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Strong Letter from Hāmākua Resident Opposed to Hū Honua Project

I am a resident of Hawaii Island, Hamakua District, and am extremely concerned about the need for alternative energy on our island, but I am even more resolute that our designated government agencies fulfill their legislated obligations to maintain the vitality of the environment, water, air and land, and community resources and quality of life. As the Hu Honua Bioenergy Plant has progressed toward operations, serious questions have arisen—and have had to be uncovered by citizens because the company itself has been less than forthcoming-- about the integrity of this process, and the appropriateness of this type of operation on our island.

I am writing to urge the State Department of Health (DOH) to determine that Hu Honua’s underground injection control wells will be a point source for which a NPDES permit is available.

Under Hawai’i Revised Statues Chapter 91 (HRS 91), I also urge that you call for a hearing before the Dept. of Health makes any decision, with a requirement for an environmental assessment for the outfalls onto conservation lands DLNR told Hu Honua they need an easement and permits from the state and must follow HRS Chapter 343 for environmental impact statements. Isn’t this a drainage system that requires an environmental assessment under state law before a NPDES permit is issued?

We can see and read in the news everyday what can happen when communities do not closely monitor business activities that impact the public environment with potential for irreversible consequences and damage, affecting marine, land, and human life. Especially when new technologies are being promoted as alternatives to fossil fuels, and lauded as “green” or “renewable,” I think we have a civic and moral obligation to examine such claims that are, at best advertising, at worst, deception. Court cases at all levels show that many types of companies regularly have engaged in practices to withhold information from the public about detrimental consequences of their products or industrial processes. We cannot jeopardize the future of our fragile island environment by rushing through an approval without carefully examining intended activities beforehand, and monitoring actual practices during construction, and regularly during routine as well as emergency operations.

The things that concern me include:

· the impact of heated and chemical-contaminated waters released and injected underground, reaching the aquifer, and coastal waters, with damage to fishing grounds for the local population, as well as other marine life that contributes to the health of the ocean ecosystem and species of plants and animals that frequent the area for food and habitat. We have heard there was a large landslide after Hurricane Lane which raises concerns about the geological stability and capacity of the area to handle any additional moisture added to our increasing rain levels. We do not want to end up with another Puna Geothermal Plant catastrophe, putting the wrong large-capacity production plant in an unstable area known to have regular earthquakes, landslides, etc. In other parts of the US and the world, there have been examples of geological instability caused by injection of fluids underground, whether the results have been sinkholes, earthquakes, or riparian erosion. Some of the chemicals this plant plans to use—and I have read the MSDS for many of them—may be critical to avoid things like pipe erosion that led to horrors like the Flint Michigan drinking water toxicity, but many have warnings that they should never be introduced into marine life areas, or into aquifers—without allowable limits for certain quantities, but warnings to never use these in that way. Have these all been approved for use with heated waters? Have they been tested when mixed as they will be in the sump pumps or reservoirs to see what compounds are produced and what toxicity occurs? Can our local enforcement agencies require the company to do such regular testing and reporting results to them? We can’t take the risk of finding out 3 years from now that local farming has been wiped out due to things leaching underground from this plant or that residents were poisoned from eating food grown in the area.

· the impact of adding this large industrial process into the surrounding neighborhood, and county roads, with the required use of large lumber trucks and other large commercial vehicles around the clock. I am not an expert in zoning, but it seems just because something was once industrial, that should not continue if the surrounding area has changed over time since the original zoning was classified. I understand this area is also a coastal are frequented by hikers, local fishers and divers, photographers, families and to destroy this local resource would be putting business above the community, which I cannot support ever.

· the effects of new large-scale lumber operations in an area that is always inundated by heavy rains, run off, and landslides, as evidenced by the recent hurricane damage. If large plots of land are suddenly bare, or have less tree canopies, won’t that just increase damage we’ve seen in the surrounding areas? We have also just witnessed in Maui and Oahu the devastation that wildfires can cause, and if this plant’s lumber appetite clear cuts local areas which then sprout new undergrowth, that’s a new wildfire hazard that’s created in those areas, especially if we encounter future droughts, which are expected with increasingly regularity with climate change. In addition, those heavy trucks on Hwy. 11 will cause more wear and tear on roads that already lack adequate striping, railings, barriers, signage, and reflectors, on a basically 2-lane road with no safety ramps for failed brakes on huge heavy trucks with loads that could be dumped on slick, curved, and narrow roads through gulches, and few slow and well-marked lanes to allow safe passing faster vehicles.

I am not willing to let a lack of state or county diligence and oversight become a community pollution catastrophe here on our island. We must examine in advance the potential for known and unintended consequences, and ensure modifications are made, requirements are met, monitoring is diligently performed, or else the whole idea needs to be scrapped. I plan to stay informed, closely watch this operation, and related state and county monitoring and requirements. Along with many neighbors and concerned citizens of Hawaii and beyond, I will be watching and insisting that you do what’s right to respect and preserve the aina, and our future.


Francine Roby

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