Aloha, below are the comments that the O‘ahu Group submitted to in response to the “Punalu‘u Beach Homes Shoreline Protection Project Draft Environmental Assessment Anticipated Finding of No Significant Impact” posted in the April 8, 2017 Environmental Notice:
TO: Department of Permitting and Planning
CC: Punalu‘u Beach Lots Business Management Association,
Group 70 International, Inc. (dba G70)
RE: Punalu‘u Beach Homes Shoreline Protection Project Draft Environmental Assessment Anticipated Finding of No Significant Impact
To whom it may concern:
The Sierra Club of Hawai‘i’s O‘ahu Group offers the following comments under HRS §343 on the DEA (AFONSI) to construct a 634-foot-long shore protection structure on seven residential beachfront lots along 53-215 to 53-239 Kamehameha Highway in Punalu‘u.
Our review of the draft environmental assessment (DEA) for building a 634-foot-long concrete rubble masonry shore protection structure which will require a Shoreline Setback Variance Permit, a Special Management Area (Major) Permit, a Certified Shoreline Survey, Building Permits, and Grading, Grubbing, Trenching and Stockpiling Permits reveals various inadequacies and points of concern. We would appreciate it if the agency and/or applicant’s consultant could follow up with further analysis and answers to the questions below in a revised draft EA.
Problematic section: In Section 3.2 Soils and Shoreline Erosion Conditions, the DEA asserts that “in the long term, the new shoreline revetment will absorb wave energy, promote sand accretion, and slow the impacts from rapid erosion along the shoreline fronting the seven properties. The placement of this structure is not anticipated to cause adverse effects to the shoreline of adjoining properties.”
Discussion and Questions regarding Section 3.2: Claiming that a rubble mound revetment will absorb wave energy is unrealistic. It is easy to see reflected waves heading seaward from any similar revetment on local shorelines. This reflected wave interacts with incident waves to create increased scour in the nearshore zone, making sand deposition less likely. The claim that this structure will “absorb wave energy” is misleading.
Given the likelihood of reflected waves and increased sand scour, how can the DEA claim that the revetment will promote sand accretion? This is the sort of unsupported argument that has been used for years to justify armoring the O‘ahu shoreline and as a result we have an epidemic of beach narrowing, beach loss, reduced public access to the shoreline, and reduced open space – all of which are are intended to be increased and enhanced under the stated objectives of the City and County setback policy.
Additionally, there is no mention of the problem of flanking. At both ends of 634 feet of new revetment the structure will be almost vertical (12:1) and there will be accelerated erosion on unprotected lands. How will this be handled? How will the increased erosion elsewhere on this shoreline as a result of this armoring be mitigated?
Problematic section: In Section 3.5 Biological Resources, the DEA notes that “due to the site’s location, some threatened or endangered marine species may be present on the site or in the vicinity of the site”
Discussion and Questions regarding Section 3.5: As sea level rise threatens sandy shoals in the Northwestern Hawaiian Islands, the continued building of armored shoreline in the main Hawaiian islands greatly limits the habitat options for threatened or endangered marine species, such as native monk seal and green sea turtles. In the National Oceanic Atmospheric Association’s (NOAA) Pacific Islands Region Main Hawaiian Islands Monk Seal Management Plan, NOAA asserts that “coastal development may negatively affect the coastal habitats Hawaiian monk seals depend on by decreasing and degrading available shoreline habitat needed for resting, pupping, rearing, nursing, and molting. Less shoreline habitat, along with increased human presence in coastal areas, also increases the chances of human-seal interactions and seal disturbances.”
Has the applicant’s consultant and/or agency consulted with NOAA in consideration of monk seal and turtle habitat needs along the Punalu‘u coastline before submitting the DEA? If we know that threatened or endangered marine species may be present at the affected site, how does the DEA justify that there will be an AFONSI in regards to our impact to marine species, whose habitat may be negatively affected by coastal development?
Problematic Section: In Section 3.10 Traffic and Roadways, the DEA notes that “the construction of the shoreline revetment will not alter public roadways. While the project is not expected to have significant traffic impacts, the following mitigation measures are recommended for optimal traffic conditions during construction: 1) construction activities and construction material or waste should be located and stored away from vehicular traffic. Sight lines for drivers on the roadway should be carefully maintained. 2) Trucks delivering construction material and disposing of construction waste should be scheduled on weekdays during times of non-peak commuter periods (9:00 AM to 3:00 PM).
Discussion and Questions regarding Section 3.5: The two-lane Kamehameha Highway that will be used to bring in the necessary machinery, equipment, and supplies for the revetment project is highly utilized and frequently congested. This highway is the only access point to the Ko‘olauloa District and Punalu‘u area. Will the applicant adhere to the proposed mitigation measures to locate and store construction activities and materials away from the vehicular traffic, maintain sight lines for drivers, and deliver and dispose of construction waste during the suggested times of 9:00 AM to 3:00 PM?
Problematic Section: In Section 3.13.2 Cultural Resources, the two Hawaiian traditional practitioners that were interviewed by Keala Pono in the Ethnographic Survey noted observed changes in the Punalu‘u area. They noted that “the beach has eroded; and fish, limu, and other resources are scarcer than in previous years.” In addition, they shared concerns about this shoreline revetment project: “One concern is that the project could affect the shoreline in Punalu‘u, possibly further eroding the surrounding lands. Another voiced concern was that the walls near the Kamehameha Schools beach lots were believed to have had a negative impact on the rest of the shoreline.”
Discussion and Questions regarding Section 3.13.2: How is the agency and/or applicant’s consultant responding to the concerns raised by both of the community residents interviewed that a) this project will erode the surrounding lands and b) shoreline hardening structures near the Kamehameha Schools beach lots have had a negative impact on the rest of the shoreline? Is there evidence that the shoreline adjacent to the Kamehameha Schools beach lots have not been negatively impacted by shoreline hardening structures to justify the DEA (AFONSI) for this new revetment project?
Problematic Section: In Section 3.15 Potential Cumulative and Secondary Impacts, the DEA notes that “Erosion has occurred for decades along the Punalu‘u Shoreline. Due to the shoreline protection of properties to the south, the beach area has retreated. Placement of a sloping rock revetment at the subject properties will help to stabilize this shoreline section and will not affect shoreline processes at other sections of the Punalu‘u shoreline. Additionally, the action to stabilize these properties will reduce future erosion threats to Kamehameha Highway at this location.”
Discussion regarding Section 3.15: It is widely understood that coastal hardening deflects wave energy and causes erosion elsewhere. Shoreline hardening structures are notorious for their documented contribution to the loss of beaches throughout Hawai‘i. For example, an estimated 25% of the length of beaches on O‘ahu has been permanently lost due to seawalls and shoreline hardening, along with many miles of shoreline on Maui.
The DEA asserts that shoreline protection to the south has resulted in retreating beach. How then can the DEA rationalize that this project will “help stabilize the shoreline section” and promote sand accretion, when there is evidence that protection measures to the south have resulted in the beach area retreating?
Problematic section: In Section 5.0 Plans and Policies, the DEA discusses the project’s consistency with applicable land use policies set forth in the State Environmental Policy, Hawai‘i State Plan, State Land Use Law, State Coastal Zone Management Program, City and County of Honolulu General Plan, City and County of Honolulu Land Use Ordinance, City and County of Honolulu Ko‘olauloa Sustainable Communities Plan, and Special Management Area.
Discussion and Questions regarding Section 5.0: The DEA completely omits a critical policy that applies to the Shoreline Setback Variance Permit that needs to be granted to complete the proposed project. We remind the Department of Planning and Permitting of the Revised Ordinances of Honolulu, Chapter 23 Sec. 23-1.2 regarding the purpose of Shoreline Setbacks:
(a) It is a primary policy of the city to protect and preserve the natural shoreline, especially sandy beaches; to protect and preserve public pedestrian access laterally along the shoreline and to the sea; and to protect and preserve open space along the shoreline. It is also a secondary policy of the city to reduce hazards to property from coastal floods.
(b) To carry out these policies and to comply with the mandate stated in HRS Chapter 205A, it is the specific purpose of this chapter to establish standards and to authorize the department of land utilization to adopt rules pursuant to HRS Chapter 91, which generally prohibit within the shoreline area any construction or activity which may adversely affect beach processes, public access along the shoreline, or shoreline open space.
(c) Finally, it is the purpose of this chapter to name the director of land utilization as the council’s designee to exercise some of the powers and functions granted, and duties imposed, pursuant to HRS Chapter 205A, Part III.
The Department of Planning and Permitting has disregarded their responsibility under this law for several decades as they approve the armoring of shoreline all over O‘ahu. It is unreasonable to assume that this new revetment is going to meet the objectives of the law when the same type of construction has resulted in the exact opposite in multiple locations around the island.
Why was the Revised Ordinances of Honolulu, Chapter 23 Sec. 23-1.2 regarding Shoreline Setbacks not included in the discussion of the DEA? How does the Department of Planning and Permitting address our concerns that they are not fulfilling the primary policy of the city regarding shoreline setbacks?
Please address the above concerns in any subsequent EA. It is in the public’s interest to protect our shorelines and access to our beaches. The existing land use and zoning rules are designed to guarantee the public’s trust interests and must be observed.
Sierra Club O‘ahu Group Coordinator