SEMPRA’S Auwahi Wind Farm – PRELIMINARY FEIS Dick Mayer
August 9, 2011
Aloha Planning Commissioners,
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. I am pleased that our federal and state governments are giving the applicant tax credits of 65% of the projects costs, thus transforming the $140 million project cost into a net investment of only $49 million for San Diego based Sempra Energy.
Nevertheless, I feel it is necessary to make sure that this new wind energy project will be sensitive to Maui’s special physical and cultural environment. Therefore, the following is a list of items whichthe Maui Planning Commission should consider in reviewing and eventually accepting (with conditions and recommended changes) or rejecting this PRELIMINARY Final Environmental Impact Statement.
I have divided the comments into FIVE general categories:
A) SUPER-LOADS – TRANSIT ROUTE
B) TRAFFIC DURING CONSTRUCTION PHASE
C) CONSTRUCTION SITE
D) PROJECT FINANCES and POTENTIAL BENEFITS
E) RELATED ISSUES
A) SUPER-LOADS – TRANSIT ROUTE
1. TRANSIT ROUTE Some may think that there are similarities in transporting the super loads from Kahului Harbor to Auwahi as there were in transporting to the Kaheawa Pasture windfarm site. This is a false impression of the route being taken from the harbor to the Auwahi windfarm site. Unlike the Kaheawa Pasture route which traveled only on wide, relatively low traffic highways, the Auwahi route will pass through several highly populated areas (Kihei, Wailea, and Makena) and on several high-traffic roads and highways (Puunene Avenue, Mokulele Highway and Piilani Highway).
2. MIS-LABELED MAP The map in volume 1, page 3-163, incorrectly labels “East Kamehameha Avenue” as it passes in front of the Kahului Safeway store, as “Kaahumanu Avenue”.
3. TRAFFIC THROUGH KAHULUI TOWN AND SOUTH MAUI There needs to be a detailed description as to what traffic would be able to operate on the impacted roads during the many super-load 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 Puunene Avenue, Mokulele Highway and Piilani Highway, 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? None of that information is available in this preliminary FEIS.
4. Traffic signals and signs The FEIS states that there will be a need to remove several traffic signals and signs along the transit route. This could result in serious traffic disruption and potential traffic accidents immediately following the passing of a super load. No indication is given as to how soon after each transit event the signs will be restored. For example, if a super-load passes along the transit route will the signals and signs be restored just after each super load passes? Or at the end of the day? Or only after all the super-loads have passed?
5. WORST-CASE SUPER-LOAD TRAFFIC IMPACT SCENARIO The Final EIS should contain an accurate and complete description of a “maximum day” of traffic disruption. How many super-loads would be transported that day? What kind of time-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? For how many hours will this activity continue? In other words, a worst-case impact scenario should be presented.
6. TIME OF OPERATION for SUPER-LOADS The Final EIS states that the super loads will travel during “off-peak” hours between 10 PM and 10 AM plus during weekends. Operating between 6:00 AM and 10 AM is NOT an off-peak period. This is the rush-hour time. Furthermore, weekends are no less busy through the Wailea and Makena resort areas since most of the traffic consists of hotel employees and tourists.
The final EIS should be corrected to state that the “off-peak“ hours shall be between 6:30 PM and 6 AM every day (including weekends).
B) TRAFFIC DURING CONSTRUCTION PHASE
7. TRUCK ROUTES – ESPECIALLY THROUGH KULA The Final EIS document has made a significant change from the Draft EIS. In the earlier Draft volume, there was very little traffic (only employees’ personal vehicles) to be routed along the Kula Highway, through Keokea, and along the extremely narrow, very winding, sub-standard rural road to Ulupalakua.The Final EIS now states that between two thirds (67%) and three quarters (75%) of the traffic will pass along this route. Upcountry residents are unaware of this significant change. That is why they have not commented to-date on the EIS.
Especially disturbing is to now learn that this substandard route will be utilized by the large dump trucks making their round-trips carrying aggregate from the tower excavation holes to some undetermined, unspecified sites, plus the many cement trucks in their roundtrips to/from the wind farm site.
Unfortunately, the final EIS has totally ignored the difficulties of traversing the Kula Highway and the extremely narrow, very winding, sub-standard rural road to Ulupalakua. Some of the considerations that need to be evaluated include: extremely low visibility winding turns, traffic delays, school bus traffic, morning traffic, Kula Hospital, and unsuspecting tourist traffic coming from Hana in the late afternoon.
Of very serious concern and deserving special mitigation measures are the five (5) schools along this upcountry route: King Kekaulike High School, Carden Academy, Kamehameha (Maui), Haleakala Waldorf, and Kula Elementary School. Just as the super-loads are discussed in detail, the upcountry route must consider in detail both the sub-standard road and the multiple schools.
Finally, it needs to be pointed out that there is no discussion in the FEIS of the effects on the road from so many heavy vehicles, nor any promise to restore the road (especially between Keokea and Ulupalakua) from the wear and tear from the heavy loads.
8. WORST-CASE UPCOUNTRY TRAFFIC IMPACT SCENARIO The Final EIS should contain an accurate and complete description of a “maximum day” of traffic disruption on this upcountry highway/road. How many dump-trucks and cement trucks would be transported that day? What kind of time-delays could be expected along each section of the highways? Who will regulate the traffic to make sure that there are no accidents? How slow will traffic be moving? Who would pay for all the needed traffic control personnel? For how many hours will this activity continue? In other words, a worst-case impact scenario along the Upcountry route should be presented.
C) CONSTRUCTION SITE
9. WATERThis Preliminary Final EIS document neglects to make clear as to the quantity, the original source, and the transmission mode of the water to be utilized in this project. Numerous potential options are discussed, including tapping into the County’s Central/South Maui water line which gets its water from the already stressed Iao Aquifer. The FEIS should settle on one water source and indicate the impacts.
10. DISPOSAL OF AGGREGATE (DIRT) IS UNCERTAINThe document describes the many dump-trucks that will be carrying away all of the aggregate being removed to prepare the foundations for the eight towers. Since each hole (FEIS page 2-6) is expected to be 20 yds. wide and 2.67 yds. deep, there will be about 1,066 cubic yards of aggregate from each of the 8 holes, and a total of over 8,500 cubic yards that will need to be disposed of. However, there is NO indication where that all that dirt will be disposed of (Page 3-166). It will have an impact somewhere, but where?
11.NOISE DURING CONSTRUCTION The Final EIS should be very explicit in describing the decibel impacts, not just from the windmill operations, but also from the construction activities. There will be on-site and road blasting, considerable heavy machinery activities and hundreds of truck movements. How many homes will be impacted by this noise? And what levels of this noise will be heard in nearby residences?
12.NOISE DURING WINDMILL OPERATIONS.The preliminary Final EIS document is explicit in describing the decibel impacts from the wind turbine operations. However, the document neglects to evaluate the implications of that noise impact on the adjoining Hawaiian Home Lands. Many acres of these Home Lands will henceforth become unusable.
13.RUN-OFF / DRAINAGE A problem arises because the EIS on page 3-35 mentions County Code 20.08 which only considers a “one hour” rainfall impact. During construction this project will have very large surface areas that will be exposed to the elements for periods of time during which a multi-hour and even multi-day Kona storm could wash vast quantities of soil into the ocean. This EIS discusses potential run-off and claims that best management practices (BMP) will be used. Even BMP may NOT be adequate to protect the ocean during a storm of over one-hour. What additional mitigating measures can be taken to prevent damage to the Class A waters immediately below the wind farm?
D) PROJECT FINANCES and POTENTIAL BENEFITS
14.IMPACT ON MAUI RESIDENT AND COMMERCIAL RATEPAYERS Because this project will have sizable disruptive impacts during construction, it is necessary to understand the positive benefits of this project. Therefore, to be included in the Final EIS socio-economic analysis, there should be a comprehensive discussion on the financial impact on the electricity consumers of Maui Island. This should include a complete and frank discussion of the impact of this windfarm project on MECO, and especially, on Maui electricity ratepayers. Will electricity be cheaper? More expensive?
This transparency is especially important because Sempra is receiving such a huge financial subsidy in the form of tax credits. Sempra states that they will be investing a gross amount of $140 million. Sempra will receive a federal credit of 30% and a Hawaii state credit of 35%. Thus, SEMPRA’s net cost will be only $49 million.
Furthermore, according to the EIS they plan to sell on average 78,500,000 KWH per year. They will receive $0.203 per KWH the first year and more each year thereafter. Thus, Sempra will start with an annual income of about $16.0 million per year. They will have relatively few additional costs (only 5 employees).
Revenues of about $16 million on a net investment of about $49 million should mean that Maui ratepayers should be seeing considerably lower electricity rates, but will they? Funds should also be adequate for more “community-benefits.
15. RELIABILITY and LIFESPAN Again, because this project has such significant impacts and may have long-term, ongoing impacts, there should be a better evaluation of the longevity and reliability of this windfarm. This is a harsh environment with much salt air and in a remote location which will make maintenance more difficult.
The FEIS states (Volume 1, Page 1-3) that Sempra Generation has extensive experience operating 2,700 MW of generation capacity. However, a check of their website indicates that SEMPRA has only two wind farms, one of which was dedicated less than 4 weeks ago (July 13, 2011), and the other in a dry area of northern Mexico far from salt air breezes.
16. ENVIRONMENTAL and SOCIAL JUSTICE — “Community Benefits Package” The neighboring residential communities of Kanaio and Kahikinui (Hawaiian Home Lands) will be the most significantly impacted by this project. The residents of these communities have intentionally chosen to live in this remote area where there is little impact from the modern “industrial world”. Many others would also care to live in the Kahikinui Hawaiian Home Lands if they could get water and access to some source of energy (electricity).
As part of a “Community Benefits” package this wind farm project should provide existing and even future residents with some important benefits. Appendix M of the FEIS discusses “community benefits” and offers no meaningful benefits for the local residents, offering only to do a “study” for a potential water well.
SEMPRA should be willing to provide a power-line along its transmission corridor coming back to Kanaio and Kahikinui from MECO’s Wailea sub-station.The ability to provide such a line was indicated in the Draft EIS (at the bottom of page 3-201) when it stated that such a line could be provided to support both the O&M facility and the Met Tower. SEMPRA should also make available low cost electricity to those residents in the neighboring communities who may wish to connect to the grid. This would, in part, meet an environmental and social justice need and concern.
Finally, rather than “studying” a water well, SEMPRA should be required to drill and operate a water well to be made available to neighbors after the construction of the wind towers? It could have great utility for both domesticl and some agricultural use.
E) RELATED ISSUES
17. INCOMPLETE MAPThe map in Figure 1-3 on page 1-8, showing the landowners that would be affected by the windmill construction, leaves off a very important landowner. Immediately to the east of the windmill site is a large land parcel owned by Hawaiian Home Lands. It is significant that identification of this land parcel has been left off of the map because these lands are where the noise contours from the windmills will be particularly high. (See Figure 3.11-1 on Page 1-197.)
18. LIGHTS AND BIRDSThe Final EIS notes that there will be a possibility of interference with a number of endangered species because of the use of lights on the very high windmills. The document points out on page 3-74 that the lighting requirements will follow the guidelines of the FAA. However, it is unclear in the Final EIS whether the FAA requirements will negatively affect the various endangered species. Low FAA lighting requirements does not guarantee minimum impacts to wildlife..
19.BATTERY IS UNDERSIZED Reference is made on page 2-20 to the use of a battery to level out the fluctuations in the production of wind energy. This discussion is unclear AND contradictory because the final EIS states that Maui Electric cannot handle more battery capacity (Volume 3 PDF page 591, “. . . extra storage would exceed the utility’s performance requirements.”)
However, the document then goes on to say that in the future, additional batteries could be utilized (Volume 3 PDF page 591, As battery costs decrease . . . it could become economically feasible to add additional batteries to the project which would allow the MECO grid to accept more wind energy.)
It would be excellent if additional batteries could be installed now at this stage, so that the wind power could be utilized as much more valuable firm base-load electricity, thus reducing the need for Maui Electric to build and maintain additional diesel units.
20.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 the complete decommissioning with the removal of the wind farm, or the replacement of the existing wind towers so the production of renewable energy can continue. Without a proper fund being available, these wind towers may remain as a permanent blight on the Ulupalakua Ranch landscape.
A Planning Commission acceptance of the Final EIS and the approval of the SMA permit should contain an actual condition .requiring such a letter of credit to guarantee the funds for decommissioning.
21.“WOULD” TO “SHALL” The final EIS document has numerous places where the non-binding word “would” is utilized (for example, on page 3-164, 8th line; and page 3-166, last line of 2nd paragraph). It would be preferable if the Maui Planning Commission requires that the word “would” be changed to “shall”. This may seem to be a small matter at this stage, but it would make sure that the mitigation measures that have been described actually get implemented.
With careful planning and sensitivity to the physical and cultural environment, I believe that this wind project can be a valuable addition to meeting Maui’s energy needs. I hope that the comments which I have made above will help SEMPRA to complete both its Final EIS and eventually a project that will be mutually beneficial to the company and to Maui.
Finally, I request:
A) that the Maui Planning Commission strongly urge its staff to make sure that the questions raised here are answered in an amended FINAL EIS; and
B) that the Planning Commission itself makes sure that the Final EIS contains the necessary and appropriate mitigation measures to protect Maui’s environment.
Sincerely yours,
Dick Mayer