by NZcaver » Sep 3, 2009 4:50 pm
More from Fred Stone today. He is making a submission to the state on the draft Environmental Assessment, and asked me to post about it here on the forum. The following is the initial summary portion. The full document is many more pages long, and includes maps, diagrams, and references.
Comments on the Draft E.A. for Connections Charter School in Kaumana
Fred D. Stone, Ph.D
Sept. 2, 2009
SUMMARY
I am requesting that an Environmental Impact Statement be completed on the plan for Connections Charter School in Kaumana. The reasons are:
The Draft EA has not adequately assessed the potential significant impact of the proposed development on Kaumana Cave, which underlies a major part of the project area beneath the former TMK 2-5-06-4, the mauka lot currently combined with TMK 2-5-06-141 (see Figures 1,2,3 below). Hawaiian land law includes in property ownership not only the surface but the subsurface , including caves. It is therefore highly improper to leave out of the Draft EA a large and well known cave that underlies, and is part of the proposed parcel.
1. The survey showing the location of Kaumana Cave under the development was omitted from the Draft EA. This is a significant omission, given that the cave was surveyed by Island Survey as part of the Puainako Extension EIS (1993, p34). Although the Draft EA sites the Puainako Extension EIS, the map showing the cave location was inexpicably left out. An accurate map of the cave is crucial for designing surface structures to avoid safety issues during construction and to prevent damage or pollution to the cave. (see Figure 1 below)
2. The Draft EA does not include the relevant parts of the Hawaii State Cave Protection Law (SH2898), which should be included in the Final EA and EIS.
3. Hazards relating to construction over Kaumana Cave have not been addressed adequately: the depth of the cave and the thickness of lava overlying the cave have not been adequately measured, with related liability and safety issues for surface development and for roof collapse within the cave. Clearing and grading over the cave could also have significant impacts on the cave ecosystem and hydrology.
4. The issues regarding the placement of the school on an area with recent lava flows has not been adequately addressed: the entire development is on the 128 year old 1880-81 lava flow in the Mauna Kea/Mauna Loa Saddle zone, that regularly channels lava flows from Mauna Loa’s upper northeast rift zone.
5. The hydrology of the area is inadequately analyzed. A thorough hydrological survey needs to be included in the Final EA and EIS, as was done for the Puainako Extension EIS (Appendix F, Drainage). The 1880-81 lava flow followed an intermittent stream channel from above Kaumana Village to below the planned development. The entire length of Kaumana Cave beneath the development is a flood water channel on a perched aquifer. Runoff water from Kaumana Drive is channeled into the cave, and contributes to major flooding of the cave downslope.
6. Alternative sites are not adequately addressed, except to state that there aren’t any.
Given the serious potential environmental impacts of the development, other sites should be presented and reasons for their acceptance or rejection should be detailed.
7. The cave biology was not included in the Draft EA (Appendix B), although it has been thoroughly studied and is well known (Puainako EIS, Appendix D).
8. Alternative uses of Kaumana Cave and the State land overlying it have not been adequately assessed.
• Science: geology, vulcanology, biology, microbiology
• Tourism, recreation
• Education
• Religious and spiritual use
• Historical values
For those who would like to read the full version, contact Fred directly at fred[at]hawaii[dot]edu