Auwahi EIS Comments: Mayer

1 April 6, 2011

From: Professor (Emeritus) Dick Mayer,

To: Applicant: Auwahi Wind Energy LLC, 101 Ash St, HQ 14,
San Diego, CA 92101 Attn: Joan Heredia (619) 696-1824
jheredia@sempraglobal.com

Accepting Authority: County of Maui, Planning Commission / Department,
250 South High Street, Wailuku, HI 96793 planning@mauicounty.gov
Attn: Joe Prutch, 270-7512 joseph.prutch@mauicointy.gov
Consultant: Tetra Tech EC, 737 Bishop Street, Suite 3020,
Honolulu, HI 96813. George Redpath, 533-3366
george.redpath@tetratech.com anna.mallon@tetratech.com

Maui Consultant: Munekiyo, & Hiraga, Inc. Wailuku, Hi 96793
Attn: Leilani Pulmano leilani@mhplanning.com

RE: Comments on Auwahi Wind Farm (DRAFT- EIS) These comments are intended to apply to any HRS 343 Environmental review, NEPA requirements, Conservation District Use permitting, Special Management Area Use, Maui County Special Use, Request for Use of State Lands, Incidental Take Permit, Incidental Take License, Use and Occupancy Agreement, County Right-of-Way Approval, Various Grading/Building and Other Construction Permits.

 

APPLICATION: Auwahi Wind Energy LLC is proposing to construct a wind farm with a generating capacity of approximately 22 megawatts (MW), augmented with an energy storage system. In addition to wind turbines, the proposed project would include a substation, operations and maintenance facility and related infrastructure, a 34.5 kilovolt (kV) transmission line and a construction access route along existing public roadways and pastoral roads. The electrical power generated on the wind farm site would be transmitted to MECO’s existing electrical grid via a new 34.5-kilovolt (kV) transmission line.

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Aloha, Thank you for allowing me to comment on the DRAFT-EIS.

 

I first wish to state that I’m strongly in favor of developing new wind energy resources on Maui so that we will not have to continue burning fossil fuels. Nevertheless, I feel it is necessary to make sure that any new alternative energy project: a) be sensitive to Maui’s special physical and cultural environment; and b) provide benefits to electricity consumers. Therefore, the following is a list of items which should be considered in revising the DEIS and preparing the Final-EIS.

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NOTE: All references to page numbers refer to Volume #1 of the Draft EIS.

 

1. WATER This project will consume very large amounts of water during its

construction phase. (Page 3-200 indicates 1,600 truck loads of water.) However, the Draft-EIS (DEIS) is vague as to where the water will come from. The Final-EIS (FEIS) should indicate exactly what is the water source is. South Maui? Central

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Maui? Page 3-200 is totally irresponsible for an EIS in claiming that it is up to the contractor. Given the serious water shortage in Upcountry Maui, the FEIS must describe its water source completely.

 

Since the primary use of water will be in the manufacturing of the concrete, how much water will be utilized to mix the concrete? Exactly how many gallons) will be utilized to manufacture the concrete? How many gallons from each source? What is its source? From which aquifer? During the construction cycle, all of the tower platforms will be constructed during a very short tome period. What effect will such a simultaneous large use of water have on the Maui County water system? Be specific.

 

Will any water from the County’s already inadequate Upcountry water system be utilized? If not, then promise/certify that in the FEIS.

 

Page 3-34 indicates the use of a 50,000 gallon tank. The FEIS should point out that the water source for this tank is the upper Kula waterline, a line which already has an inadequate flow of water. Please indicate an alternative source of water for this tank which will be used to both suppress fires and to reduce dust on the construction site.

Page 3-34 states that a possible water source would be the Makena resort. This large luxury development project has not yet identified for itself an adequate source of water; and it certainly cannot be counted upon to provide water for this project.

 

Clarify in the FEIS whether there will be an on-site water well, and what will happen to the well and its water after the completion of construction? Will the water be made available for residential and/or agricultural use by neighboring residents?

 

2. TRAFFIC THROUGH KAHULUI TOWN Pages 3 — 112 to 3-117: There is a need for a map of the route through Kahului town from the harbor to Mokulele Highway. The map should clearly locate all impediments to the transit of the super-loads. Furthermore, there should be an indication as to whether any traffic would be able to operate on the impacted roads during these transit events. For example, are loads going to be too wide for only one lane, two lanes in a single direction, or all four lanes of traffic? For example on Dairy Road? At what speed do the vehicles move? How long will it take for the numerous super-loads to pass from the harbor to Mokulele Highway? Along Mokulele and Piilani Highways?

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Page 3-114: It is surprising to read in the Draft EIS that the transit route has not been thoroughly assessed for obstacles, specifically overhanging wires and light fixtures.

 

3. KANAIO HIGHWAY INTERRUPTIONS There are numerous references to the need to make changes in the highway that goes from Ulupalakua, through Kanaio, to Kaupo/Hana. There will be curves that will be straightened and 9 large “bumps” that will need to be leveled. The FEIS should include a complete discussion of the potential traffic delays: no. of vehicles, time delays, affects on local residents, etc.

 

4. WORST-CASE TRAFFIC IMPACT SCENARIO Page 3-121: Month seven of the construction cycle is indicated as having the largest number of vehicles and especially super-load vehicles. A special section of the Final EIS should contain an accurate description of a “maximum day” of activity during that month. How many loads would be transported that day? What kind of delays could be expected along each section of the highways? How slow will traffic be moving? Who would pay for all the needed traffic control personnel? Does Maui have an adequate number of heavy lift vehicles for that day? For how many hours will this activity continue? In other words, a worst-case impact scenario should be presented. Finally, it should be indicated how many days during that month 7, this will occur.

 

5. TRUCK ROUTES – ESPECIALLY THROUGH KULA The Final EIS document should be very clear as to the actual routes to be utilized by all trucks delivering the wind blades, the wind towers, the wind turbines, the sand, gravel, and cement, the 600 ton construction cranes, the construction equipment, batteries, the numerous power poles, etc.

 

This traffic information would be useful in not only in evaluating the impacts of this project, but also to help develop mitigation measures. Special attention should be made of the winding roads between Kula and the wind-farm site. Furthermore, there are several bridges along this upcountry route which may not be able to bear both the heavy burdens and their continued use for heavy truck traffic. How will local Kula traffic be impacted?

 

During the post-construction phase will the highway through Kula be utilized for O&M activities? On a daily basis for all of the workers? As a transport route for repair trucks and equipment repairs? This highway has a rapidly growing amount of traffic since the Keokea Hawaiian HomeLands project continues to grow.

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6. LAND TITLES During the public meetings members of the public stated that there were questions as to the actual ownership of the land being discussed for use in the wind-farm project. Please make sure that the FEIS indicates with certainty that the applicant has the legal right to utilize these lands for the wind-farm. The DEIS did not do this. If there are outstanding land title issues, these should be specifically spelled out.

 

The map indicating land ownership should differentiate between lands owned by the State of Hawaii and those under the control of Hawaiian HomeLands. The map at the following website may prove helpful. http://hawaii.gov/dbedt/gis/maps/maui_large_landowners.pdf

 

7. ROAD OWNERSHIP Mention is made of the land owners from Makena Ala Nui up to Kula highway. One of the owners listed is ATC, the owner of Makena resort. During a recent discussion with one of the ATC owners, he made clear that no permission has yet been given to transit the Makena Resort lands. Furthermore, the Final EIS should indicate whether future activities would be allowed to transit the completed Makena Resort development since there could be serious disruptions to that exclusive/expensive resort community.

 

8. MAKENA RESORT To better understand cumulative impacts, page 4-5 needs to add an additional project to the list of other developments. Makena Resort will be significantly impacted by traffic during the construction phase and also subsequently at the time of needed repairs and maintenance. Furthermore, the owner of Makena Resort has yet to provide any indication of access to its lands and roads. If permission is not granted, an alternative route may have to be found.

9. HOMES and RESIDENTIAL AREAS The Final EIS should clearly map locations of all actual and planned (entitled) residences that may be impacted by construction traffic, noise, lights, or view plain interference. This would include residences in Kahikinui, Kanaio, Makena Resort, and residences on the Kula Highway within 1 mile of the generator tie-in corridor. The Final EIS will be better understood if it is clear where the actual residences are located in relationship to the potential impacts.

 

10. ELECTRICITY TRANSMISSION ROUTE (GENERATOR TIE-IN) More details must be provided in the FEIS for the transmission corridor. Specifically, how close (in feet) are the closest neighboring residences where the transmission line crosses the Kula Highway and anywhere else along the corridor route.

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11. Page 4-1 CUMULATIVE IMPACTS and POTENTIAL SEGMENTATION

It was mentioned during one of the public meetings that the electricity transmission lines would be built with a larger capacity than is needed for the proposed 22 MW wind farm. This implies that there may be a “Phase 2″ for this project, or that there may be other energy projects (geothermal or solar) that may be developed in a segmented fashion. Full disclosure is needed to understand the cumulative environmental issues to be evaluated. Section 4 of volume 1 does not do this.

 

What will be the capacity of the transmission (Generator Tie-in) lines running through the corridor? Page 2-23: Will the power lines be sized large enough to accept additional electricity generation from a potential Phase 2 of the Auwahi wind project? Even if there is no phase 2 of the Auwahi wind project, will these power lines be capable of carrying electricity generated by the proposed geothermal plant(s) that will also be sited on the Ulupalakua Ranch property?

 

Note: There has already been a Maui presentation by Ormat concerning a geo-thermal operation near the wind-farm and also on Ulupalakua Ranch lands. They stated that the geo-thermal generators might hook up to the transmission lines being developed by this wind-farm project. There is at least one other company investigating geothermal in the general vicinity of the wind farm.

 

12. NOISE The DEIS primarily discusses the noise resulting from the generation of wind in and around the various wind towers. In addition to the wind turbine operations, the Final EIS document should be very explicit in describing the decibel impacts from the construction activities as well. Blasting? Excavating? Jack-hammers?

 

How many homes will be impacted by noise? And what levels of this noise will be heard in any residence? In attempting to mitigate daytime traffic disruptions, will off-peak truck traffic disturb the communities of Wailea and Makena in the night?

 

13. LIGHTS Will there be any nighttime transporting and/or construction activities which will require lighting? Describe in detail the number of lights on the towers and blades, and their brightness. What can be done to mitigate the “light pollution” in this otherwise dark and pristine area? The flight paths of endangered birds are at stake.

 

14. CONSTRUCTION CRANES Although much of the focus of attention will be placed on the 10 to 15 wind towers, there needs to be a comprehensive impact Auwahi Wind Farm Dick Mayer April 6, 2011 Page 6

 

analysis of the 600 ton construction crane and smaller cranes. How tall are these? Will they work 24/7? Day and night? For how long will they be involved in the construction of the wind towers? Considering their weight, how will they impact nearby archaeological sites?

 

15. CONSTRUCTION TIMEFRAME For how long will the residents of the remote Kahikinui and Kanaio communities have to deal with construction activities? For how long will residents in neighboring communities (Kula and South Maui) have to deal with trucking operations from/to the wind-farm? What can be done to mitigate disruptions in the lives of these communities?

 

16. BATTERY Occasional reference is made to the potential use of a battery to level out the fluctuations in the production of wind energy. This discussion is incomplete; it should be elaborated upon with an indication of the location of the battery and its effects on the Maui electric grid system. Furthermore, the battery lifetime should be made clear, indicating the replacement route when the battery is no longer effective. Finally, could even more batteries be added to improve the benefits of this project?

 

17. PUMP STORAGE Page 2-31: The idea of “pump storage” is dismissed in the Draft EIS because of the expense and potential environmental harm from constructing two sizable reservoirs. Elsewhere in the world one of these reservoirs has been eliminated by utilizing ocean water as the lower reservoir. Would this be a potential option, especially considering that it would transform this wind farm into much more valuable, dependable firm base-power?

 

18. SOLID WASTE Page 3 – 200: Mention is made that all the waste material will be sent to the Central Maui solid-waste dump. The Draft EIS rather cavalierly indicates that the dump will take whatever the project delivers. However, there’s no indication as to how many truckloads will be delivering waste and how many tons will be added to the dumpsite.

 

19. MAXIMUM WIND SPEED 3-21, 3-27 and 3-28 discuss the operational characteristics of the wind mills and indicate the wind speed at which a windmill will be turned away from the wind and no electricity will be produced. However, there is no indication concerning the maximum wind force that the wind towers are expected to be able to sustain in the event of very high winds or a hurricane. The fact that Maui has not received a hurricane for many years should not allow the Final EIS to indicate the NON-vulnerability of these towers and the subsequent potential impact

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on Maui if these towers were to be damaged/destroyed. In the future Maui may become dependent on these wind towers.

20. SMA Page 3-159: an SMA review will need to be done. What questions will be asked in that review and does the Final EIS answer those questions?

 

21. RUN-OFF / DRAINAGE On Page 3-33: During construction this project will have very large surface areas that will be exposed to the elements for periods of time during which a Kona storm could wash vast quantities of soil into the ocean. The Draft EIS discusses potential run-off and claims that best management practices (BMP) will be used. Are even BMP adequate to protect the ocean? What additional mitigating measures can be taken to prevent damage to the Class A waters immediately below the wind farm?

22. HELICOPTER. It would seem logical to utilize a helicopter for a number of this project’s activities. Are there helicopters that could reduce the number of transits and highway disruptions? Are there helicopters large enough to carry some of the super-loads? Would a helicopter be utilized to evacuate workers who may be injured, instead of relying on an ambulance? Is there an available landing place for a helicopter on site?

 

23. RELIABILITY AND LIFESPAN Again, because this project has such significant impacts and may have long-term, ongoing impacts, there should be an evaluation of the lifespan and replacement schedule for the various wind-farm components: the blades, the towers, the turbines, the transmission lines, the battery, etc.

 

This is an environment with much salt air and in a remote location which will make maintenance more difficult. Therefore, how will the immediate surrounding neighbors and the Kula community be impacted by ongoing maintenance and periodic equipment replacement activities?

 

NOTE: The Socio-Economic section (on Pages 3-191 to 3-196) is very superficial. It totally avoids discussion of any significant economic or social issues: a) electric rates; and b) impacts on immediate neighbors/residents.

 

24. ELECTRICITY RATES As part of the socio-economic analysis, it is very important that there be a complete and frank discussion of the impact of this wind energy on MECO, and especially, on all of Maui’s electricity ratepayers. Will electricity be cheaper? More expensive? This needs to be VERY explicitly clarified with actual Auwahi Wind Farm Dick Mayer April 6, 2011 Page 8

 

electric rates in the FEIS.

 

To gain a better understanding and appreciation as to whether the numerous impacts on this project will be compensated by lower electricity rates, SEMPRA should be willing to state in the FEIS the proposed cost (in cents per KWH) to MECO for the electricity which will be derived from the wind-farm.

Page 3-195: Merely stating that there will be a stable long-term “set rate” is not enough. What actually is the rate going to be? Higher? Lower? How will it affect the rates being paid by Maui electricity consumers?

 

Tax Subsidy Furthermore, what is the expected Federal and/or State tax subsidy for this project? What will be the tax write-off that is eventually paid by the federal and state taxpayers? Lower taxes paid by SEMPRA would mean higher taxes for residents.

 

25. PROJECT VIABILITY Because this project may have sizable negative impacts, it is necessary to fully clarify the positive benefits of this project. Therefore, to be included in the FINAL EIS document, there should be a comprehensive discussion on the amount of electricity to be generated (daily and yearly), its reliability and variability (This may also relate to the battery system.), and its financial impact on MECO and on the electricity consumers of Maui Island.

 

26. ENVIRONMENTAL AND SOCIAL JUSTICE The neighboring residential communities of Kanaio and Kahikinui will be most significantly impacted by this project. The residents of these communities have intentionally chosen to live in a remote area with little impact from the modern “industrial world”. These communities and residents deserve to receive benefits from this project commensurate with the negative impacts which they will need to bear.

 

In what way will SEMPRA and/or MECO provide a benefit package for these seriously impacted residents? Will it make available low cost electricity to those residents in the neighboring communities who may wish to connect to the grid? Will SEMPRA be willing to provide a power-line along its transmission corridor coming back to Kanaio and Kahikinui from MECO’s Wailea sub-station? This would, in part, meet an environmental and social justice need and concern. The ability to provide such a line is indicated in the Draft EIS (at the bottom of page 3-201) when it states that such a line could be provided to support both the O&M facility and the Met Tower.

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27. TIMELINE Page 1-9 and page 2-27: The timeline for the proposed project is extremely ambitious, hoping to complete the project and put it online by December 2012. The consequences of not meeting a tight deadline should be discussed in the Final EIS.

 

28. DECOMMISSIONING THE PROJECT Page 2-27 (bottom) and page 2-28: Decommissioning of the project at the conclusion of its 20 year life span will necessitate considerable costs. A “sinking fund” should be established that will allow for either a complete decommissioning and for the removal of the wind farm, or the replacement of the existing wind towers. Without a proper fund being available, these wind towers may remain as a permanent blight on the Ulupalakua Ranch landscape.

 

29. MEASUREMENT UNITS Page 2-4 and in other places, there seems to be an inconsistent pattern in measurement units. Sometimes metric units are utilized, as in this page; and sometimes NON-metric units are utilized. There should be consistency. And for the benefit of readers, I would suggest that “non-metric units” which are more familiar to the FEIS approving body.

 

30. POSSIBLE ERRORS

On page 3-114, there seems to be an error. Does the construction crane way 500 or 600 tons?

On page 3-159, the wrong elevation seems to have been given. The point where the power lines cross the ridge is much higher than 623 feet. Perhaps 4-6,000 feet.

 

On page 3 — 161, consider the view interference from the tallest towers (3MW), not the shortest ones.

 

On page 3-191, the population statistics are given for Maui County. This is not the area that will be impacted by the project. There is no electricity connection between Maui Island and the other islands. Therefore, all impacts should refer to Maui Island.

 

On page 3-197, the number 2,328 is incorrect; it should be about 232.8.

 

Page 4-4 discusses climate and utilizes a gross exaggeration of the benefits of the wind farm by stating that there will be 12,278 metric tons per hour savings of

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greenhouse gases (GHG). This miscalculated amount would, if true, produce savings greater than the total output of Maui greenhouse gases. That cannot be.

 

31. CAVEAT There are no comments in my letter concerning several major topics which are included in this Draft-EIS document: archaeology, plant life, animal life, etc. The lack of comments in these areas should not be interpreted as meaning that there are no issues with those topics. Others may be better able to discuss the adequacy of those topics.

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Mahalo for your consideration of these comments. I look forward to a substantive response in the FINAL-EIS.

Sincerely,

 

 

Prof. (Emeritus) Richard “Dick” Mayer (Geography and Economics)

PERSONAL NOTE Thank you for your attention to and response to these concerns. The rural atmosphere of the Upcountry region is cherished by Upcountry residents whose wishes are clearly expressed in the (Upcountry) Makawao-Pukalani-Kula Community Plan, as well as in the Kula Community Association vision.

 

CC. Office of Environmental Quality Control, Hawai’i Dept. of Health

Environmental Center, University of Hawai’i

Kula Community Association