO Box 1350
Santa Rosa Beach, Fl 32459
REQUEST:
Amend existing SMA Use Permit No 221 for facility upgrade and change in
fuel source. Former fuel source, coal, will be replaced with locally grown biomass.
Project will involve upgrading existing boiler,andair emissions equipment to best
available control technology, improving existing structures, and constructing supporting
facilities and infrastructure.
TAX MAP KEY: ZONING:
2-8-8:104 MG-5a, General Industrial &
A-20a, Agricultural
SIZE OF PROPERTY OR AFECTED AREA(S):
25.57 acres
AGENT:
ACSI
ADDRESS:
PO Box 30094, Honolulu, HI 96820
TELEPHONE: (Bus)
(808) 349-9076
Please indicate to whom original correspondence and copies should should be sent
ORIGINAL:COPIES:
Hu Honua Bioenergy, LLC ACSI
SPECIAL MANAGEMENT AREA USE PERMIT
APPLICATION AMENDMENT
HU HONUA BIOENERGY FACILITY
SPECIAL MANAGEMENT AREA USE PERMIT No. 221
MAJOR FACILITY UPGRADE & CHANGE IN FUEL SOURCE
Pepeekeo, Hawaii
TMK 2-8-8:104
(Formerly 2-8-007:Portion of 53)
1.Filing Fee:
the $250 filing fee is submitted with the application
2.Original (Signed) & 20 Copies Of Completed Application –
Submitted As Required.
3.Original And Twenty Copies Of Following Background Information On Subject
Request:
A.An EIS, If Required, Under Chapter 343, HRS, Or When Required By Director, May
Be Submitted In Lieu Of This Section
Hu Hunoa Bionenergy, LLC (“Hu Honua”), as the applicant for an action, evaluated the
criteria under HRS 343 and HAR 11-200in consultation with the State to determine
whether an Environmental Assessment (EA) would be required to determine whether the
action may have a significant effect. The State Department of Health (“DOH”) was the
agency that initially agreed to review the action and to determine whether the proposed
project met the criteria for having to prepare an EA.The DOH concluded, based on the
applicability requirements of HRS 343-5, that the proposed project did not meet the
criteria specified for an EA. A copy of their letter stating their findings is provided as
Attachment 1.
Hu Honua also met with the County Planners and the Director to discuss the project on
several occasions. As a result of their initial review and potential for impacts resulting
from local traffic and changing the fuel source from coal to sustainable locally grown
biomass, the Director has requested that a supplementalenvionmental report be
submitted concurrent with the application. A copy of this document is provided in
Attachment 2.
HuHonua has actively initiated advanced coordination with several State Agencies and
local organizations to discuss the project. Below is a list of some of those meetings that
were attended by senior Hu Honua representatives. There have also been numerous
meetings with various agencies in which Hu Honua was represented by its consultants.
1.5/19/08 Pepeekeo community board meeting (about 15 in attendance)
2.7/9/08 Pepeekeo community meeting (about 100 inattendance)
3.8/13/08 Pepeekeo community meeting (about 100 in attendance)
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Hu Honua Bioenergy, LLC January 2010
4.8/25/08 Ted Liu, DBEDT
5.9/16/08 Josh Strickler,Hawaii State Renewable Energy Coordinator
6.7/10/09 ILWU sponsored meeting with Pepeekeo community seniors
organization and other community leaders (about 40 people attended)
7.8/11/09 Presentation made to South Hilo Rotary Club (about 30
attendees)
8.8/11/09 Meeting with George Yokoyama,Hawaii County Economic
DevelopmentCouncil
9.9/16/09 Briefing for Josh Strickler,Hawaii State Renewable Energy
Coordinator
10.10/21/09 Meeting with George Yokoyama
11.10/21/09 Meeting with Richard Ha,Community leader
12.10/27/09Meeting with Gary Faagau,President, Orchards Community
Association
13.11/11/09Meeting with Lorraine Mendoza, Pres. and Don Hanson, VP
Pepeekeo Community Association.
In addition to the meetings noted above, Hu Honua conducted a community survey in
the fall of 2008 during which over 700 residents of the community signed a petition in
support of the Hu Honua Project (see Attachment 3). Hu Honua also ran a full page
notice in the Hawaii Tribune Herald in June 2009 to inform the public about the status of
the project (see Attachment 4).
B.Detailed Written Description Of Proposed Project And A Statement Of Objectives
And Reason For Request
The developer, Hu Honua Bioenergy, LLC, is proposing to convert the former Hilo Coast
Power Company (“HCPC”) coal-burning electric generating power plant into a renewable
electrical power generation facility fueled by locally grown sustainable biomass. The
refurbished Hu Honua facility (the “Facility”) will provide a net power output of up to 21.5
megawatts (MW) to the grid.
Summary Of Proposed Improvements
In order to achieve the committments described below,and convert the power plant to
sustainable wood biomass, reduce noise levels, improve aesthetics and signicantly
improve emissions, several physical improvements or additions to facility equipment,
namely the boiler and air emissions control equipment, and support facilities require
refurbishment, construction, or repair. The improvements would be within the existing
property boundary defined by TMK 2-8-8:104. Proposed improvements to convert the
facility from coal to wood biomass would include the following:
1.Upgrade Boiler & Boiler Building –The boiler will undergo a significant renovation
to accommodate the wood biomass and increase combustion efficiency. The
building housing the boiler will also be enclosed with acoustic siding to both
reduce noise levels during operations and improve the aesthetics of the facility.
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Hu Honua Bioenergy, LLC January 2010
2.Upgrade Air Pollution Control Equipment –The old air pollution equipment will be
replaced with a state of the art electrostatic precipitator (“ESP”) meeting Best
Available Control Technology (“BACT”) and an Selective Non-Catalytic
Reduction (“SNCR”) system will be added. The height of the exhaust gas stack
will be reduced back down to its original 140 foot height.
3.Construct Chip Storage Building –A new structure will be constructed to provide
dry storage for the chips prior to being transferred to the boiler. The building will
be an A-Frame type structure with a foundation base of 170 feet long by 79 feet
wide, and a height of 61 feet.
4.Construct Chip Processing Building –A building will also be constructed to
process wood logs into chips. This building will have a foot print of 120 feet by
70 feet, and 37 feet high.
5.Wood Transport Conveyors –a new conveyor will be required to transport the
chips from the chip building storage to the boiler. The conveyor will be 44 inches
wide, 110 feet long and elevated about 40 feet off the ground at the entrance to
the boiler hopper.
6.Install a Concrete Pad and Step Up Transformer -–The existing Hawaii Electric
Light Company (“ HELCO” or the “Utility) sub-station is more than 30 years old
and requires modernization which requires that Hu Honua install a newstep-up
transformer and switchgear toimprove the interconnection between Hu Honua
and the HELCO grid.
These improvements are needed to meet air quality standards, improve performance of
the boiler, improve reliability of the plant and improve surrounding land use, and to fullfill
its requirements under the power purchase agreement with Hawaii Electric Light
Company (HELCO). After completion the physical footprint at the facililty structure will be
less than the original sugar mill.
In April of 2008 HuHonua Bioenergy, LLC (“Hu Honua”) was formed as a joint venture
between Ethanol Research Hawaii (“ERH”) and MMA Renewable Ventures, LLC
(“MMA”). HuHonua is majority owned by MMA. Hu Honua owns the power plant and the
long term lease for the land the plant sits on. The Hu Honua power plant will be a firm
capacity electrical generation facility meaning that HELCO will be relying on its
generation to keep the grid online. Historically,this facility has provided approximately
10% of the island of Hawaii’s required power. One of HELCO’s requirements is to have
emergency backup fuel for situations where the facility’s supply of biomass fuel is
temporarily interrupted. Biodiesel, or other suitable biomass fuels, will be used as
emergency backup fuel in those instances.This combination of fuel sources will make
the facility 100 percent operable on renewable energy sources. The capability for using
coal is being removed from the existing air permit and other permits held by the plant,
including the SMA permit.
The most compelling factor with respect to restarting operations at the facility has been
the quality of the major power plant components. The boiler, turbine and generator are in
good condition and form the technical and logistical basis for going forward with
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Hu Honua Bioenergy, LLC January 2010
refurbishment and operational restart. Hu Honua’s engineering team with the assistance
of the original plant equipment manufacturers has developed a plan to refurbish the
facility that maximizes efficiency and biomass fuel flexibility while incorporating state of
the art emission controls that will allow the facility to meet the County, State and the
EPA’s latest emission andenvironmental standards.
The merits of refurbishing the facility at Pepeekeo become apparent when you consider
that after the refurbishment the facility will be contracted to operate for the next 20years
and will replaceapproximately 240,000 barrels ofimported oil each year. This is oil that
is currently being burned to create the same amount of electricity that the Hu Honua
facility will generate (enough to power about 18,000 homes). This is achieved with the
refurbished facility at a fraction of the cost of a new “green field” facility.
Once in operation the Hu Honua power plant will create 28 – 30 direct jobs and over 100
indirect jobs associated with renewable biomass fuel supply and related power plant
cottage industries. Additionally, the use of locally grown sustainable biomass will help to
keep important agriculture land in agriculture and the island of Hawaii “green” by
reducing greenhouse gases and replacing current oil based power plant operations with
a zero or negative carbon footprint renewable facility.
Hu Honua has identified several sources of sustainable biomass fuel to meet the power
plant’s fuel needs over the next 20 + years and has, or is in the process of obtaining
contracts to secure this fuel. We anticipate the main source of fuel for at least the first
ten years of operations will come from the existing eucalyptus plantations along the
Hamakua Coast. The Facility can work in conjunction with other agricultural projects. For
example, a proposed veneer business is a potential user of the plantation wood, but will
only use about 55-60 percent of the tree, resulting in asignificant amount of wood waste,
which can be used as fuel for the power plant. Both high and low value wood can be
used as fuel for the Hu Honuapower plant. This helps the higher value product
producers remain competitive and gives Hu Honua an affordable fuel for the power
plant, a symbiotic relationship that supports two different employment groups.
Another source of biomass fuel in the first several years (and likely beyond) will come
from mid to large land owners on Hawaii. As these land owners remove or process trees
to eliminate invasive species, build, grow crops,or maintain fire protection, it will yield
biomass byproducts which can be used as fuel.Hu Honua,with its local Ag industry
partners,will work with these land owners to assist in proper land management, saving
the land owner money, and providing a low cost fuel source for the plant.
As part of its efforts to have greater control over its fuel supply, Hu Honua isdeveloping
a sustainable biomass farming plan. Creating alternative plans now ensures long term
viability of the operations and a sustainable renewable fuel supply.
Again, leveraging local expertise, Hu Honua is working with specialists from the University
of Hawaii, Hawaii Agriculture Research Center (“HARC”) and other commercial and
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Hu Honua Bioenergy, LLC January 2010
academic groups with the goal of growing biomass fuel for the power plant at Pepeekeo.
Once completed, the plan will serve as a blueprint for Hu Honua’s agriculture operation.
At this time, research has revealed Leucaena may beanother viable source of biomass
(instead of Eucalyptus) because of its ability to be harvested for decades without
replanting and its high volume of biomass production per acre planted. Leucaena is grown
internationally as a fuel source and UH has been developing strains of Leucaena for a
variety of applications for over 40 years. Hu Honua would expect to harvest every 3 -4
years with an estimated yield of 75 –100 tons of fuel per acre.
At present Hu Honua is the only Hawaii based bio-energy project that has acquired a
site, owns, and is refurbishing major power plant equipment. Additionally, the plant has
an existing connection to HELCO’s grid. On March 16, 2009, HELCO submitted a
binding term sheet agreement with Hu Honua to the Public Utility Commission. This is
the only binding term sheet completed under the PUC competitive bidding waiver
process.
Hu Honua funded a system interconnection study which was recently completed by a
third party engineering firm to establish the final technical parameters for the interface of
the Hu Honua facility with the HELCO grid. As a next step, HELCO and Hu Honua will
enter into a definitive Power Purchase Agreement (PPA). HELCO will then prepare the
PPA and appropriate supporting documentation for submittal to the PUC for its review
and approval.
Statement Of Objectives
The objectives of the proposed action are:
Convert existing power plant equipment and facilities from coal to,biomass wood
Make necessary improvements to accommodate wood biomass, including
addition of buildings and upgrades to equipment
Generate electricity for sale to the local utility company
Reasons for request
The primary reason for this request is to revise the existing SMA Permit No. 221 to allow
the use of solid material, namely renewable biomass fuel, for purposes of producing
power for sale to the electric company. The existing SMA permit restricts the plant
operator to using only washed low-sulfur Class B sub-bituminous coal. Substitutions are
not allowed without approval from the State Department of Health and County Planning
Department.
The existing power plant facility was constructed in 1972. The facility and/or the site
boundary have changed over time. A brief history of the permit and its amendments is
outlined below and copies of subject permits are included in Attachment 5:
Permit No. 208, June 5, 1984–Allow Change of Zone and approve Special
Management Area Use Permit application for subject property;
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Hu Honua Bioenergy, LLC January 2010
Permit No 85-2, April 18, 1985 –to allow the establishment of coal storage and
and a coal burning energy plant and related improvements;
Permit No. 221, February 3, 1995 –to allow an increase in height of flu stack at
power plant; and
SMA 03-009–related to Continental’s subdivision (extraction of Lots 149 and
150)of the original plant site. Related to this approval is a Declaration of
Covenants, Conditions and Restrictions (CC&R’s) that was developed and flows
with each of the parcels in the vicinity of the facility (see Attachment 6).
Additionally, the proposed use, activity and operation is valued greater than $125,000;
therfore, under County Planning Rules of Practice and Procedure, Chapter 9-11(G), an
amendment to the existing permit is required.
C.Description Of Property And Surrounding Area
The property consists of about 26 acres of irregular shape property boundaries, and is
situated adjacent to the shoreline. The site is about 80 feet above mean sea level and
slopes generally from mauka (west) to makai (east), which ends at the shoreline by a
steep cliff.
The existing Hu Honua facility is located on the east coast of the Island of Hawaii, near
the town of Pepeekeo, and abuts the Pacific Ocean to the east. Approximately 25 miles
to the west the peak of Mauna Kea rises to an elevation of 13,796 feet. The trade winds
blow from the northeast during day time hours at speeds of up to 20 miles per hour.
There are also persistent winds from the southwest during night time hours due to the
drainage of cool air flowing down the slope of Mauna Kea.
The existing boiler and turbine buildings served as the two most prominent structures on
the site and will be improved as part of future planned operations. The former bagasse
house collapsed and the steel structure has been removed; only the concrete
foundations and covered storage area exists. Several small (<20,000 gal) tanks used for
water, and one 150,000 gallon tank for fuel oil formerly used and currently present on
the site are slated for removal. A conveyor which transported the coal from the former
coal storage yard to the boiler is also present and will be removed as part of plant
upgrade. Several former concrete foundations and structures exist throughout the site
and will be incorporated into future plans for the site.
The site averages between 120 and 180 inches of rain per year. The project is located in
Pepeekeo, Hawaii, about 10 miles north of Hilo center. The power plant will reside on a
reduced footprint of the former HCPC coal power plant, which was once a part of the
former sugar mill complex.
The physical address of the facility is:
28-283 Sugar Mill Road
Pepeekeo, Hawaii 96723
The subject property is located makai of the Hawaii Belt Road approximately three-
quarters miles north of Pepeekeo and has undergone many changes over the years.
The following figures are provided to help understand the location and history of the
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Hu Honua Bioenergy, LLC January 2010
property and surrounding land. It should be noted that the area of the old plantation
office (Lots 149 and 150) is no longer on the subject property due to the recent
subdivision and is not a part of this application.
Figure 1 -Location of the facility on a USGS quadrangle
Figure 2 -Site location on aerial photograph of the area
Figure 3 -County TMK Map. The subject parcel is Lot 104 on Tax Map Key
(TMK) 2-8-08
Figure 4 –Aerial photograph of plant as it existed in 1993 (Source –ERM Phase
II)
Figure 5 –Aerial photograph of plant as it exists today (Source –ERM Phase II)
Figure 6 –Illustration of facilities of time from 1950 to 2008 (Source –ERM
Phase II)
Figure 7 –Site plan showing existing and former buildings
D.Statement of Valuation of Proposed Use, Activity, or Operation
The plant upgrade repairs and modernization costs are estimated at approximately $60
million. This involves major upgrade and improvement to the boiler and air pollution
control equipment, adding two new support structures for wood fuel operations, making
improvements to existing sructures (e.g, enclosing the boiler structure), and engineering
and upgrades to other plant supporting equipment.
E.State/County Plans Affecting the Subject Request: General Plan Designation and
Community Development Plans
General Plan LUPAG Map Designation:The site overlaps three designations,
see Figure 8:
Industrial (ind)
Important Agriculture Land (ial)
Open (ope)
Zoning: General Industrial (MG-5a) and Agriculture (A-20a), see Figure 9
State Land Use Boundary:Urban and Agricultural
Land Study Bureau Soil Rating: “U” or within urbanized area
SMA: Eastern portion of property is within SMA zone
Coastal Zone Management, HRS, and Chapter 205A: the entire State of Hawaii lies
within the Coastal Zone Management Area; Special Management Area is part of the
Coastal Zone Management Program; site is not located within County Civil Defense
Agency’s evacuation area for hazards due to tsunami and surges from hurricanes
ALISH Map: not classified as lands important for agriculture
Community Development Plan: the Facility is situated within the district covered by the
Hilo Community Development Plan,adopted on May 21, 1975.
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Hu Honua Bioenergy, LLC January 2010
F.A Written Statement Discussing The Proposed Development In Relation To The
Objectives And Policies As Provided By Chapter 205A, HRS, And The Special
Management Area Guidelines
The proposed project is consistent with the objectives and policies as provided in
Chapter 205A, HRS, and Special Management Area guidelines contained in Rule 9 of
the Planning Commission Rules of Practice and Procedure. The specific Objectives and
Policies, as they apply to the project, are summarized below:
Recreational Resources
–Subject project is not located such that it will prevent
coastal recreational opportunities or accessibility to the public. Public access to
shoreline, for example, is provided on both the north and south property
boundaries. The rough surf and high cliffs make the area unsuitable for any form
of recreation other than fishing.
Historic Resources
– The proposed changes to the facility will not affect any
resources of historic significance on the property or surrounding area.
Scenic and Open Spaces
–There are no known valued scenic resources
known in the vicinity of the project. The existing stack, currently 190 feet high, is
visible from Sugar Mill Road, but does not block any view planes or affect scenic
or open spaces. The stack height will be reduced by 50 feet to 140 feet above
the ground surface.
Coastal Ecosytems
– Water quality from the facility will not change significantly
from previous power plant operations. The thermal discharge was the primary
controlled pollutant and will continue to be covered under the future permit. The
water discharge point source permit requires the facility to meet current water
quality standards and to conduct biological studies of the reef in the area.
Economic Uses
– This Facility will replace approximately 240,000 barrels of
imported oil each year. This is oil that is currently being burned to create the
same amount of electricity that the Hu Honua facility will generate (enough to
power about 18,000 homes.) The facility will be a firm capacity electrical
generation facility meaning that HELCO will be relying on its generation to keep
the grid online. Historically,this facility has provided approximately 10% of the
island of Hawaii’s required power.
Coastal Hazards
-TheFacility is not in a tsunami zone; will not be affected by
storm waves because itis located about 80 feet above mean sea level; there is
no localized stream which could cause flooding; erosion will be controlled
through physical plant infrastructure improvements; and pollution will be
controlled through issuance of State and County permits.
Managing Development
– Use of existing laws and regulations will be adhered
to through issuance of permits by Federal, State or local agencies. There are no
known potential impacts to coastal development related to these facility
improvements and changes.
Public Participation
–The public will have opportunity through this SMA
amendment and other permit participation requirements to be involved in the
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Hu Honua Bioenergy, LLC January 2010
coastal zone management process. There are no known coastal management
issues for this project.
Beach Protection
–There are no known public beaches along the cliffs of the
property and the facility will not require any construction of erosion-protection
structures and does not interfere with existing recereational and waterline
activities.
Marine Resources
–The facility will promote the protection, use, and
development of marine and coastal resources to assure sustainability. The
changes and improvements to the facility will not affect any development of
marine resources.
Additionally, the facility will be consistent with the Special Management Area Guidelines
as summarized below:
Adequate access is provided to publically owned or used beaches, recreational
areas and natural reserves.
the facility will not restrict access to beaches or fishing grounds.
o
Adequate and properly located public recreation areas and wildlife preserves are
reserved.
the facility will not affect these resources.
o
Provisons are made for solid and liquid waste treatment, disposition and
management.
the facility is required to adhere to strict environmental regulations
o
regarding generation, classification, handling and disposition of solid and
liquid waste. Solid waste will either be beneficially used and recycled to
the fullest extent and liquid waste will be treated under permit conditions.
Alterations to existing land forms and vegetation, and construction of structures
shall cause minimal adverse affect to water resources and scenic and
recreational amenities and minimum danger of floods, wind damage, storm
surge, landslides, erosion, siltation, or failure in the event of earthquake.
The facility improvements and new structures will be designed and
o
constructed in accordance with the latest building and industrial codes to
prevent significant adverse impacts.
Moreover, the changes and improvements will not have any substantial adverse
environmental or ecological effects asdiscussed below and in the Supplemental
Environmental Report in Attachment 2.
In general, more than adequate water is available to the site through both a public
county water service and private wells, located mauka of the property. All essential
utilities and services are or will be made available to the site, which complements the
objectives of Rule 9. A right of way easement is in place with the land owner where the
wells are located. Potential runoff or discharge that could reach the ocean are handled
by on-site improvements consistent with the requirements of the Department of Public
Works and the State DOH Clean Water Branch. Impacts from soil erosion and runoff
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Hu Honua Bioenergy, LLC January 2010
during site preparation and construction phases will be mitigated through compliance
with existing regulations governing such and construction best management practices.
The proposed project will meet State and Federal environmental air, water and solid
waste standards in order to substantially minimize adverse environmental or ecological
effects. Additionally, the project will comply with all applicable state and/or federal
permits, including permits for air pollution, storm water, waste water and solid waste.
Any potential off-shore water quality impacts will be mitigated through compliance with
discharge permits. Provisions are made for solid and liquid waste disposition and
management which will minimize adverse effects upon SMA resources. These
provisions include such things as beneficial use of ash generated as a byproduct of
combustion from the boiler, disposal of solid wastes at licensed disposal facilities, and
on-site treatment (settling of solids) and disposal of boiler quench water into discharge
trenches.
The property is not known to contain any unique ecological systems, nor provide
habitats for any endangered plants or animal species. Further, there are no known
archeological features of importance known or previously found on the site. The subject
property has been used as a sugar processing facility and electric generation station
dating back to the late 1800’s.
All proposed structures will be situated approximately 200 feet at the nearest point from
the shoreline.
Based on the above, it is determined that the proposed project will not result in loss of
valuable natural, cultural, or recreational resources of the shoreline or coastal area.
G.Surrounding Zoning and Land Uses
Surrounding zoning primarily consists of Agricultural (A-20a), but some Single Family
Residential with minimum building site area of 20,000 square feet (RS-20) and 7,500
square feet (RS-7.5) are located along the north and aportion of the east boundary of
the property.There is a limited industrial parcel (ML-20) located more than a 1,000 feet
west of the power plant along Sugar Mill Road, see Figure 9.
Surrounding land uses include primarily Important Agricultural Land (ial), low density
urban (ldu) immediately north of property,and open space (ope) along the shoreline
(Figure 8).
H.Flood Insurance Rate Map (FIRM) Designation
FIRM, Zone X, outside 500 year flood plain (see Attachment 7for County Flood Zone
certification page).
I.Archeological Resources
The property is is not listed as a historic property in the Hawaii State Register of historic
places, has not been determined to be eligble for inclusion in the National Register of
Historic Places, and is not profiled as a significant cultural and/or historic site in the
General Plan. A “no effect” determination letter is being requested from the State
Department of Land and Natural Resources (“DLNR”) Historic Preservation Division for
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Hu Honua Bioenergy, LLC January 2010
the subject property concurrent with this submittal and will be provided as soon as a
response is received from the State Historic Preservation Division (“SHPD”), see
Attachment 8. In 2003, a field inspection was conducted of the surrounding properties
and a portion of the subject property as part of a SMA application (SMA 03-009) for new
residential development located in the makai lands of the former Pepeekeo Sugar
Plantation (aka Hilo Coast Processing Company), which is located on a portion of the
site of the former Hilo Coast Power Company (“HCPC”). The filed inspection was
conducted to determine the presence/absence of historic sites, and the need, if any, for
additional archeological and historical research for any subsequent development
planning and permit applications. No historic sites were found. The DLNR agreed with
the 2003 field inspection noting that there were no historic sites present.
J.Floral and Faunal Resources
The entire property has been used for heavy industrial and agricultural uses since the
late 1800’s making the prospects of having endangered plant or animal life quite remote.
There are no known endangered plant or animal species on the subject property, nor is
the subject property within any known critical habitat. Overall impact to flora and fauna
is expected to be negligble since the plants are alien and introduced species. There are
no records of the site being the habitat for rare or endangered plant or animal species.
Therefore, since the site had previously been extensively improved as part of former
sugar mill and power plant operations, it is not likely to be a habitat of any threatened or
endangered species (Source: SMA Permit Applications for Permit 221 and SMA 03-
009).
K.Valued Cultural Resources
Except for fishing along the shoreline, no valued cultural, historical, or natural resources
exist on the property and there is no evidence of any traditional or customary Native
Hawaiian rights being practiced on the subject property.
L.Public Access: Existing Public Access To And Along The Shoreline Or To The
Mountain Areas And Knowledge Of Whether Public Access Is Being Used
The Pepeekeo Mill Road, also known as Sugar Mill Road, has been used by the public
to travel to the shoreline at Pepeekeo Point and adjoining areas for many years. The
public has used the rocky shoreline in this area for fishing, `opihi picking, and beach
going on an informal basis for many years and until recently, the access did not have
any recognized formal legal access. As established by a Settlement Agreement with the
surrounding land owner, Pepeekeo Mill Road is a public vehicular access to the
shoreline, and there is designated parking at the end of the road. Also in a larger area
owned by Continental Pacific and covering about 1,300 acres and three miles of
shoreline, including that of the subject property and surrounding properties, there is a
continuous lateral pedestrian path along the coast near the top of the sea cliff. Generally
this is provided through a 10-foot wide path within 25 feet or so of the top of the sea cliff.
Vehicular access has also been provided on plantation roads parallel to the shoreline.
There are five mauka-makai pedestrian paths from those plantation roads to the coastal
paths and are identified on the County TMK map (2-8-08).
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Hu Honua Bioenergy, LLC January 2010
M.Description Of Access To The Area
General acces to the area isgained via Hawaii Belt Road, a State owned two-lane
paved highway within a 100 foot right-of-way, which is located about one mile from the
property. The primary access off the Hawaii Belt Road is the Sugar Mill Road (aka
Pepeekeo Mill Road) with an existing 20 to 30-foot wide asphalt-concrete paved
roadway within a 60-foot right-of-way. The road is private and owned by the subdivsion.
Attachment 9 contains pages from the site Lease and relevant sections have been
underlined. General visitor and contractor plant access will be provided by a secured
gate off Sugar Mill Road and a paved driveway. Primary access for fuel delivery will be
the old cane haul road on the west and south side of the property accessed from the four
way cross intersection along Sugar Mill Road.
N.Traffic Impacts –Assessment Of Existing Traffic Conditions, Anticipated Increase
In Traffic And Traffic Impacts From Proposed Use
Traffic conditions of the existing coal power plant included routine daily traffic of
employee vehicles, contractors, vendors, and visitors. During non-shift changes, the
plant averaged three to four vehicles and/or trucks per hour. Coal was delivered on a
non-routine basis three to four times per year. During this delivery period, large dump
trucks were used 24 hours per day for up to seven days to deliver the coal from the
harbor to the plant.
Except for fuel deliveries, routine daily traffic patterns and number of vehicles per hour
for employees, contractors, vendors and visitors will essentially be the same for the
proposed biomass operations as with prior coal operations.
The most significant change in traffic conditions will result from fuel delivery, whereby
wood biomass will be delivered daily opposed to the non-routine continuous 24-7 traffic
pattern of the previous plant. Fuel deliveries will be limited to daylight hours. It is
anticipated that fuel delivery trucks will be no more than 5 to 6 per hour during daylight
hours only.
As has been, the practice, since the mill began, trucks will be required to turn onto Sugar
Mill Road from Highway 19 from both directions.depending on which land tract was
used to source the sustainable biomass fuel.. Highway 19 provides adequate left turn
accommodations for trucks having to turn from the southbound direction.
Truck traffic along Sugar Mill Road will have to pass by twelve (12) Ag-20a lots which
border either side of the road between Highway 19 and the Railroad Ave (the four way
stop). Trucks will be diverted from Sugar Mill Road at the four way stop to a former
sugar haul road which will bring large vehicle traffic into the plant from the south to avoid
the residential lots at Pepeekeo Point area. Two Ag-20a lots will be affected by this
traffic between the four way stop and the plant. (See Attachment 13)
O.Availability Of Utilities:Water, Telephone, Electricity, Sewage Disposal
All essential utilites are available to the site. Police services are located approximately
10 miles from the facility, and fire services are available from the Central and Kaumana
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Hu Honua Bioenergy, LLC January 2010
Stations. Emergency medical services are available from the Hilo Medical Center on
Wainuenue Ave. in Hilo.
Potable and Non-Potable Water Sources
Potable water for drinking and sanitary purposes is provided through a County service
connection. County water is also used for boiler makeup water and will be treated to
remove mineral content with an on-site reverse osmosis system. Two non-potable wells
located mauka of the subject property supply water for boiler quench, ash quenching
and general plant maintenance usage. The amount of water required for ash quenching
will be substantially less than that used for operation of the plant on coal due to the lower
amount of ash produced by biomass and a change in the ash collection technology.
Three brackish water wells will supply up to 21.6 million gallons per day of non-contact
cooling water for the steam condensor.
Sewage Disposal
Domestic wastewater from the bathrooms and sinks in the facility is currently discharged
to an on-site cesspool. The current system will be replaced with a properly licensed
septic system.
Non-domestic water, which includes quench water and floor drains, requires disposal
separate from the domestic wastewater system. The former power plant utilized two
settling ponds to discharge the wastewater. The settling ponds were designed to
separate or settle out ash solids and allow water to percolate into the ground. The former
power plant had a wastewater treatment unit permit from the State to allow them to
discharge the wastewater. The same system will be used as part of the upgraded facility,
whereby boiler quench water, floor drains, RO reject water, and air conditioning
condensates will all be directed to the quench sump and pumped to the settling ponds
for discharge. A wastewater treatment permit will be obtained from the State to allow
such discharge. This settling ponds are required because there is no county system
accesible or in close proximity to the plant.
Non-contact cooling water for the steam condensor will be discharged to surface water
(Pacific Ocean) through the same outfall on-site that was used for prior operations. Up
to 21.6 MGD will be discharged, which is based on the three existing pumps, each with a
rated capacity of 5,000 gallons per minute. A newindividual NPDES permit will be
obtained from the State DOH Clean Water Branch to allow this discharge.
Telephone:Aboveground line service is available and present from Hawaiian Tel.
Electricity:There is currently no public service available at the plant. Electricity is
generated on site either through the boiler and turbine or the back up generator. When
the plant is back in operation, electricity will be available to the plant via backfeed
through the revised interconnection facility.
Solid Waste Disposal:Solid waste will include bottom and fly ash from the boiler and a
very small amount of “domestic” waste produced by the business. One to two truckloads
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Hu Honua Bioenergy, LLC January 2010
of ash per week will be transferred off-site for beneficial use or disposal. Regular trash
pickup will be accomplished by commercial haulers and will consist of one to two
truckloads per month.
P.In The Case Of An Applicant Whose Proposed Development Has Been Assessed,
Any Information As To The Areas Of Critical Concern Delineated By Director
There are no known Areas of Critical Concern.
4.Original And Twenty Copies Of Anticipated Impacts Of The Proposed Development
On The Special Management Area, Including But Not Limited To:
A.Description Of Environmental Setting
The project site is located about ten miles north of Hilo center along Highway 19 in a
highly agricultural regional area. The land surrounding the facility consists of mostly
agricultural zoned property; however, recent development has re-zoned land to the north
of the project to allow single-family homes. The physiology and topography have not
changed in more than 100 years and will not change as a result of these improvements.
The subject site is the former HCPC coal-fired power plant which ceased operation on
December 31, 2004. The power plant, originally built in 1972, was once part of asugar
mill complex. Conversion of the power plant to biomass operations and/or improvements
are not anticipated to create any significant adverse impacts on the environment. The
property has been extensively developed for industrial uses, and the proposed
improvements will be consistent with on-going activities. Any impacts that may be
generated would be mitigated through compliance with applicable regulatory controls
and requirements.
Water and air quality will generally be improved as result of changing from a fossil fuel
source to a sustainable biomass fuel.Moreover, no negative impacts to terrestrial
species,endangered species, cultural, historic and natural resources, are expected as
result of the improvements. More complete and specific discussions are contained in the
supplemental document.
B.The Relationship Of The Proposed Action To Land Use Plans, Policies, And
Control Of The Affected Area
The project site falls within the jurisdiction of the current County of Hawaii General Plan
which includespolicies and goals related to environment, energy, transportation, natural
resources, shoreline, and public utilities. Land use activiites are guided by the General
Plan which setspolicy for long range comprehensive development, guidesthe pattern
for future development, priovidesframework for regulatory decisions, and promotes and
safeguards public interest, among other purposes.
The subject site conforms to the General Plan, Hilo Community Development Plan, and
Zoning Code, as the site is classified and zoned for industrial uses, which allows for an
electric generating facility.
The County’s General Plan sets the policy for the long range comprehensive
development of the island of Hawaii.We offer the following regarding key elements of
the General Plan as they relate to the amendment and upgrade of the facility:
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Hu Honua Bioenergy, LLC January 2010
Economic: this facility will help the County meet its needs regarding maintaining
agricultural lands and forestry initiatives through our use of sustainable biomass fuel to
operate the plant; operation of the facility will help the local community improve
opportunites by diversification and strengthening employment of secondary industries;
this facility is consistent with the policy to encourage new industries that provide
favorable benefit-cost relationships to the people of the County.
Energy: this facility will help the Big Island meet its goal to strive towards energy self-
sufficeincy and conforms to the policy that encourages the development of alternate
energy resources. Until the demise of sugar in the 1990’s, thirteen percent of the
island’s energy once came from biomass. This facility will help decrease the island’s
dependency on fossil fuel,will help assure a sufficent supply of energy for present and
future demands, diversify energy supply and help to minimize environmental impacts
associated with energy uses.
Environmental Quality: the County’s basic industries, agricultural, tourism, and scientific
and technological enterprises, depend on a “clean” environment for optimum growth,
including clean air, water and soil. This project is consistent in promoting a clean
environment, inasmuch, the air quality from biomass is signifacntly better than that of
coal, water pollution will not degrade, and there willbe no implats to soil. The project’s
emsissions mostly consist of organic polluants and some inorganic minerals and metals
at lower amounts than when the facility operated on coal. This upgrade of the facility will
help meet the goal of improving existing environmental quality in the area and pollutants
willbe controlled through equipment meeting the highest industrial standards available.
Natural Resources and Shoreline: the facility upgrades are being completed on existing
and former facility infrastructure. As such the facility will not adversely affect the natural
resources or shoreline through exploitation or encroachment or damage. Moreover, no
recreational resources will be impacted and public access to fishing spots and the
shoreline will be available through exisitng established easements.
Public Utilities: this facility will not burden public utilities such aswater, sewer,
electricity, or telephone. The facility will draw water from the countyfor only sanitary
uses and low volume maintenance activities and does not require public electricity nor
sewer service. Existing telephone lines will be used by the facility for
telecommunications.
Transportation: this Facility will not impede the ability for the County to meet its goal to
move people and goods efficiently. The number of trucks per hour is small compared to
traffic along the State highway at the facility’s entrance at Sugar Mill Road. Traffic
generated by the facility is consistent with the policy to promote and infulence desired
land use.
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Hu Honua Bioenergy, LLC January 2010
C.The Probable Impact Of The Proposed Action On The Environment
The proposed project will not have any significant adverse environmental or ecological
effect, except as such adverse effect is minimized to the extent practicable and clearly
outweighed by public health, safety, or compelling interest. The proposed project is not
anticipated to create significant adverse impacts upon immediately adjacent properties
which are zoned Ag-20a and RS-7.5 and RS-20.The Facility will utilize controls that
achieve compliance with existing regulations and will not impact surrounding uses. The
proposed project will not impact coastal recreation or visual resources to the shoreline
and coastal ecosystems. As a result of a Settlement Agreement between the County
and Continental Pacific, there is mauka-makai lateral coastal access; therefore the
project will not restrict access to coastal recreational resources along the shoreline.
Both vehicle and pedestrian access is provided and available north and south of the
subject property. The electricity to be generated by this facility is essential for continual
electrical service to the entire County of Hawaii. Technical documents, such as permits
and permit applications with the State, demonstrate the facility will be in compliance with
various environmental Acts (e.g., Clean Air Act, Clean Water Act, Solid Waste Disposal
Act, etc.).
No significant impact on the environment is believed created for the following reasons:
Air emissions will be controlled with best available control technology
Changing the fuel source from fossil fuel to renewable fuels will decrease the
types of byproducts produced
The major environmental concern associated with any solid mass combustion facility is
its potential impacts on air quality. The concern is principally with the emissions that
result from combustion. For biomass fuel, this includes nitrogen oxides, carbon
monoxide and particlar matter (PM 2.5 and PM 10). To a smaller degree, sulfur dioxide,
volatile organic compounds and hydrogen chloride. Fugitive emissions from fuel storage
and ash operations are expected to be minor as fuel will be in chipped form with minimal
fines, and the ash will have a high moisture content coming from the boiler. Although
the Hu Honua facility has an existing valid air permit based upon the use of coal as the
primary fuel (see Attachment 10), Hu Honua has completed an application to the Hawaii
Department of Health for a new covered source air permit based upon the use of
biomass as the primary fuel (see Attachment 11).
The project will not block views from the highway to the sea.The viewscape is that of
undeveloped agricultural area. The land gently slopes and drops a few hundred feet in
elevation from the highway to the shoreline. Besides the plant stack, there are no
noticable features that would be considered view resources, e.g., unique geological
features. Generally, public views of the plant are limited to vantages along Sugar Mill
Road, and it is not generally noticable or visible. The plant does not obstruct any scenic
view planes.
D.Any Probable Adverse Environmental Effect Which Cannot Be Avoided
No adverse environmental effects are being created by this project.
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Hu Honua Bioenergy, LLC January 2010
E.Alternatives To The Proposed Project
The action under consideration is the upgrade and modification to an existing power
plant. A no action alternative would mean no improvement to the existing plant and
continuing with coal as the primary fuel source, ceasing operation or continued
dependence on imported fossil fuels in the area. The proposed action includes
upgrading existing equipment to accommodate a different solid biomass fuel source.
One other option would be to construct a new facility in a different sustainable location;
however, this would require extensive site analysis, land agreements, and major capital
to accomplish. The current site lends itself to the best location because the existing
infrastructure is in place to accommodate the needs of converting from coal to
sustainable biomass.
F.Mitigating Measures Proposed To Minimize Impact
Hu Honua has made the following commitments to the community with respect to those
concerns:
Improved Sound Insulation
•Plant equipment and walls will be properly insulated
•Trees and landscaping added or maintained to act as sound barrier
•Plant will not have morning steam whistle
•Truck “Jake brakes” prohibited on Sugar Mill Road (5-6 trucks per hour during
daylight hours only)
•Sound levels from the power plant will conform to residential limits at the nearby
residences
Modern Emissions Controls
•Decreased air pollutant emissions due to renewable biomass fuel source
•Further decreased air pollutant emissions with newbest available control
technology equipment; adding an electrostatic precipitator and rotary over-fired air
system and urea injection to reduce particulate matter, nitrogen oxides, carbon
monoxide, and hydrochloric acid emissions
•New source permit being obtained rather than modifying existing permit
Improve Road Infrastructure
•Work with Sugar Mill Road owners to improve current road conditions
•Limit Truck traffic to daylight hours only
Facilitate Shoreline Access
•Assist in maintaining current public access immediately adjacent to project
G.Any Irreversible And Irretrievable Commitments To Resources
The are no irreversible and irretrievable commitments to resources expected from this
project. This project has partnered with private forestry management companies to
develop forest management plans for clearing, growing, and harvesting the wood. It’s
expected that wood resources consumed will be replenished with tree species that have
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Hu Honua Bioenergy, LLC January 2010
the least amount of impact to the environment. Large amounts of water to cool the
steam turbine are required, but water retrieved from the groundwater is a brackish
source, not used for drinking water, and more than 95 percent is returned to the
environment.
5.Original And Twenty Copies Of A Preliminary Site Plan Drawn To Scale Showing
Property Lines And Measurements; All Existing And Proposed Structures With
Elevations, Uses, And Improvements; Proposed Subdivision And Refrence Points
Such As Roadways, Shoreline, Etc.
Scaled site plan included and attached.
6.One Copy Of A Full-Size (2’ X 3’) Scale-Drawn Plot Plan Of Item 5 For Presentation
Purposes
Provided as requested.
7.A Shoreline Survey When Parcel Abuts The Shoreline, Except As May Be Waived By
The Director When The Proposed Development Is Clearly And Unmistakely Located
On A Shoreline Parcel Some Distance From The Shoreline
The proposed project will not impact coastal recreation or visual resources to the shoreline
and coastal ecosystems. As a result of a Settlement Agreement between the County and
Continental Pacific, there is mauka-makai lateral coastal access; therefore the project will
not restrict access to coastal recreational resources along the shoreline. A copy of the
request for waiver of the requirement to conduct a shoreline survey and supporting reasons
is provided in Attachment 12.
8.In The Case Where A Multi-Unit Residential Structure, Containing More Than Ten
Units Is Proposed, The Director May Require The Applicant To Develop A Scale Model
Of Three-Dimensional Rendering Of The Proposed Development And Related
Improvements
Not Applicable to this project.
9.A list of Names, addresses and tax map keys of all owners and lessess of record of
surrounding properties who are required to receive notice
See Attachment 13.
10.Any other plans or additional information relevant to this application may be
requested by the Planning Director to facilitate processing of this request
A supplemental environmental document has been prepared and included with this application
to provide additional supporting documentation. (see Attachment 2)
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Hu Honua Bioenergy, LLC January 2010
Hu Honua Bioenergy, LLC January 2010
Hu Honua Bioenergy
Facility
USGS Location Map
Scale:
NTS
FIGURE 1
Date:
8/1/09
Project Location
General Plan
Designations
Scale:
NTS
FIGURE 8
Date:
8/1/09
Project Location
Zoning
Designations
Scale:
NTS
FIGURE 9
Date:
8/1/09
Hu Honua Bioenergy, LLC January 2010
ATTACHMENT 1
Letter from Hawaii Department of
Health
HRS 343 Determination
Hu Honua Bioenergy, LLC January 2010
ATTACHMENT 2
Supplemental Environmental Report
Hu Honua Bioenergy, LLC January 2010
SMA PERMIT No. 221 AMENDMENT
SUPPLEMENTAL ENVIRONMENTAL
REPORT
28-283 Sugar Mill Road
Pepeekeo, HI
January 2010
Table of Contents
Page
Executive Summary
1
General Information
2
Project Description
2
Environmental Setting, Impacts and Mitigation Measures
3
Climate, Geology, and Soils 3
Drainage, Water Features and Water Quality 4
Flora, Fauna and Ecosystems 4
Noise and Scenic Sources 5
Air Quality 5
Hazardous Substances, Toxic Waste and Hazardous Conditions 7
Socioeconomic 7
Cultural and Archeological Resources 8
Infrastructure 8
Transportation 9
Secondary Cumulative Impacts
9
Required Permits and Approvals
10
Consistency with Hawaii State Plan
10
Consistency with the Hawaii Clean Energy Initiative
10
Consistency with Hawaii County General Plan
10
Hawaii County Regulations
11
Hawaii State Land Use
11
Determination
11
EXECUTIVE SUMMARY
Bioenergy, LLC (“Hu Honua”) proposes to modify and upgrade the existing facilities
formerly known as the Hilo Coast Power Plant (“HCPC”). The purpose of the project is to
convert the former coal-burning electric generating power plant into a renewable electrical
power generation facility fueled by locally grown sustainable biomass. The existing power plant
structures and equipment will generally remain the same, but undergo upgrade and
modification; however, two new structures will be addedto support the biomass handling and
processing. The power plant will be a firm capacity electrical generation facility. This means
the Hawaiian Electric and Light Company (“HELCO”) will rely on its power generation to enable
it to meet its Renewable Portfolio Standard goals with stable, reliable power for the local
community.The Hu Honua facility is considered a reliable source of energy because it does not
depend on variable natural resourcessuch as sunlight or wind to be present in order for the
facility to generate power. The Hu Honua facility relies upona solid fuel fired boiler that
produces steam, which in turn operates the steam turbine, which produces the electrical output
to the grid. The solid fuel source, sustainable biomass, for the boiler is abundant and plentiful in
this region. Hu Honua has secured multiple sources of sustainable biomass fuel to operate the
plant.
As a result of this action, the County Special Management Area (SMA) permit requires
modification since it currently restricts the plant operator to using only low-sulfur Class B sub-
bituminous coal. The substitution of other fuels is not allowed without approval from the State
Department of Health and County of Hawaii Planning Department.
This supplemental document has been provided to support the SMA permit application and
provide additional information that may not be provided insufficient detail to help facilitate
review and approval by the Planning Commission. This document focuses on the anticipated
impacts as a result of converting the HCPC power plant from coal to sustainable biomass.
While we do not anticipate any significant adverse affects, some changes in traffic and noise
patterns may result from localized truck traffic along the private Sugar Mill Road andappear to
be the concerns raised by the County and community.
The Hu Honua facility upgrades, modifications,and proposed operations would have a minimal
impact on existing infrastructure, including roads, water supplies and electrical power. No
sensitive biological or archaeological resources are present and there are no traditional cultural
uses on the industrially zoned property, which was formerly a coal-fired power plant and sugar
plantation mill for the last century. No adverse impacts are foreseen.
1| Page HU Honua Bioenergy January 2010
GENERAL INFORMATION
SMA Applicant Hu Honua Bioenergy, LLC
& Site Address: 28-283 Sugar Mill Road
Pepeekeo, HI 96723
Tax Map Key: 2-8-9:104
Owner: Hu Honua Bioenergy, LLC
City Financial Tower
201 Merchant Street, Suite 1830
Honolulu, HI 96813
PROJECT DESCRIPTION
Hu Honua Bioenergy, LLC proposes to upgrade and modify the existing HCPC power plant on
TMK (3rd) 2-8-08:104, a 25.57-acre parcel in Pepeekeo, Hawaii, to produce electricity for sale
using sustainable biomass as the fuel source. See Figure 3 of the application.
The “Hu Honua Facility” or the “Facility” is located at latitude 19º50'15" N and longitude
155º6'25" W in Pepeekeo, on the east coast of the island of Hawaii on a 25.57-acre site.The
site abuts the Pacific Ocean on its eastern side and is surrounded by cultivated and uncultivated
unpaved land on the other sides. The land use in the vicinity of the Facility is rural. The town of
Pepeekeo is about 3,000 feet southwest of the facility and the nearest city, Hilo, is 8 miles south
of Pepeekeo. The peak of Mauna Kea is located about 25 miles to the west and rises up to an
elevation of 13,796 feet (4,205 meters), with a steady slope down toward the sea.
The site includes buildings that house the boiler, steam generator, and biodiesel generator. Two
new buildings will be constructed to support the chipping operations. A new 10,000-gallon
biodiesel fuel tank will be installed to replace the existing 147,000-gallon oil storage tank. A
buffer of trees separates the buildings from the ocean and adjacent lots
Hu Honua will acquire sustainable biomass material from several sources along the Hamakua
coast as well as other private locations throughout the east and south regions of the island.
Biomass will generally be delivered in chipped form, but the plant will store whole logs for
processing into chips if necessary. The plant will require approximately 260,000 tons of biomass
annually and employ 28 to 30 workers to operate the plant. Feedstock will be transported to the
Facility via commercial trucks and the plant will maintain two to four weeks of fuel at the plant
site. Chips will be stored ona paved surface along the south boundary of the property.
The property iszoned industrial with a small portion zoned agricultural (remnants from sugar
plantation era). The fuel stock is sustainable biomass wood material and does not
spontaneously combust and isdifficult to ignite in the local humid environment, thereby
imposing only a minimal fire risk. Currently, much of the land surrounding the Facility is
2| Page HU Honua Bioenergy January 2010
undeveloped; however, there are a few single family residences zoned in close proximity as a
result of recent subdivision alterations. Any landscaping will use primarily native species.
ENVIRONMENTAL SETTING, IMPACTS AND MITIGATION MEASURES
The project site is a 25.57-acre parcel located on along the shoreline in Pepeekeo,
approximately 10 miles north of Hilo center.Trees and other masking vegetation exist along the
property boundaries and in small buffer areas around the plant. The site was used in the past
as a sugar mill facility and as coal-fired power plant until December 2004. Adjacent land use
consists of mostly agricultural zoned property, but some sites along the north boundary of the
property are zonedsingle family residence.
Climate, Geology, and Soils
Pepeekeo is located north of Hilo on the eastern side of the island of Hawaii.The area's
topography is mostly sloping, from the tops of the scenic Mauna Kea and Mauna Loa mountains
to the sea. The Hilo region has a warm semitropical climate and experiences abundant rainfall
without the droughts and shortages that trouble other parts of the island. The rain, which
generally falls during the night, keeps the area fresh and green. Hilo's rich soil is conducive to
the growth of a variety of diversified agricultural products.
The defining characteristics of the wind flow around the site are the trade winds and Mauna
Kea. The meteorological data used to create these were collected at the Hilo International
Airport located approximately 9 miles south of the proposed project. The trade winds blow from
the northeast during the daytime at speeds of up to 20 miles per hour. This is due to a semi-
permanent high-pressure cell over the Hawaiian Islands, which occurs predominantly during
daytime hours.Another notable feature is the persistent, slower winds from the southwest. This
is due to the drainage of cool air flowing down the slope of Mauna Kea. This nighttime radiative
surface cooling generates currents that persist, like the trade winds, across all seasons. The
nighttime drainage winds are more specific in direction than the trade winds. Seasonal
variations in Pepeekeo are minimal, with mean temperatures varying by only 5 degrees
Fahrenheit, between 76 to 71 degrees throughout the year. The Pacific Ocean and the low
latitude of the site both contribute to this consistency. In addition to the small seasonal
variations in temperature, diurnal variations are also minimal. The eastern coast of the island of
Hawaii, where the Facility is located, receives most of the island’s rain. Hilo averages 128
inches annually. In addition to rainfall, the region is susceptible to hurricanes, which disrupt the
average wind and rain patterns.
Soils are identified as being of the Hilo series, consisting of well drained silty clay loams. These
soils formed in aseries of volcanic ash layers that gave them banded appearance. The
representative profile is that of surface layer dark brown silty clay loam about 12 inches thick;
subsurface is about 48 inches thick and consists of dark brown, dark reddish-brown, and very
dark grayish-brown silty clay loam. Permeability is rapid, runoff is medium and erosion hazard is
3| Page HU Honua Bioenergy January 2010
slight to moderate (Source: U.S. Department of Agriculture, Soil Conservation Service). The
project site does not appear to be subject to subsidence, landslides or other forms of mass
wasting.
In general, geologic conditions impose no constraints on the facility andit is not imprudent to
implement the planned development.
Drainage, Water Features and Water Quality
The plant is not located near a perennial surface water body and there are no known areas of
local (non-stream related) flooding present in the area. The Federal Emergency Management
Agency’s Flood Insurance Rate Map (FIRM) shows that the plant is in Flood Zone X, outside of
the 500-year flood plain. Maps printed by the Pacific Tsunami Warning Center and the Hawai‘i
County Civil Defense Agency show the parcel outside of anarea that should be evacuated
during a tsunami warning.
The Facility is required to follow County regulations and policies, among them Chapters 10 and
27 of the Hawai‘i County Code. Chapter 27 requires the difference between pre-development
and post-development runoff to be contained onsite, limiting impacts. Furthermore, Chapter 10
requires measures to prevent erosion and sedimentation. Existing infrastructure accommodates
storm runoff on-site. All storm water is directed and collected for discharge through aprimary
outfall known as outfall 001.
The project will notdisturb more than one acre of soil during construction; therefore, a National
Pollutant Discharge Elimination System (NPDES) Notice of Intent for General Permit –
Construction, is not necessary from the Department of Health. However, best management
practices (BMPs) will be instituted during plant upgrade and construction. These measures may
include the following:
•Restoring and stabilizing disturbed areas, and using hydro mulch, geotextiles, or
binding substances, as soon as possible after working;
•Placing structural controls including silt fences, gravel bags, sediment ponds, check
dams, and other barriers in order to retard and prevent the loss of sediment from the
site;
• Minimizing disturbance of soil during periods of heavy rain;
• Constructing a stabilized construction vehicle entrance, with designated vehicle wash
area that discharges to a sediment pond;
•Maintaining BMPs; and
• Cleaning up significant leaks or spills and disposal at an approved site, if they occur.
Flora, Fauna and Ecosystems
4| Page HU Honua Bioenergy January 2010
The natural vegetation is common to the region and consists of various weed species, Guinea
grass, and California grass and remnant sugar cane. No faunal survey was conducted but
rodents and birds are present.The entire property has been used for heavy industrial and
agricultural uses since the late 1800’s that would make the prospects of having endangered
plant or animal life quite remote.There are no records of the site being the habitat for rare or
endangered plant or animal species, and as such operations are not likely to have adverse
impacts to biological resources. There are no known endangered plant or animal species on
the subject property, nor is the subect property within any known critical habitat. Overall impact
to flora and fauna is expected to be negligble since the plants are alien and introduced species
Noise and Scenic Resources
Noise from the Facility operations will be moderate and derived mainly from the boiler
operations and from fuel handling equipment. Ambient noise levels in the vicinty of the Facility
are affected by traffic from Hawaii Belt Road and the subdivisions surrounding the Facility. As in
industrial operation, noise levels are expected to exceed residential noise levels on-site. Sound
levels from the power plant will conform to residential limits at the nearby residences through
distance, enclosing equipment or structures where high decibels are created, maintaining
vegetated barriers, and avoiding activities that generate loud decibel sounds, such as the
morning steam whistle.
Noise from truck traffic on Sugar Mill Road will be limited to daylight hours, and restrictions such
as prohibiting ‘Jake Brakes’ will be employed.
The area does not contain any sites that are considered significant for their scenic character in
the Hawai‘i County General Plan. The area is designated as an industrial and agricultural area
where the scenic considerations are not paramount.
The Facility operations, with noted improvements, would not measurably affect noise levels or
scenic sites recognized in the Hawai‘i County General Plan.
Air Quality
The federal government has set standards, specifically the NAAQS, for ambient concentrations
of six “criteria” pollutants to protect human health. These health-based standards represent a
threshold below which health impacts are not expected. The pollutants include ozone (O),
3
nitrogen dioxide (NO), sulfur dioxide (SO), carbon monoxide (CO), and particulate matter less
22
than 10 microns in diameter (PM) and particulate matter less than 2.5 microns in diameter
10
(PM).(.) An area with ambient air concentrations below the NAAQS levels is said to be “in
2.5
attainment.” The number of exceedances allowed depends on the pollutant considered and the
averaging time, but is typically only once per year. The state of Hawaii has been designated “in
attainment” of the NAAQS for all criteria pollutants.
The HDOH has established its own, generally stricter, standards for the criteria pollutants,
known as the SAAQS. Like the NAAQS, the SAAQS specify concentration standards for a given
5| Page HU Honua Bioenergy January 2010
averaging time for a given pollutant. The pollutants with short-term standards are those with
short term health effects, and those with long-term averaging times reflect those with long term
health effects. It is not uncommon for the same pollutant to have multiple averaging times, for
example.HDOH operates ambient monitoring stations in various locations throughout the state.
Monitoring data collected between 2005 through 2007 show no exceedances of the NAAQS or
SAAQS.
Hu Honua proposes to operate the following equipment:
• Babcock & Wilcox Boiler (approximately 250,800 lb/hr of steam), the principal emission
unit, will be equipped with
Electrostatic Precipitator (ESP)
Controls equivalent to the Nalco Rotating Over Fire Air (ROFA) System
Controls equivalent to the Nalco Rotating Mix (ROTAMIX) Urea Injection
System
Trona or lime injection as necessary
• Steam Powered Turbine Generator (Gross Power Output of 23.8 MW, Net Power
Output of 21.5 MW)
Other insignificant sources (as defined by the State regulations) include:
•836 kW biodiesel emergency engine generator
• 10,000-gallon biodiesel polyethylene storage tank
• 250-gallon biodiesel day tank
• Electric/steam chipper operating within an enclosed chipper building with building dust
collector. Contract will require wood to be received within a certain moisture range,
thereby further limiting PM10 emissions
An air quality impact assessment has been performed to estimate maximum off-site
concentrations of CO, NO2, PM10, PM2.5, and SO2. The analysis was performed to
demonstrate that the operations of the Facility will not cause or add to an exceedance of an
NAAQS or SAAQS. The impact analysis was performed for multiple operating scenarios to
illustrate that the maximum potential concentrations have been identified. The operating
scenarios vary depending on the pollutant and averaging times and represent the boiler at
maximum firing load, minimum firing load, and during startup conditions. Scenarios were also
included for the diesel generator operations. The modeling analysis conducted illustrated that
the project will not cause an exceedance of any NAAQS or SAAQS.
The Hawai‘i Department of Health (“DOH”) has an U.S. Environmental Protection
Agency (“EPA”) approved Title V operating permit program under the U.S. Clean Air Act, which
isimplemented in Chapter 11-60.1 of Hawai‘i Administrative Rules (“HAR”). Air
6| Page HU Honua Bioenergy January 2010
pollution sources subject to the federal Title V requirements are called “covered sources”
inHawai‘i’s rules. Sources not subject to Title V are called “non-covered sources” and
must meet the requirements of Subchapter 4 as well as other general air pollution
control provisions in Chapter 11-60.1.
The Facility’s projected emissions of criteria pollutants are more than 100 tons per year;its
emissions of hazardous air pollutants are greater than 10 tons per year individually and 25 tons
per year in total.
The Facility’s boiler is not exempt per any of the exemptions listed in HAR § 11-60.1-82(d), nor
is operation of the boiler at the Facility considered an “insignificant activity” per § 11-60.1-82(e)
through § 11-60.1-82(g). Therefore, the boiler is subject to the requirements for covered sources
per § 11-60.1-82. The covered source will comply with the requirement of § 11-60.1-85 for
submitting a compliance plan by listing all applicable requirements and the compliance status of
each requirement. Annual emissions from the boiler are predicted to exceed these significance
thresholds for CO, NOx, PM, and PM10 and so BACT is required for these pollutants. According
toHAR § 11-60.1-132, the requirements for a Prevention of Significant Deterioration (PSD)
review are applicable to any “major stationary source” or “major modification” as defined in HAR
§ 11-60.1-131. The major stationary source threshold for a non-fossil-fuel-fired boiler is 250 tons
per year of any regulated air pollutant. The air quality impact analysis shows that controlled
emissions of regulated air pollutants will remain under 250 tons per year, and PSD criteria
would be satisfied.
Based on the foregoing discussion, it is concluded that the proposed facility will have a minimal
impact on local air quality both on a short and long-term basis and will comply with existing
State and federal ambient air quality standards.
Hazardous Substances, Toxic Waste and Hazardous Conditions
Wood ash will be generated as a byproduct from the combustion of sustainable wood biomass.
Both fly and bottom ash will be generated and collected for beneficial use or disposal off-site. It
is anticipated that the majority of the ash will be beneficially used in off-site forest management,
whereby the ash will be applied to the ground and cultivated into new plantings to return
valuable nutrients back to the forest. Other beneficial uses may include using the ash as
general fill or soil amendments. The facility will obtain a solid waste beneficial use permit from
the State DOH Solid Waste Branch to allow such activity. Any excess or non-value ash will be
disposed in one of the County licensed landfills.
Normal or regular solid waste from plant activities will be disposed of by commercial haulers at a
County licensed landfill or facility.
The Facility may on occasion generate hazardous small quantities of waste from certain
maintainence activities, such as turbine blade wash, laboratory chemicals, or other equipment
servicing. The Facility is registered as a Small Quantity Generator (> 100 kg, but less than
1,000 kg, per month) with the State and EPA. Any hazardous wastes generated will be
containerized, accummulated for less than 180 days, and disposed of at a licensed Treatment,
Storage, or Disposal Facility (TSDF) on the mainland.
7| Page HU Honua Bioenergy January 2010
Used oils generated from equipment will be recycled in accordance with State regulations (HAR
11-279).
Socioeconomic
Sugarcane cultivation was once the economic mainstay of Pepeekeo. With the closing of the
sugar mill in 1996 and the general demise of commercial agriculture, independent growers are
leading the way in putting former plantation land into alternative crops. The most common
products are papaya, ginger, and flowers. The Facility would affect the township of Pepeekeo,
which has a small residential population. Data from the 2000 Census reported a population of
1,697 people consisting of 443 families residing in the Pepeekeo Census Designated Place
(”CDP”). The average family size was 3.2 persons. The reported median annual income per
family was $35,345.
Approximately 16.9% of the families (75 families) had income below the
New homes are being developed along Sugar Mill Road and by Pepeekeo Point.
poverty level.
One small industrial property is located about ½ mile west of the facility at the four way stop
along Sugar Mill Road.
The facility is being modified and upgraded in conformance with its designated industrial zoning
and providesa meaningful level of public benefit through the orderly development of private
industrial facilities providing jobs and tax revenues, in keeping with State and County plans.
Cultural and Archaeological Resources
The property is is not listed as a historic property in the Hawaii State Register of historic places,
has not been determined to be eligble for inclusion in the National Register of Historic Places,
and is not profiled as a significant cultural and/or historic site in the General Plan. A “no effect”
determination letter has been requested from the State Department of Land and Natrual
Resources (DLNR) Historic Preservation Division for the subject property. In 2003, a field
inspection was conducted of the surrounding properties and a portion of the subject property as
part of a SMA application (SMA 03-009) for new residential development located in the makai
lands of the former Pepeekeo Sugar Plantation (aka Hilo Coast Processing Company), which is
located on a portion of the site of the former Hilo Coast Power Company (HCPC). The filed
inspection was conducted to determine the presence/absence of historic sites, and the need, if
any, for additional archeological and historical research for any subsequent development
planning and permit applications. It was found that there are no historic sites, which is due,
most likely, to the fact that a century or more of intensive sugarcane cultivation occurred in the
area. The DLNR agreed with the field inspection and believes that there were no historic
properties present. Construction of the new structures will reside over existing footprints of
previous buildings.
Except for fishing along the shoreline, no valued cultural, historical, or natural resources exist on
the property and there is no evidence of any traditional or customary Native Hawaiian rights
being practiced on the subject property.
In the unlikely event that archaeological resources or human remains are encountered during
upgrade activities within either the proposed easement or applicant’s property, work in the
8| Page HU Honua Bioenergy January 2010
immediate area of the discovery will be halted and SHPD contacted as outlined in Hawai‘i
Administrative Rules Title 13, Chapter 275-12.
Infrastructure
All essential utilites required are available to the site. Police services are located approximately
10 miles from the Facility, and fire services are available from the Central and Kaumana
Stations. Emergency medical services are available from the Hilo Medical Center on Wainuenue
Ave. in Hilo. The following infrastructure issues are discussed in the body of the SMA
Amendment Application:
Potable and Non-Potable Water Sources
Sewage Disposal
Telephone
Electricity
Solid Waste
The Facility will not have any substantial impact on existing utilities or public services.
Transportation
Primary access to the facility will be from Hawaii Belt Road (Highway 19). As has been the
case during the duration the site served as a sugar mill, vehicles and trucks will be required to
turn onto Sugar Mill Road from Highway 19 from both directions. Vendor and contractor traffic
will primarily come from the south, or Hilo direction, and make right turns into Sugar Mill Road.
Fuel source traffic will come from both directions depending upon which tract of land supplies
the sustainable biomass fuel. In general, Highway 19 provides adequate left turn
accommodations for trucks having to turn from the southbound direction, and has a 100 foot
wide right of way. Adequate shoulders exist to allow traffic to pass turning traffic.
Traffic conditions of the existing HCPC coal power plant included routine daily traffic of
employee vehicles, contractors, vendors, and visitors. During non-shift changes, the HCPC
power plant averaged three to four vehicles and/or trucks per hour. Coal was delivered on a
non-routine basis three to four times per year. During this delivery period, large dump trucks
were used 24 hours per day for up to seven days to deliver the coal from the harbor to the site.
Routine daily traffic patterns and number of vehicles per hour for employees, contractors,
vendors and visitors will essentially be the same for the proposed sustainable biomass
operations as with prior coal operations, averaging three to four vehicles per hour outside of
shift change hours.
The most significant change in traffic conditions will result from fuel delivery, whereby
sustainable wood biomass will be delivered daily,asopposed to the non-routine continuous 24-
7 traffic pattern of the previous HCPC plant. Biomass fuel deliveries will be limited to daylight
hours. It is anticipated that sustainable biomass fuel delivery trucks may average 5 to 6 per
hour during daylight hours only.
9| Page HU Honua Bioenergy January 2010
Truck traffic along Sugar Mill Road will have to pass by twelve (12) Ag-20a lots which border
either side of the road between Highway 19 and the Railroad Ave (the four way stop). Trucks
will be diverted from Sugar Mill Road at the four way stop to a former sugar haul road which will
bring large vehicle traffic into the Facility from the south to avoid the residential lots at Pepeekeo
Point area. Only two Ag-20a lots will be affected by this traffic between the four way stop and
the plant.
The Facility operations will cause slight increases in daily traffic patterns along Hawaii Belt Road
and along Sugar Mill Road. Traffic impact is projected to be minimal.Given the traffic
characteristics of the project, along with the fact that the Sugar Mill Road is designed to
accommodate industrial traffic, no traffic impact analysis is necessary.
10| Page HU Honua Bioenergy January 2010
SECONDARY AND CUMULATIVE IMPACTS
The planned upgrade, modifications and new construction is minor and does not appear to have
the potential to involve any secondary impacts, such as population changes or effects on public
facilities. Cumulative impacts result when implementation of several projects that individually
have limited impacts combine to produce more severe impacts or conflicts in mitigation
measures. The adverse effects of the Facility are very limited in severity, nature and
geographic scale. At the current time there do not appear to be any roadway, utility or
development projects being undertaken in the area that would combine in such a way as to
produce adverse cumulative effects or involve a commitment for larger actions. Industrial uses
such as the power plant were specifically planned as part of these larger uses, and
infrastructure is being planned accordingly.
REQUIRED PERMITS AND APPROVALS
The development of the facility requires granting the following permits and approvals:
•County of Hawai‘i, Department of Public Works, Building Division Approval and
Building Permit
•County of Hawai‘i, Department of Public Works, Engineering Division, Grading
Permit
•County of Hawai‘i, Planning Department,SMA Permit Amendment
•State of Hawai‘i, Department of Health, National Pollutant Discharge Elimination
System Individual Permit (NPDES) for storm water and non-contact cooling water
•State of Hawai‘i, Department of Labor, Boiler Inspection Certification
•State of Hawai‘i, Department of Health, Covered Source Permit
•State of Hawai‘i, Department of Health, Wastewater Permit for settling ponds
•State of Hawai‘i, Department of Health, Solid Waste Permit for beneficial use of ash
CONSISTENCY WITH HAWAI‘I STATE PLAN
Adopted in 1978 and last revised in 1991 (Hawai‘i Revised Statutes, Chapter 226, as amended),
the Plan establishes a set of themes, goals, objectives and policies that are meant to guide the
State’s long-run growth and development activities. The three themes that express the basic
purpose of the Hawai‘i State Plan are individual and family self sufficiency, social and economic
mobility and community or social well-being. The Facility promotesthese goals by maintaining
clean, sustainable industrial and agricultural activity to the North Hilo district, thereby enhancing
quality-of-life and economic and social well-being of the local population.
CONSISTENCY WITH THE HAWAII CLEAN ENERGY INITIATIVE
The Hawaii Clean Energy Initiative was signed by the US Department of Energy, the State of
Hawaii and the local electric utilities in October 2008. As part of that document certain specific
projects were identified that supported the State of Hawaii’s goals to reduce dependency on
11| PageHU Honua Bioenergy January 2010
imported oil. The Hu Honua project was specifically identified as a project that was consistent
with that goal.
CONSISTENCY WITH HAWAI‘I COUNTY GENERAL PLAN
The General Plan for the County of Hawai‘i is a policy document expressing the broad goals
and policies for the long-range development of the Island of Hawai‘i. The plan was adopted by
ordinance in 1989 and revised in 2005 (Hawai‘i County Planning Department). The General
Plan itself is organized into thirteen functional elements. The facility use is consistent with the
goals, policies and objectives, standards, and principles for several functional areas.
HAWAI‘I COUNTY REGULATIONS
The project site is zoned Industrial (MG-5a).The land uses in the immediate area are a mix of
industrial, agricultural and residential uses. The closest residences are located along the north
boundary of the plant.Under Section 25-5-100, Hawai‘i County Code, the General Industrial
(MG) district applies to areas for uses that are generally considered to be offensive or have
some element of danger. Permitted uses include a wide variety of business activities including a
power plant, for example, which has been the intended use within this designation.
Aportion of the property is situated within the County’s Special Management Area (SMA) and
an existing permit is being amended to accommodate the change inuse for the land.
HAWAI‘I STATE LAND USE LAW
All land in the State of Hawai‘i is classified into one of four land use categories –Urban, Rural,
Agricultural, or Conservation –by the State Land Use Commission, pursuant to Chapter 205,
HRS. The property is in the State Land Use Urban District. The proposed use is consistent with
intended uses for this land use district.
DETERMINATION
Based on the assessment above and the findings below, the facility will not significantly alter the
environment, as impacts will be minimal.
12| Page HU Honua Bioenergy January 2010
March 1, 2010
BJ Leithead Todd, Planning Director
Planning Department
County of Hawaii
Aupuni Center
101 Pauahi Street, Suite 3
Hilo, Hawaii 96720
Dear Ms. Leithead Todd:
Amendment to Special Management Area Use Permit No. 221
Applicant: Hu Honua Bioenergy, LLC (formerly Hilo Coast Power Company)
Subject: Request for Additional Information for County Environmental Report
Tax Map Key: 2-8-8: 104 (formerly 2-8-007: Portion of 53)
The following information is provided in response to your letter of January 26, 2010 requesting additional
information with regard to Hu Honua’s request for amendment of SMA Permit No. 221:
Response to Item #1(A).
Hu Honua intends to replace its existing covered source air permit (CSP -
0229-02-C). Anapplication for anew covered source permit was submitted to the State of Hawaii
Department of Health (DOH)on August 28, 2009. The DOH Clean Air Branch is the agency authorized to
issue covered source air permits in Hawaii. The DOH reviewed the application and notified Hu Honua on
October 22, 2009 that the application was deemed complete (i.e., all required information was submitted).
The DOH staff is now in the process of verifying the modeling and air quality assessment completed by
Hu Honua and evaluating the permit request. A draft permit is expected to be issuedby the DOH as early
as March 2010. A public notice and hearing would likely follow within two months from Hu Honua’s
acceptance of the draft permit. If the process continues according to normal Departmental review time
frames, the new permit could be issued by August 2010.
HuHonua will require a new covered source air permit because it has the potential to emit more than 100
tons per year of CO, NOx, SOx or PM, or more than 25 tons per year of HAPs. The covered source
permit will include provisions for testing, monitoring and recordkeeping to ensure that emissions are
controlled and conform to applicable state and federal regulations. To put these values in perspective
and according to recent studies from the EPA, 100 tons of emissions per year is roughly equivalent to the
annual emissions of 16.5 passenger vehicles or the yearly COemissions from the energy use of 8.1
2
single family homes. The refurbished plant, which will primarily use sustainably grown feedstock from
local timber plantations, will emit substantially less than it did when coal and oil were itsprimary fuels.
For example, the existing air permit allows total potential emissions of 3,853 tons per year and in the last
full year of operation, the facility emitted a combined 1,624 tons while operating for a period of 4,348
hours. In contrast, the newly refurbished plant is expected to have total emissions of approximately 838.5
tons per year while operating up to 8,040 hours clearly suggesting significantly reduced emissions on
both an hourly and aggregate basis.These improvements, as further described below,are due in large
part, to the change from fossil fuels to biomass and the incorporation of best available control
technologies into the design of the refurbished plant.
Air impacts for CO, NOx, and PM will mitigated through installation of state of the art emission control
equipment and improved operating characteristics(e.g., better combustion in theboiler).To achieve
these requirements, the boiler will have an electrostatic precipitator (ESP) that will reduce the
uncontrolled level of PM by at least 95 percent. The boiler will utilize an air mixture system that will
improve combustion so that NOx and CO emissions are reduced. A urea injection system will also be
added to further reduce NOx. Lastly, a lime or equivalent material will be injected into the boiler or boiler
exhaust to reduce hydrogen chloride and sulfur oxide emissions to levels below concern.
City Financial Tower 201 Merchant Street, Suite 1830Honolulu, HI 96813
(P) 808.521.1600 (F) 808.521.1603 www.huhonua.com
Response to Item #1(B).
HAR Title 11, Chapter 46, Community Noise Control is the applicable standard
for noise control. Under this State of Hawaii standard, the maximum permissible sound levels for Class C
zoning districts (areas zoned agriculture, country, industrial or similar type) is 70 dBA 24 hours per day, 7
days per week at any point at or beyond the property line; this level should not be exceeded for more than
10% of the time within any twenty minute period, except by permit or variance. Hu Honua istargeting
significantly lower noise levels, possibly in the 55 dBA range,at the nearest residence. Consequently, Hu
Honua will not need a noise permit from the DOH and does not plan to request a permit or variance.
Ho Honua intends to implement a number of measures to control and mitigate sound emanating from its
facility.For example,Hu Honua will increase the level of vegetation surrounding the facility.Hu Honua
will also install acoustic panel building siding to absorb machinery sounds and silencers on safety release
valves (which are used as a protection device for steam boiler malfunctions)as well as locate equipment
in such a manner so as to utilize the natural favorable acoustic limiting features of the sitetopography.
Response to Item #1(C).
The Hawai’i DOH Clean Water Branch is the State agency authorized by the
EPA to evaluate and issue wastewater and storm water discharge permits known as the National
Pollutant Discharge Elimination System (NPDES). Under this program, all facilities which discharge from
any point source into waters of the United States are required to obtain a discharge permit. Hu Honua
intends to conform to regulations and controls required by the DOH and, as such, will be subject to the
following permits and issuance schedules:
Storm Water Notice of General Permit Coverage (NGPC)
1. , Industrial Activity. A NGPC
for the facility was issued on October 3, 2008 by the DOH Clean Water Branch to cover
storm water discharges associated with the industrial activities, even though the existing
facility is not operating or producing electricity. This permit expires on October 21, 2012,
unless a Notice of Cessation (NOC) is submitted by the facility. Hu Honua intends to
operate and comply with this permit until the Individual Permit covering storm water is
issued for the plant; expected before the current permit expires.
Individual NPDES Permit, Non-contact cooling water, Industrial Discharges and
2.
Storm Water.
A new Individual NPDES permit will be required before discharges
commence for the renovated facility. The Permit will cover: (i) non-contact cooling water
from three on-site water wells used for temperature control in the steam condenser on
the turbine, (ii) miscellaneous plant maintenance water, and (iii) storm water discharges.
The individual permit covering the former plant required the completion of a yearly
Bottom-Biological study designed to assess the impact of water discharged from the plant
into the ocean. The results of these studies showed the plant’s water discharge did not
significantly impact the marine environment. The renovated plant will produce similar
nature and quantity of water as the former plant, and therefore, will not have significant
impact on the marine environment. Hu Honua expects it will be required by the State to
perform similar annual marine monitoring as part of conditions of the permit.
Storm Water NCPC Construction Activity.
3. -Generally, a facility conducting
construction activity and disturbing more than one acre of ground would need to submit a
Notice of Intent to discharge storm water and obtain a NGPC for Construction Activity.
While Hu Honua does not expect to disturb more than one acre, the facility would be
required at a minimum to modify its existing Industrial Activity NCPC to include the
construction activities. The purpose of modifying the existing NGPC permit is to assure
an approved storm water pollution control plan stipulates best management practices for
workers during construction. Modifications to the current NGPC and associated storm
water pollution control plan will be required, approved, and put in place prior to
commencing construction.
City Financial Tower 201 Merchant Street, Suite 1830Honolulu, HI 96813
(P) 808.521.1600 (F) 808.521.1603 www.huhonua.com
Response to Item #2.
Hu Honua expects to source the majority of its feedstock from existing
sustainable forest plantations located onor near the Hamakua Coast of Hawaii. Feedstock from land
clearing may also be used on an opportunistic basis. Approximately two-thirds of the feedstock could be
delivered to the plant chipped while the remainder will arrive in log form.We expect 5 to 6 truckloads per
hourwill be required to deliver the necessary volume of fuel to the Hu Honua facility.Parties involved in
the harvest and haul of fuel tothe plant will be required to comply,where applicable, with regulations
such as the Hawaii County Code Sections 24-164 and 24-165 and the Hawaii State Department of Land
and Natural Resources Best Management Practices developed as part of the Watershed Protection and
Management Program (see attached Exhibit A). It is our understanding that these practices would
include measures to mitigate potential invasive species and control the amount of mud and debris
deposited onto the roadways by vehicular traffic. In addition, Hu Honua intends to confer with the Hawaii
Invasive Species Council and seek recommendations regarding the management of invasive species,
such as Coqui frogs.According to the Coqui Frog Working Group, there are already reports of Coqui
frogsin the Pepeekeo area (see attached map).
Hu Honua is still negotiating terms for sourcing, harvesting and hauling.It is likely that third-party
harvesters and haulers will be contracted directly or the parties selling the feedstock to Hu Honua. In this
scenario Hu Honua will be accepting and purchasing fuel at the plant gate in chipped or whole log form.
We expect harvested trees tobe allowed to air-dry in log form in the field prior to chipping and delivery to
the plant. This will significantly reduce the overall weight of material to be transported from the field to the
plant. As previously mentioned, noise in the vicinity of the plant created by delivery vehicles will be
mitigated by efforts such as re-routing the access road and requiring delivery vehicles to refrain from the
use of jake brakes. Hauling will also be limited to daylight hours.
Response to Item #3.
The attached map indicates properties that we believe have existing dwellings
within approximately a 1000 and a 2000 foot radius of the facility.The proposed access road to be used
to transport the feedstock from the sustainable forestry operations tothe facility (see attached map) has
been designed to minimize impact on nearby residential properties.Lot #149 is the closest dwelling to the
facility, is the home of the Continental property care-taker,andwas formerly part of the office complex for
the facility.
The plant stack height will be reduced from 190 to 140 feet. On February 18, 1972 a variance approving
a 140 foot stack height was issued by the County of Hawaii Planning Department (see attachment). As
shown in the attached photographs, lowering the stack height will significantly reduce its visibility from
many pointsof reference.The siding of the boiler house will also be camouflaged via paint color
selection (see attached photographs for potential color schemes).
Response to Item #4.
Theoriginal HCPC mill was still in operation as a sugar mill when the Northeast
Hawaii Community Development Plan (the “Plan”) dated June 26, 1979 was approved. At that time,
bagasse was the primary fuel for the power plant. The Plan encouragedlegislative support of sugar
industry initiatives and contemplated the continuing operation of the HCPC mill in the region. In that
regard, the Hu Honua project to revitalize the old mill power plant is consistent with the Plan.
The Plan also focused on the potential benefit of developing a fledgling timber industry. Specific note
was made of a January 1976 report by the Department of Land and Natural Resources on “Forestry
Potentials for Hawaii”. The Capital Chip operation was identified and further development of the forestry
industry encouraged. One of the key economic benefits of the Hu Honua project is the synergy of the
project with the start-up of the Tradewinds veneer mill and development of a healthy sustainable forestry
industry. Hu Honua will provide a market for the portion of the timber product harvested that is unsuitable
for use in the manufacturing of veneer. This will improve the operating metrics of the forestry portion of
the supply chain and, in turn, could provide a more stable job creation environment.
City Financial Tower 201 Merchant Street, Suite 1830Honolulu, HI 96813
(P) 808.521.1600 (F) 808.521.1603 www.huhonua.com
Attachment 3
Petition In Support of
The Hu Honua Project
PetitioninSupporthasbeen
removed,butthephysicalcopy
canbeviewedatthePlanning
Department.
Hu Honua Bioenergy, LLC January 2010
Attachment 4
Hu Honua Advertisement In
Hawaii Tribune Herald
June 2009
Hu Honua Bioenergy, LLC January 2010
ATTACHMENT 5
Existing SMA Permit No. 221
And
Prior SMA Permits
Hu Honua Bioenergy, LLC January 2010
Attachment 6
Pepeekeo Point Shoreline
Declaration of Covenants,
Conditions & Restrictions
Hu Honua Bioenergy, LLC January 2010
ATTACHMENT 7
Flood Insurance Rate Map Designation
Hu Honua Bioenergy, LLC January 2010
Attachment 8
Request to DLNR
For
“No Effect Letter”
Hu Honua Bioenergy, LLC January 2010
January 14, 2010
Dr. Theresa Donham
State Historic Preservation Division
40 Po`okela St.
Hilo, HI 96720
SUBJECT: Chapter 6E-42: Request for Review of a Draft Report of a Literature
Review for the Proposed Hu Honua Bioenergy Facility, Pepe`ekeo,
Kahua Ahupua`a, South Hilo District, Hawai`i Island, State of Hawai`i
TMK: (3) 2-8-008: 104.
Dear Dr. Donham:
At the request of the HHonua Bioenergy LLC, Pacific Consulting Services, Inc.
(PCSI) conducted a literature review for a proposed bio-energy facility in Pepe`ekeo,
Hawai`i Island. H Honua Bioenergy LLC intends to construct a chip processing building
and a chip storage building as part of their plan to create a biomass energy production
plant. All of the proposed ground altering activities will take place within a single 25.57-
acre parcel at TMK: (3) 2-8-008: 104.
General Findings
Review of previous archaeological studies reveals that no historic properties
listed on the Hawai`i and/or National Registers of Historic Places are known to be
present in the project area. A previous field inspection of the project area demonstrated
that the area has been fully developed as a coal-to-energy power plant. During the
previous study by Paul H. Rosendahl, Ph.D, Inc., no archaeological sites were observed
on the ground surface within the boundaries of the project area.
Historical accounts show that the subject parcel was fully developed as a sugar
th
mill by the mid-19 century. Soil survey data shows that the sediments in the area
consist of Hilo silty clay loams that were favored by commercial sugar cane operations.
Consequently, the entire project area, and much of the land surrounding it has been
previously altered through grubbing and grading.
Construction Specifications
Construction plans detailing specifications for the proposed biomass energy plant
show that excavations will extend to six feet in depth for two buildings measuring 180 x
40 feet.
Summary
The potential for encountering archaeological resources/historic properties is
considered to be minimal in the project area. Previous land-altering activities at the
project area do not preclude the possibility that sub-surface archaeological resources
exist in the area, but they do make it improbable.
Request for Concurrence With a Determination of “No Historic Properties Affected”
In view of the above facts, we recommend that a determination of “no historic
properties affected” be made for the proposed undertaking. Your agency’s review of and
concurrence with this determination are requested and we look forward to a timely
response. We would appreciate a response by February 14, 2010.
We look forward to receiving your review. Should you have any questions, please feel
free to contact me by telephone at 808-546-5557 X202 or by email at
steve.clark@pcsihawaii.com.
Sincerely,
Stephan D. Clark
Manager, Cultural Resources
Pacific Consulting Services, Inc.
ATTACHMENT 9
Pages from Site Lease
Hu Honua Bioenergy, LLC January 2010
Attachment 10
Letter from HDOH
RE: Existing Air Permit
Hu Honua Bioenergy, LLC January 2010
Attachment 11
Letter from HDOH
RE: New Air Permit
Application “Deemed Complete”
Hu Honua Bioenergy, LLC January 2010
ATTACHMENT 12
Request for Waiver of Requirement to
Conduct Shoreline Survey
Hu Honua Bioenergy, LLC January 2010
Former Plant Foot Print
Advanced Compliance Solutions, Inc
Scale:
NTS
PO Box 30094
FIGURE 1
Honolulu, HI 96820
Date:
Ph. (808) 349-9076 12/15/2009
Proposed Air Pollu-
tion Control Unit &
Stack Relocation
Proposed Chipper
and Chip Storage
Proposed Modifications
Advanced Compliance Solutions, Inc
Scale:
NTS
PO Box 30094
FIGURE 2
Honolulu, HI 96820
Date:
Ph. (808) 349-9076 12/15/2009
ATTACHMENT 13
List of Surrounding Property Owners
ListofSurroundingProperty
Ownershasbeenremoved,but
thephysicalcopycanbeviewed
atthePlanningDepartment.
Hu Honua Bioenergy, LLC January 2010