Note: Karen Chun is an Engineer formerly with Western Area Power Administration in their Power and Water Resources Planning Division. She coaches outrigger paddling at Na Kai 'Ewalu Canoe Club at Kahului Harbor. She can be reached at Karen@MauiPaddle.com
Mr. Brian Ishii
Edward K. Noda and Associates, Inc.
615 Piikoi Street, Suite 300
Honolulu, Hawaii 96814
Dear Mr. Ishii,
On November 1, the canoe clubs on Maui first became aware that you had issued a DEA for the Kahului Harbor Improvements. I have been trying to obtain a copy. Apparently the only copy sent to Maui is the bound copy at the Kahului Library Reference Desk. At great time and expense I was able to copy some of the voluminous report but I am not able to review the entire document. On September 1, I visited the Kahului Harbor Office and, strangely enough, they had not received the report either. None of the canoe club representatives mentioned in the DEA were sent a report. I called the Oahu Harbors Division and requested a copy but they had only one and did not send it. I called you on 9/2 and requested a report be sent.
Obviously, the few days of time coupled with the inaccessibility of having only one report on Maui, which can’t easily be copied, is adversely affecting the feedback you will get. In light of your failure to send copies to the affected organizations and even your own Harbor Office on Maui, and your lack in adequately notifying the community of its availability, it is clear that the comment deadline must be changed to be at least a month after the report is in our hands (The library is not accessible enough since we making copies is prohibitively expensive and time consuming there.)
I suggest that you extend the deadline to November 30, 2004. I demand that you at least extend it to 30 days after we became aware of its existence or October 1, 2004.
In reading the Draft Environmental Assessment (DEA) for the Kahului Commercial Harbor Improvements dated August 5, 2004, I find there are significant omissions and glaring inaccuracies and what can only be deliberate misrepresentation of the facts.
“…the Pier 5 improvements, breakwater and channel improvements are on indefinite hold. The proposed Pier 5 improvements will not be constructed within the planning period due to the DOT-HAR budgetary goals and the results of the U.S. Army Corps of Engineers’ Wave Climate and Wave Response, 2025 Plan, Kahului Harbor 2002. The results of this study indicate that the use of Pier 5 by large vessels will create operational problems, and the Pier 5 improvements will encounter significant wave surge conditions. When and if these … projects become ripe for decision-making, an environmental analysis will be completed to determine….”
In other words, Pier 5 is physically infeasible yet you are retaining it in the DEA. The entire Pier 5 construction, dredging and breakwater needs to be removed from this DEA. This is a sneaky way of getting it past this part of the process without doing a full-scale EIS and without acknowledging that it is unworkable and should not even be considered further.
Recommendation: It is clear that the Pier 5 improvements must be completely scrapped as physically unworkable and eliminated entirely from the DEA.
Alternate Recommendation: If Pier 5 improvements are retained in this DEA, their impacts and mitigations must be thoroughly analyzed and discussed. Either it is in or it is out. It can’t be in as a proposal and not analyzed.
To leave Pier 5 in, is to keep an impossible project alive and to move it ahead by trickery. Once it passes this step, the effect is to accept a DEA on it and it will have escaped analysis.
“In the preparation of the EA, the comments from the pre-assessment consultation, the minutes of the public meetings during the 2025 Master Plan process, and comments on previous Environmental Assessments were reviewed. In addition, information was gathered from field visits, meetings…interviews with various community members and organizations.”
The feedback from your community meetings was universally negative. The impacts that were brought up were ignored or were deliberately modified to seem less severe than they actually are. Deliberate misrepresentation of the effects on surfers, canoe paddlers, fishers and the residents of Maui is prevalent throughout this document. The rest of this discussion delineates the outright lies in this document. The implication that the paddler representatives mentioned as consulted said that these deceptively mild impacts were true is reprehensible. The DEA is supposed to be a objective document. Thus negative impacts should not be minimized, omitted or falsified as they are in this in the DEA. The bias shown by the preparer is obvious.
Recommendation: Go back to community and write their comments accurately.
“The Pier 1C Mooring Dolphin is an improvement project which is covered under a separate Environmental Assessment, dated March 2004”
It is my contention, that you have separated the projects in order to circumvent the need for a full Environmental Impact Assessment on the entire project.
Recommendation: Pier IC Mooring Dolphin, even though approved and under construction, needs to be included with the rest of the projects and all of it needs a full-scale EIS.
“use of …a practical”: means that it won’t be used.
Recommendation: Strike “as practical”.
“Continue tenant-user meetings and communiqués of activities in the Harbor”
Our local Harbor office is very good about communicating the Federal Security regulations and the boat traffic to us. However, Oahu did not even send our local harbor office a copy of this DEA! Continue WHAT communication? We asked for a copy of the DEA and no one will send it to us. Our own harbors office doesn’t even know about it or have a copy. We are referred to the library where we must hand copy a bound version of the DEA at an exorbitant cost in time and money, effectively preventing the majority of people from access in order to comment. Library hours conflict with work hours thus preventing most interested parties from access to your DEA.
Recommendation: The deadline on comments on this DEA must be continued until such time as the DOT can provide adequate copies of it to interested parties. This means at least until November 30, 2004.
“The construction of Pier 2C will reduce the number of lanes for the canoe paddlers; however is not considered a significant impact.”
This is an out and out lie. The construction of Pier 2C will completely eliminate the ability of the canoe paddlers to hold any races and will severely impact their ability to practice in the harbor.
In order to hold a regatta. high school race or Na Opio race we need a rectangular area that is 1452x760 feet (1/4 mile plus 3 canoe lengths of 44 feet) by (9 lanes times 80 feet + 40 on end).
The idea that we can use half the lanes and do twice the number of races is ludicrous and was never a proposed solution. In fact, if we had half the lanes, we’d have to run three times as many races (2 races for half the paddlers and then a race-off of the winners) Considering that regattas already run from 7:30pm to 5:00pm, that would require 28.5 hours of daylight which exceeds the amount available on a weekend. The fact that this ridiculous idea was included as a mitigation shows that there was inadequate information-gathering or that the preparer simply ignored or misrepresented community input.
Recommendation: Go back to the community and get correct facts this time.
Section 3.4:
“…as practical, the design will incorporate low-energy fixture and water saving devices”
Recommendation: Strike “as practical”.
Section 3.5 Pier 2C Preferred Alternative
Recommendation: Include description of where the 10,000 square foot passenger terminal will be built.
Recommendation: Include alternative with smaller passenger terminal.
Recommendation: Include the estimated number of vehicles using Pu’unene due to the ferry.
Recommendation: Include wave study of effect of 800 foot pier (500’ + 300’) and riprap on currents and whether this will erode the beach.
Recommendation: Include water study on the effect of the stagnant water that will form between Pier 2c and the beach.
Recommendation: Include a diagram showing the area taken up by the ships and their security zones.
Recommendation: Strike “as practical”.
Section 3.5 Pier 2C 2010 Alternative
This alternative is not labeled as the preferred one although talks with Kahului staff indicate that it is, in fact, the preferred choice. Less preferred choices are usually included because they have smaller adverse impacts. This alternative has bigger impacts, so why was it included unless it is actually the preferred alternative?
Recommendation: Include effects of 30 ft dredging on beach erosion
Recommendation: Include drawing showing the fill, dock, road boats and their security zones in relation to the Hideaway restaurant, the two canoe hale and the hotels. Include scale.
Include drawing showing maximum ship size and their associated security zones.
Recommendation: Add section with Pier Notching Alternative.
Talks with Kahului Harbor Staff indicate that the most realistic alternative and one they are seriously considering is to notch the existing pier to accommodate the Ferry. The glaring omission of this alternative which is the one that is most likely to occur, makes the information in this DEA highly suspect.
Section 3.6 (No build alternative)
Editorializing does not belong in this section. This is another example of the bias of the DEA preparer. No positive impacts such as continued Hawaiian cultural use, less danger of erosion damaging near buildings, bigger docking fees that can be collected, etc. are mentioned
Recommendation: Remove biased pro-project editorializing or include positive effects of not doing the project also.
Section 4.6.3
Pier 2C Alternatives
What is the basis of the statement that Pier 2C will not have significant impact on the environment? Was a study done of the effect of changing the currents on creating stagnant water where the tributary enters? On the effect of beach erosion?
Recommendation. Include beach erosion study of effect of pier structure, dredging and fill.
Recommendation: Include stagnant water study
Recommendation: Include traffic study of the impact of the number of cars on traffic for Ka’ahumanu Hwy and Pu’unene. This is a major commute intersection and is already choked with cars so that the intersection is blocked when the traffic backs up and people don’t wait outside the intersection.
Page 31:
“The current cultural activities…. Current users include two paddling organizations.”
This paragraph is a glaring example of how the community feedback was ignored or was just plain recorded incorrectly. Note that the canoes are stored on the beach in front of the hale and any erosion of the beach or increase in wave impact will adversely affect both the buildings and the canoes.
Canoe practice at both clubs takes place year round. Additionally, Lae Ula O Kai, the other north shore club, uses the harbor when conditions become too rough outside the harbor.
It should be clearly stated that Kahului Harbor is the only safe place on the north shore to practice during the high surf months and that without access to the harbor, all the north shore clubs will be severely impacted on their winter and spring training.
The statement that paddling season usually extends from March to September/October is false. The first 6-man race is in March and the last 6-man race is in November. Offseason high school and youth paddling takes place from December through February with races in the harbor. Both practice and racing extends year round and the 1-man races occur when the 6-man races are not running. The timing of races will most likely expand in coming years.
There is no mention that Pier 5 will totally eliminate one of Maui’s best surfing spots. There is no mention that Pier 5 and Pier 2c and their associated security zones will most likely squeeze canoe racing into such a small area as to be impractical. New security zones have already impacted the canoe clubs so congestion creates problems. To reduce the area more will have a cumulative impact.
Recommendation: Change “Current users include two paddling organizations” to "Current users include two resident paddling clubs comprising of in excess of 500 people".Recommendation: Replace “The paddling season usually extends from March to September/October” with “All 8 canoe clubs of the Maui County Hawaiian Canoe Association and the Maui Canoe and Kayak organization, comprising several thousand Maui residents use the harbor year round with regattas during the summer and high school races during the winter.”
Recommendation: Change “in back of Hoaloa Beach” to “on Hoaloa Beach”
Recommendation: Change “8 lanes” to “9 lanes including a rectangular area 1452’ x 760’. The ends of this area are marked with flags which have physical requirements which necessitate that the majority be placed in water shallower than 10 feet”
Recommendation: Add: “Kahului Harbor is the only safe place for paddlers to practice during the high surf months. Without access to the harbor and beach, all the north shore clubs will be severely impacted on their winter and spring training.”
Recommendation: Discuss the security zones. Include a drawing of the harbor with the proposed improvements with security zones drawn on it showing the canoe hale, Hideaway restaurant and hotels, drawn to scale with scale shown.
Page 33: Pier 2C Development
“The Pier 2C Preferred Alternative will have an impact on two or three canoe lanes.”
This statement is an out and out lie. Pier 2C will eliminate 3 or 4 outside lanes and the ability to hold any short races (high school or regatta) in the harbor.
“The reduction of racing lanes may require that the regattas be moved to Saturday and Sunday”
This is an infeasible mitigation made up out of thin air using a sarcastic comment that was meant to show the DEA consultant than eliminating even two or three lanes would make racing impossible. It again shows that the consultant was simply listening to community feedback with a selective filter and has rejected or distorted that feedback in order to create a misleading and false DEA.
“However, this impact is considered to be an insignificant impact to the canoe facility”
Another out and out bare-faced lie. This will be a major, huge impact on the canoe clubs and all several thousand MCHCA paddlers. It will not only eliminate 3 of the 7 regattas, 2 of the high school races and several of the Na Opio races which are held in the harbor but it will severely impact the ability of paddlers to practice in the harbor.
“The 2010 Alternative would eliminate the canoe facility at its present location and would force the canoe clubs to find another location for the races.”
Where are the mitigations? Where will the canoe clubs go? Lae Ula O Kai is the only north shore club based outside the harbor and even they need to use the harbor when the surf is big. What other sheltered water exists on the north side? What about the impact on MIL highschool paddling? On Na Opio youth paddling? What about the impact on the north shore kids who don’t have transportation to practice elsewhere. There is no discussion of the role the clubs play in the cultural life of our youth especially our at risk youth. Hui Malama holds regular classes at the Hawiian Canoe Club Hale.
There is no discussion of the “other location” for the races. We tried to hold the races at Kanaha park and had to rescue one of the crews who couldn’t get back to shore. There is no other north shore venue suitable for canoe racing.
According to a staffer at the Kahului Harbor office the 2010 Pier 2c plan is actually the preferred plan, yet there is no discussion of the huge cultural impact of eliminating one of the 8 canoe clubs on Maui, the elimination of its Kamehameha Schools high school paddling, the elimination of high school races, regattas and Na Opio races in the harbor.
Recommendation: Include a detailed plan of where the canoe clubs will relocate to, how much it will cost, how this will be accomplished and who will pay for it. Include comments on relative safety of our child paddlers in any nonharbor north shore location.
Page 33 4.9.3 Mitigation Measures
Where is the discussion of relocating the canoe clubs? Although the 2010 Alternative is not listed as the preferred alternative, in my talks with a local DOT employee, that appears to actually be the preferred alternative.
This DEA is incomplete without a detailed plan for relocating the Canoe Clubs, include costs and actual locations approved by the clubs. This will necessitate more community meetings with MCHCA and the individual clubs.
“Although no or insignificant impacts are expected with the preferred improvements…”
Again, this is a lie and the preparer knew it was a lie when it was written. Also the “preferred improvement” of Pier 2c is perhaps the 2010 alternative. Why was this not coordinated with the Kahului office? Why was the 2010 alternative included if it was not the preferred alternative since it has far more negative impacts?
I request a copy of the letter from SHPD dated Octover 23, 2004 and more time in order to respond in an informed fashion.
Page 35.
The discussion of cruise ship waste and bilge water is inadequate. They may claim that they signed the MOU for discharge of water but what are the fines? These fines need to be substantial (e.g. in excess of 1 million dollars) and there needs to be a fund created to monitor the water so that we can enforce this. I can tell you from personal experience that the cruise ships are not complying with the MOU.
“Except for Pier 2C 2010 alternative, the proposed improvements will have an insignificant impact on marine biota”
What about the stagnant pool formed behind Pier 2c and its impact on health and odor for the adjacent businesses including a restaurant and hotels? This needs to be discussed and mitigation measures designed.
Page 43 section 4.21.2 Alternative Analysis
“The Pier 2C Preferred Alternative will have an impact on two or three canoe lanes”
This entire paragraph is false. It will eliminate regatta racing from the harbor and severely impact the clubs using the harbor for practice, acerbating the congestion caused by the new security regulations.
“The Pier 2C 2010 Alternative would eliminate the canoe facility at its present condition [sic]….”
And where does the State suggest that Na Kai ‘Ewalu go? Or is the state simply going to destroy an entire canoe club and its associated cultural and educational activities and its several hundred thousand dollar hale?
Na Kai ‘Ewalu hosts Kamehameha Schools high school paddling. Where will Kamehameha Schools paddlers go? Where will our at-risk youth paddlers in the Na Opio program go? Who is going to pay to relocate Na Kai ‘Ewalu? And the big question: Where on the north shore of Maui is there a protected water which is safe for our youth to paddle in during the school year when MIL and Na Opio paddling occur?
Page 1c Section 5.0
“(1) Involves in irrevocable commitment to loss or destruction of any natural or cultural resource…”
“While the construction of Pier 2C, preferred alternative, will remove several canoe racing lanes, this is not a significant loss to the use of the area.”
This is inaccurate and an out and out lie. It will mean that we cannot hold any of our regattas, high school races or Na Opio youth races in the harbor and will severely impact the use of the harbor for practice. There is no discussion of the security zone and how far it extends. Since this information was not included on a drawing showing the harbor, canoe hale etc. we can not evaluate whether this might completely eliminate even practice paddling in the harbor.
The 2010 Pier 2c alternative will irrevocably destroy a long-time canoe club and its cultural practices and educational programs including the hosting of the Kamehameha Schools paddling program. Why wasn’t this information and its mitigation included?
“(2) Curtails the range of beneficial uses of the environment.”
“This action will not curtail the range…”
Another out and out lie. It will eliminate or reduce paddling.
Pier 5 (which, if it is included in this document must be mentioned and discussed) will eliminate surfing at one of Maui’s best surf spots. It may also eliminate access to the boat ramp.
(3)Conflicts with the state’s long-term environmental policies…”
“…enhancement of the quality of life…it will provide a port that will be able to meet the existing and forecast demand….”
No mention made that this is mostly for the cruise ships and ferry and that it will possibly destroy a canoe club, eliminate a 30 year history of regattas in the harbor, curtail a 1000 year cultural use of the harbor, impact the cultural activities of Kamehameha Schools and cultural and educational practices associated with paddling.
This is so deceptive and false, it makes glaringly obvious the consultant’s pro-project bias.
“(4)… The proposed action will provide a positive effect on the economic and social welfare of the community…”
However it will negatively impact the residents who paddle and surf and observe Hawaiian cultural practices.
The writer goes on to say “In addition, with the growth in the cruise ship industry, the proposed actions will provide facilities for these activities to continue…”
Hey wait, didn’t the writer previously say that this project would not increase the number of ships? This inconsistency again points out the writer’s pro-project bias and distortions.
“(6)….effects on public facilities”
Traffic? No study. No mention. Writer completely ignores the effect of the ferry and cruise ship traffic on Ka’ahumanu and Pu’unene’s already over-congested rush hour traffic. This DEA is glaringly incomplete and once again, deceptive. No mention on the impact of eliminating the boat ramp on other boat ramps if Pier 5 is built.
“(7) degredation of environmental quality”
No mention of the oil from all the traffic going to the ferry on the Pu’unene extension washing into the semi-closed system of Kahului Harbor. No mention of the exhaust from the idling cars waiting for the ferry. No mention of the paving over of Hoaloha park. The finding of no significant degredation is unsubstantiated. The writer simply ignored discussion of anything that could impact.
“(8) …The proposed action does not involve a commitment to larger actions, nor would the cumulative impacts result inn….”
The writer has ignored the current Pier 1 dolphin extension, the new imposition of security zones and the Pier 5 proposal. This development is already part of a chain of cumulative impacts that are reducing citizen recreational paddling and subsistence fishing in the harbor.
“(10)…water quality….would not be detrimentally affected…long term”
No discussion of stagnant water and concreted waterway behind the Pier 2c extension. This conclusion is reached by ignoring discussion of potentially negative impacts.
“(11)….beach, erosion-prone area…coastal waters..”
DEA does not discuss stagnant water of beach erosion problems. To ignore studying their effects is not the same as saying they have no effect. This statement is unsubstantiated by facts.
Comments on “Archaeological and Cultural Impact Assessment of Cultural Resources at Kahului Harbor” Dated April 2004
Since this is based on (or lead to) the misleading statements outlined above, the entire study needs to be re-worked with a consultant whose bias will prevent them from casually dismissing the destruction of an entire canoe club, the ending of MCHCA, high school and Na Opio regattas in the harbor, the curtailment of Kamehameha Schools High School Paddling, the destruction of Hawaiian cultural artifacts including an Ahu in front of the Na Kai ‘Ewalu hale, the curtailment of paddling in the harbor, the elimination of one of Maui’s best surf spots as having “no significant adverse impact to cultural resources”
This study is too flawed to be accepted. I recommend that another, less biased, Maui-based firm be engaged to do an objective and accurate Cultural Impact Assessment. The inaccuracies and just plain lies in this study render it completely unprofessional and unacceptable.
Two paragraphs of the Executive Summary are untrue:
“The cultural impact assessment…”
This paragraph is false for all the same reasons listed for the DEA above. It simply repeats (or originated) the false and misleading “information”.
“It is recommended that…” is an incorrect conclusion. Had the writer not based his conclusion on the false statements outlined above, a finding of significant, irrevocable, damage to cultural activities would have been inescapable.
One of the most egregious deceptions contained in this report was to list Gabby Goveia and Mary Akiona as having been contacted for this study when, not only was their information on adverse effects omitted, but wholesale fabrications on the part of the writer were used in their place.
Given the short amount of time, my assessment stops at the Executive Summary of the Cultural Assessment. I request that you extend the deadline for comments based on your lack of proper notification and dissemination of the DEA.
I request that the Cultural Assessment be redone so that it is accurate.
I request that a complete discussion of the effects and mitigations for the Pier 5 work be included or that mention of Pier 5 be removed from this DEA.
I request that a full scale EIS be done on these projects as they have been artificially separated so as to go “under the radar”.
I request that Oahu and Kahului discuss which Pier 2 alternative is actually the preferred.
I request that you include mitigation for the destruction of Na Kai ‘Ewalu Canoe Club’s paddling area.
I request that you include what I am told is the actual plan for the ferry, namely notching the existing harbor.
This document is inaccurate and should be scrapped and redone with truthful, accurate information.
Sincerely
Karen Chun
87 Lae St.
Paia HI 96779