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June
22, 2009
RE:
0792
Craig
Foltz
National
Science Foundation
Division
of Astronomical Sciences
4201
Wilson Boulevard, Room 1045
Arlington,
VA 22230
Supplemental
Draft Environmental Impact Statement
Advanced
Technology Solar Telescope
Makawao,
Maui
Dear
Mr. Foltz:
The
National Science Foundation proposes to construct an Advanced
Technology Solar Telescope (ATST) facility at the summit of Haleakala
on 0.86 aces of land within the 18.166 acre University of Hawaii (UH)
Institute for Astronomy (IfA) Haleakala High Altitude Observatories
(HO) site. The preferred site is located east of the existing Mees
Solar Observatory. The alternative site is another location within HO
– a currently unutilized site known as Reber Circle. A No-Action
Alternative is also analyzed in the document. The primary goal of the
proposed project is to better understand solar magnetic activities
and variability. The ATST Supplemental Draft Environmental Impact
Statement (SDEIS) is a joint Federal and State of Hawaii document
prepared in compliance with Federal National Environmental Policy Act
(NEPA) regulations and the State of Hawaii Chapter 343, Hawaii
Revised Statutes. The SDEIS is also prepared with the intent of
evaluating potential environmental impacts associated with issuing a
National Park Service Special Use Permit application to operate
commercial vehicles on the Haleakala National Park road during the
construction process and operational phase of the proposed project.
This
review was conducted with the assistance of Richard Mayer, Maui
Community College; Jacquelin Miller, Environmental Center; and Ryan
Riddle, Environmental Center.
General
Comment
Our
reviewers found preparation
of a meaningful review of the SDEIS to be particularly difficult and
time consuming due to the overall verbiage of its format and the
extensive use of acronyms throughout the text. Throughout the
document there are frequent duplications of sentences and incorrectly
numbered figures and sections as a result of what appears to be cut
and paste word processing. The document is also lacking in in-text
references – an issue that makes cross-reference between the
Executive Summary, Description of Affected Environment (Section 3.0)
and Summary of Environmental Consequences Cumulative Effects and
Mitigation (Section 4.0) particularly difficult. These factors all
serve to frustrate the reader’s ability to objectively review the
text. As for the plethora of acronyms, even a modest effort to write
out the full name of the abbreviated term every few pages would make
reading the document infinitely more user friendly.
In
addition to our general comment, we also have several specific
comments.
Electrical
Systems (p.
ES – 41)
In
regard to the provision of electrical power for the proposed project,
the document states, “With this upgrade, there should be sufficient
capacity to handle activities at the Mees or Reber Circle sites”.
In this sentence the word “should” needs to be replaced with the
word “will”.
Other
Required Analyses (p. ES – 45)
In
reference to environmental impacts from implementation of the
proposed project at either the Mees or Reber Circle site the SDEIS
states, “No major effects were identified that could not be
mitigated to a less minor level”. This use of a double negative is
confusing to the reader.
Reasonably
Foreseeable Future Actions (p. ES – 46)
Mention
is made of the proposed Satellite Laser Ranging (SLR) station that
would be installed on the southwestern side of the Mees Solar
Observatory. Is that action in any way related to or dependent upon
ATST site selection? What possible effects could the SLR station have
upon the ATST facility? Will the SLR station require an additional
structure at the Mees site? What is the anticipated schedule for the
implementation of the SLR project?
Topography,
Geology, and Soils (p. ES -53)
This
paragraph references using native soils and rock to “restore the
pu`u at Reber Circle from its present truncated cone shape to a
closely rounded natural appearance” thereby adding an estimated 24
feet of additional height. Given the concerns expressed by the
Hawaiian community for soil stability, preservation, and general
protection of the mountain, additional information on the potential
impacts of such an earth moving/building project warrants greater
explanation. This is mentioned as a possible mitigation measure and
an alteration of topography yet it is not discussed further in
Section 4.
Project
Location (p. 1-2)
In
the last paragraph on page 1.1 the total area of the project is given
as 0.86 acres. The document states that this figure includes the
leveling area, buildings, and paved pads. In Section ES-2.4 (p. ES-7)
the SDEIS states, “The entire facility would include approximately
43,980 square feet of new building space within a site footprint of
0.74 acres.” We assume that the figure given in the executive
summary does not include the entire leveling area and paved pads. It
would be helpful to have a breakdown of the square footage required
for each of the project’s various components.
Site
Selection Chronology (p. 2-2)
In
the first paragraph on page 2-2 the SDEIS states that the criteria
that formed the basis for the elimination of the other 66 sites are
discussed in Section 2.2.2 – Site Selection in Detail. There is no
Section 2.2.2 in the text, however, there is a Section 2.3.1 titled
“Site Selection in Detail”.
Response
to Public Comment Regarding Alternative Siting on Haleakala (pp. 2-6 - 2-7)
The
SDEIS inadequately explains why a space-based telescope is not
completely evaluated as one of the alternative sites. It would seem
that a space-based telescope would have many of the advantages that
were found at Haleakala and would avoid the need for “adaptive
optics”.
The
SDEIS limited its alternatives analysis to the 18 acre site operated
by the UH IfA. A potentially superior site, perhaps in the saddle to
the southwest of the 18-acre site, was only mentioned and did not
receive detailed evaluation in the text. This alternative site could
potentially avoid many of the visual problems of being located so
close to Haleakala National Park. The site also may avoid some of the
problems with Hawaiian cultural sites.
Features
of Infrastructural Design (pp.
2-19 – 2-20)
In
literature supplied at one of the scoping meetings it was mentioned
that a potential solution to the considerable ground heat at the
location would be the installation of a white apron extending
approximately 10 meters from the telescope’s base. It is further
stated that this white apron would provide numerous benefits such as
reducing the height of the telescope, containing spilled lubricating
oil and collecting water runoff. This design element is never
discussed in the SDEIS. If the white apron were built, what would be
the needed telescope height?
Electricity (p. 2-39)
In
this paragraph the SDEIS discusses the electrical needs of the
project. Were photovoltaics among the options considered? Given the
local conditions this seems to be a suitable alternative.
An
upgrade to Maui Electrical Company’s (MECO) HO sub-station is
mentioned in this section. However, no mention is made as to who will
pay for the upgrade. Will this burden fall upon the general
population of Maui?
Also
mentioned is a MECO-funded study that was conducted to identify
economizing strategies for the proposed project. Can you summarize
the potential strategies that were identified as a result of the
study?
Features
of Infrastructural Design (p. 2-41)
In
Section 2.5.1 the SDEIS mentions the need for a new above ground fuel
storage tank to support the back-up generator at the Reber Circle
site. The document states that the proposed location and capacity of
the tank have yet to be determined. It would seem that the volume of
fuel needed to operate the emergency system over the expected life of
an emergency can be calculated. What is the capacity of the Mees fuel
storage tank and where is it located relative to the proposed
structures?
Haleakala
Summit as a Traditional Cultural Property (pp. 3-8 – 3-9)
On
pages 3-8 and 3-9 the SDEIS states, “Native Hawaiian stonemasons
erected the West and East ahu for ceremonial use by Kanaka Maoli at
HO in 2005 and 2006, respectively . . . Although the purpose of this
construction was to restore structures previously existing on
Haleakala, the original structures were not necessarily in the
particular locations where the new ahu were erected”. Is there any
previous documentation (oral or written) of the use of the sites
where the ahus were constructed in 2005 and 2006?
Visitor
Use and Experience (p. 3-46)
In
regard to a 2007 survey given to visitors exiting HALE the SDEIS
states, “HALE has indicated that this survey is significantly
flawed and likely biased and there are significant technical errors
in the instrument and related reporting. Also, HALE indicated that
the conclusions are based on an insufficiently designed and
administered survey.” The SDEIS then seems to agree with the stated
flaws while proceeding to draw conclusions from the results. Do plans
exist for conducting a revised survey based upon recognized flaws in
the 2007 survey? The SDEIS should not make the statement that
“approximately 60 percent of respondents did not care if the new
observatory was built” based on data that is recognized as being
significantly flawed.
Natural
Hazards (p.
3-70)
In
this section mention is made of closing the Park road whenever
weather conditions become critical and serious enough to warrant
protecting human life. How often does closing of the road occur and
for what duration in any given winter? Will this present a problem
for construction or safety during erection of the facility?
Earthquakes (p. 3-71)
In
the description of earthquake risk the SDEIS states, “Any repeat of
the 1871 Lana`i earthquake would affect the project site. Mitigation
of this risk is discussed in Section 4.17.14 – Natural Hazards”.
Section 4.17.14 is titled Air Quality, not Natural Hazards. Did you
mean Section 4.18.14?
Land
Use and Existing Activities (p.
4-6)
This
section mentions the FAA’s 2007 issuance of a Notice of Presumed
Hazard regarding probable radio frequency shadowing at the FAA RCAG
facility. This issue seems to be of critical importance and perhaps
one of the most significant impacts of the proposed project. This
topic is only briefly discussed in the text and possible mitigation
measures are never mentioned. Solutions to this navigation concern
must be fully addressed in the Final SEIS.
Cultural,
Historic, and Archaeological Resources (pp. 4-7 – 4-14)
What
is the time frame for the Memorandum of Agreement (MOA) /
Programmatic Agreement (PA) and Section 106 consultation process?
This is an issue that should have been resolved prior to issuance of
the SDEIS and one that should be fully addressed in the Final SEIS.
Visual
Resources and View Plane (pp. 4-29 – 4-75)
The
SDEIS does not mention the type of paint to be used in coating the
exterior of the telescope facility. In scoping meetings it was
pointed out that the white paint would be “extremely reflective”
- much more so than the highly visible neighboring AEOS telescope.
Consequently, the visual impact of the 143 feet high ATST will be
amplified by its reflected radiance. The Final SEIS should discuss
the impacts that this will have upon visual resources and view
planes.
Visitor
Use and Experience (pp. 4-75 – 4-80)
Of
particular concern are the 250-foot crane and smaller 100-foot cranes
that will be utilized for many years during construction. These
visual and aural disturbances (individually and in combination) are
most certainly a significant environmental impact. Over the course of
7 years over 7,000,000 visitors will be impacted.
Communications
Systems (p. 4-92)
The
SDEIS mentions that the location of the Maui base facility and ATST
data repository has yet to be determined. How can one state that
there is no impact to communication systems given that there is no
description or evaluation of the facilities, equipment, and
locations? In this section there is also reference to communication
links via a fiber optic cable. The SDEIS states, “Connectivity from
the site to the base headquarters would use existing dark optical
fiber from the proposed ATST Project.” Does the connectivity refer
to the military’s computer located in Kihei, to the Waiakoa
Astronomy facility in Kula, to the new astronomy building constructed
in Kula Malu in Pukalani or does it apply to all of these locations
or none of these locations? This issue should be resolved in the
Final SEIS.
Employment,
Economics, and Income (p. 4-112)
The
economic analysis provided in the SDEIS is lacking. Section 3.12.1.2
fails to describe the major economic activity on Maui, namely
tourism. It fails to mention employment in tourism as well as tourism
dependency. Additionally, Section 4.12.2 does not mention how the
proposed project could potentially alter the visitor experience and
therefore the economic benefits associated with Maui’s tourist
industry. The Final SEIS should include this as part of the economic
study.
Effects
of Past, Present and Reasonably Foreseeable Future Actions (pp. 4-127 – 4-128)
There
are additional new projects at Haleakala in addition to the ATST:
Pan-STARRS, the NASA Transportable Laser Ranging System, and the AEOS
Mirror Coating Facility. What are the cumulative impacts associated
with these projects? Do they each have a separate CDUA? If so, how
will the DLNR Board be able to consider cumulative impacts?
Thank
you for the opportunity to review this Supplemental Draft EIS.
Sincerely,
Peter
Rappa
Environmental
Review Coordinator
cc:
OEQC
Charlie
Fein, KC Environmental, Inc.
Mike
Maberry, UH Institute for Astronomy
James
Moncur, WRRC
Richard
Mayer
Jacquelin
Miller
Ryan
Riddle
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