Punalu‘u Shoreline Revetment Project

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.

Mahalo,

Jodi Malinoski

Sierra Club O‘ahu Group Coordinator

O‘ahu General Plan

Aloha, below are the comments the O‘ahu Group submitted in regards to the 2nd draft of the O‘ahu General Plan. The O‘ahu General Plan sets forth the long-range objectives and policies for the general welfare and, together with the regional development plans, provides a direction and framework to guide the programs and activities of the City and County of Honolulu. More information about the O‘ahu General Plan can be found at the Honolulu Department of Planning and Permitting website here.

To: HHF Planners
Attn: O‘ahu General Plan

Aloha HHF Planners,

On behalf of our 8,000 members and supporters on O‘ahu, mahalo for considering the comments of the Sierra Club O‘ahu Group regarding the O‘ahu General Plan draft. In general, it should be said that we are pleased with the proposed changes in the General Plan update as many of the Sierra Club O‘ahu Group’s concerns have been given attention. We found the addition of new areas focusing on climate change, sea level rise and renewables to be positive inclusions. Additionally, we welcome the increased focus on mass transit, transit-oriented development, and an Age-Friendly/Complete Streets development approach. Finally, stronger language surrounding the urban growth boundary, preserving the character of certain neighborhoods while still recognizing the need for density, and the inclusion of a substantial amount of language promoting agriculture are appreciated. We hope that the language proposed in these areas is preserved in the final version. However, we do have some concerns.

First, in the Economy section (Objective B, Policy 7) language has been changed from “manage” to “facilitate” with regards to secondary resort areas and the specific destinations of Ko‘olina, Turtle Bay, Hoakalei, Mākaha and La‘ie. The Sierra Club O‘ahu Group is concerned with the stronger encouragement of development in these areas which we believe to be inappropriate. We see this as promoting development outside the primary urban areas and providing a justification for intruding in currently undeveloped areas. This will necessitate further investment of scarce taxpayer resources on infrastructure in rural areas. Given that the city is investing 8 billion dollars on infrastructure in order to concentrate development on the Leeward coast, we believe this encouragement of development in the rural area to be misguided. Moreover, encouraging such increased visitor activity in the Country will place further stresses in areas that have already reached their capacity. For these reasons we strongly recommend that the draft revert to the original language to “manage” these activities.

On a related note, other sections of the General Plan draft have useful language that should be added to the Economy section when evaluating maintenance requirements and proposed construction in resort areas and Waikiki, especially in relation to sea level rise. The Housing and Communities section (Objective C, Policy 6), the Transportation And Utilities section (Objective D, policy 5) and the Public Safety and Community Resilience section (Objective A, Policy 2) contains language addressing the proper evaluation of variables surrounding climate change and development such as: “topography that could be difficult or dangerous, sewer capacity, utility capacity, extreme cost and potential environmental damage.” In these sections, these variables are framed around simply being bad growth that shouldn’t be encouraged or which could potentially incur the City large costs – this framing of perspective should be taken for our tourism economy. This is especially true when talk of establishing beach preservation funds which would use transfer of development rights (TDR) and purchase of development rights (PDR) which could be exorbitantly more costly for the City/State if not guided by language and policy which expects these same considerations from the tourism industry. The addition of this language could help prevent significant financial cost and damage to the environment.

In the Physical Development and Urban Design section, the new addition of Policy 6 on page 50 allows for short-term vacation rentals in TOD areas – the Sierra Club O‘ahu Group does not support this. The O‘ahu Group understands the many values of TOD, one of those being its power to control sprawling and uncontrolled growth by placing our residents closer to where they live, work and play; taking away more of the available area in TOD neighborhoods and giving it to non-residents does not facilitate this. This type of activity should be strictly prohibited outside of our resort areas and Waikiki, as it is counterproductive.

Language relating to deregulation exists in both the Housing Communities section (Objective A, Policy 2) as well as in The Economy section (Objective C, Policy 4). The O‘ahu Group recognizes that some regulation is indeed burdensome, especially for the farmers mentioned in Objective C, Policy 4. We strongly support an increase in local agricultural production, however we would welcome additional language to clarify that this increased activity would not fly in the face of environmental impact, pesticide, water quality, and invasive species regulations.

Finally, the Energy section (Objective A, Policy 6) promotes an impressive suite of renewable energy resources and the Sierra Club O‘ahu Group supports the emphasis on producing renewable energy for O‘ahu. However, it should be mentioned that with regards to geothermal and its listed prospects in both Wai‘anae and Windward, the national Sierra Club supports geothermal, but not hydraulic stimulation or “fracking” which the newest forms of geothermal now use. If language can be added that steers O‘ahu away from this process which can pollute groundwater and increase seismic activity, then it should be done.

Again, the Sierra Club O‘ahu Group thanks you for your time and interest in our comments. If you have additional questions please do not hesitate to contact our staff and board at your convenience.
Mahalo,

Elliot Van Wie

Executive Committee Member, Conservation Chair & Smart Growth Chair, Sierra Club O‘ahu Group

Haiku Stairs Comments

Aloha, below are the public comments the O‘ahu Group submitted in response to the Environmental Impact Statement Prep Notice (EISPN) in regards to the future of Haiku Stairs, or the “Stairway to Heaven”:

To: OEQC and G70

The Sierra Club O‘ahu Group is concerned about the Haiku Stairs being torn down. Here are our comments and questions.

COMMENTS

1) The Haiku Stairs should be preserved. It is well-known and attracts both locals and visitors. It is unique — no other hiking trail on Oahu is remotely similar. There are fantastic views all along the way and the stairs have a long history. To quote a recent editorial by Vernon Ansdell and Jay Silberman, the stairs “have been determined to be eligible for listing in the National Register of Historic Places, because of their integral role in the defense of the Pacific during WWII. Experts in botany and natural history have described the Stairs hike as unique in the Hawaiian islands, for several reasons. It would be an incalculable loss of an irreplaceable recreational, educational, historic and cultural resource.”

2) Managing the stairs has been done before with little or no difficulty. Again quoting Silberman — “Think about what was involved when the U.S. Coast Guard Omega Station did it in the 1980s: hikers parked in the parking lot next to the main building, filled out a sign-in sheet, and walked over to the Stairs. That’s it. The station and parking lot were open during the day, so no one had a reason to park on neighbors’ lawns and sneak up at night. During the six years that the Stairs were open, an estimated 20,000 people a year climbed it, with no supervision, and no impact on the neighbors.”

3) No one has been killed or seriously injured while hiking the stairs. This is an amazing record for a trail that has been drawing hikers for over three decades. People have been very careful because of the obvious danger if they fell off the stairs.

4) The City spent almost $800,000 fixing the stairs (and replacing the railings) over a decade ago. It has spent about $170,000 a year for the past several years to post guards at the gate near the end of Haiku Road. All of this money should go to making the stairs available to the public! And if the stairs are torn down, it will cost the city almost 3 million dollars. This money could be used to create a hiking trail that would draw tens of thousands of people a year without annoying the residents who live near the trailhead.

5) If the City won’t maintain the stairs, perhaps another government agency will. DLNR comes to mind. They have a lot of experience in managing trails (think Na Ala Hele). The stairs lead up to the Koolau Summit Trail (KST) and could be part of an all-day hiking experience unlike any other in the state. Up the stairs, along the KST, down Middle Ridge and out along the Kamananui Valley road would be an unparalleled recreational experience.

Another possibility: again quoting Ansdell and Silberman, “If BWS can’t be troubled to manage the Stairs, hire a contractor to do it, and collect entrance fees to cover all operating, maintenance, security and management costs, as well as all potential liability. The state collects hundreds of thousands of dollars per year from entrance fees to Diamond Head State Monument.”

6) The concerns the City has expressed about liability are overblown (again, no deaths or serious injuries in over 3 decades of hiking by everyone from first time hikers to experienced mountaineers). Liability should not be the primary consideration in deciding whether to preserve the stairs or not. The State’s experience with Diamond Head State Park and Manoa Falls Trail (the two most hiked trails on Oahu) should put to rest any concerns that the City has.

7) Oahu’s trails are being inundated by an unprecedented number of hikers. We had almost 9,000,000 visitors to the state in 2016. The situations at Maunawili Falls Trail and Kuliouou Ridge Trail and Mariner’s Ridge indicate that we need more, not fewer, popular trails. Haiku Stairs could be an attraction that helps alleviate the foot traffic on our most popular trails, thus taking some of the pressure off a resource that was not made to handle so many people.

QUESTIONS

1) Have other governmental agencies (besides the Board of Water Supply) been asked about their interest in “taking over” the stairs?

2) Have non-profits been asked about their interest in managing the stairs (for example, the Friends of Haiku Stairs)?

3) Has anyone from the City hiked similar trails in other states or foreign countries? Have they seen how those states and countries managed that recreational resource?

4) Has the City made an offer to Department of Hawaiian Home Lands to swap land that can be used for housing for the land that DHHL owns in Haiku Valley (courtesy of the US government when Coast Guard Omega Station closed down) and which is unsuitable for housing?

5) Has the City considered selling the stairs to a third party (such as Trust for Public Land) which would transfer the stairs to another government entity or non-profit or public-private partnership (PPP)?

6) Has the City considered reviving the Coast Guard method from the 80’s — i.e. renovating the parking lot and main building of the former Coast Guard facility to allow hikers to park there so that neighbors would not be inconvenienced?

7) Has the City considered using the Diamond Head State Park model — charging for parking ($5 per vehicle) or walking in ($1)? These monies could be used exclusively to maintain the stairs and provide a great visitor experience.

8) There is a serious shortage of funding to protect and maintain our natural resources. With almost 9,000,000 visitors last year, DLNR needs more resources just to maintain, much less improve, the visitor experience. This doesn’t even count the number of locals who also use the resource base. Has the City considered turning the stairs over to the State to use as a revenue source (similar to Diamond Head)?

9) Has the City considered convening a meeting of interested parties in resolving this situation? Representatives from the Board of Water Supply, DHHL, DLNR, the Friends of Haiku Stairs, Sierra Club, Hawaiian Trail and Mountain Club, Trust for Public Land, City attorneys, State attorneys should sit down and talk to each other about possible solutions. This would cost very little and some innovative ideas might come out of this get-together. It is worth a try. The Haiku Stairs is a unique resource and definitely worth saving.
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The Sierra Club looks forward to your response. And mahalo for this opportunity to share our mana’o with you.

Randy Ching
Sierra Club O‘ahu Group

Bill 59- O‘ahu’s Plastic Ban Ban 2.0

Tomorrow, Honolulu’s City Council will have its final hearing for Bill 59 (2016) CD2, FD1 – an ordinance that will “close the loophole” on O‘ahu’s plastic bag ban. We have been sharing action alerts on social media to encourage our members to submit testimony in support of the FD1 (1st floor draft) which is the preferred language for Bill 59. Below is the testimony the O‘ahu Group submitted in support of Bill 59 (2016), CD2, FD1:

May 9, 2017-

Aloha Chair Menor, Vice Chair Anderson, and members of the Honolulu City Council,

On behalf of the Sierra Club O`ahu Group’s 8,000 members and supporters and as a participating organization in the Rise Above Plastics Coalition, we are in STRONG SUPPORT of Bill 59 (2016) CD2, FD1, which will implement a 10 cent fee on all check out bags at grocery stores and phase out the thicker “reusable” plastic bags in 2020. This FD1 balances both business and environmental concerns: the stores have adequate time to use their stock of thick plastic bags and will receive money from customers to invest in paper or cloth bags, while our community moves towards eliminating plastic pollution and promoting sustainable consumer behavior. When the Council passed the first plastic bag ban there were unintended consequence of allowing thick plastic bags to be considered “reusable.” Bill 59 (2016) CD2, FD1, will effectively eliminate these types of plastic bags on O`ahu to help reduce cleanup costs, save vital resources, and protect our marine environment from plastic pollution.

We respectfully cannot support the CD2 as it is currently written. It creates more confusion and ambiguity about what types of bags are allowed in the future, particularly by allowing “non-recyclable bags” for prepared foods, beverages, and bakery items. It also does not phase out the thicker plastic bags or compostable bags, which was the intention of Bill 59 (2016). We would prefer to not have to revisit the plastic bag issue another time. Passage of the FD1 would successfully accomplish the intention of the initial plastic bag ban: to eliminate plastic bags on our island.

The Sierra Club O`ahu Group advocates for a reduction of all plastic bags – regardless of their thickness. If we cannot eliminate thick plastic bags in Bill 59 (2016) and truly move towards sustainability and waste reduction, we ask that the Council defer this measure until better a consensus between the Council, environmental groups, and industry representatives can be reached. Grocery stores can already impose a 10 cent fee for checkout bags without passing this bill. We cannot support a bill that will impose a mandatory fee on customers if it is not coupled with language to phase out the thick plastic bags; the point of having a fee on bags is to encourage a reusable mindset, not to help grocery stores purchase more plastic bags.

Mahalo,

Sierra Club O`ahu Group

 

Honolulu’s New Office of Climate Change

Every ten years the Honolulu Charter Commission proposes changes on the City’s Charter, or Honolulu’s constitution. Twenty proposed changes made it to the November 2016 ballot such as Question 6: a City Charter Amendment that would create an “Office of Climate Change, Sustainability, and Resiliency”. The O‘ahu Group was ecstatic when majority of residents voted yes on this Charter Amendment because we are already seeing the impacts of climate change, yet policies to combat these effects have not been a focus at the city level. Passage of this amendment shows community support to prioritize sustainability and resiliency in a transparent matter.

Here are some of the things the O‘ahu Group suggests the city considers when creating this office:

  • Holistic: this office should create and implement a comprehensive climate change plan and resiliency strategy tailored for Honolulu; incorporating all major climate change impacts, potential catastrophic events, and other social, economic, and environmental stressors into this strategy.
  • Action Planned: this office should prioritize sustainability projects consistent with the resiliency strategy to help adapt to sea level rise and plan development accordingly, end our dependence on fossil fuels, protect our natural resources and open space, and increase our food self-sufficiency.
  • Inclusive: this office should effectively convene city departments, policy makers, scientists, and community members. The staff should work on a variety of tasks: from implementing the resiliency strategy through policy and projects, to educating the public about climate change and promoting a vision of a resilient future, and engaging stakeholders to support a plan of action, including future revenues for major infrastructure work.

We believe that the formation of this office will help facilitate discussion about the impacts of climate change, promote environmental stewardship, and initiate sustainability projects on O‘ahu. Seven positions are proposed for this office in the Mayor’s 2018 budget with funding for 5 requested, including: a Chief Resiliency Officer/Executive Director, a Deputy Director, Secretary, Coastal Project Manager, and Energy Coordinator. The Chief Resiliency Officer position will be funded by a two year grant from the Rockefeller Foundation, but the other positions will need to be approved by the City Council during budget hearings from April to June. Eventually, we hope the office will be expanded to include a few more key positions, such as a grants manager, a communications coordinator, a food policy coordinator, and a water conservation coordinator. We’ll be lobbying Councilmembers to support this office, so stay tuned on how you can get involved. This is an exciting time for Honolulu, mahalo for your support!