Hawai’i island activist Cory Harden reports that the Mauna Kea Management Board was sharply critical of the Army’s High-Altitude Mountainous Environmental Training (HAMET) environmental assessment. Mahalo to Cory for sharing her comments on the Army’s Environmental Assessment for High-Altitude Mountainous Environmental Training on Mauna Kea:
Comments Re: Environmental Assessment (EA) for High-Altitude Mountainous Environmental Triaing (HAMET)
at Pohakuloa, December 2010
for Mauna Kea Management Board meeting 10 AM Tuesday, January 18, 2011
by Cory Harden, Box 10265, Hilo, Occupied Hawai’i 96721 8080-968-8965 email@example.com
Please call for a Federal Environmental Impact Statement. The Army wants to start training next month, but the EA has many shortcomings.
The EA does not fully explore the alternative of training in Colorado, where a train-the-trainer course for HAMET is already available. [p. 2-13]
An “exercise would include up to three flights [of one or two aircraft] per mountain [Mauna Kea and Mauna Loa], running continuous operations for up to 18 hours for each 24-hour period.” Helicopters would fly 1,500 to 2,000 hours each year. LZs (landing zones) are at 8,000 to 12,000 feet. [p. 2-8]
LZs were already constructed under special-use permits [p. 2-8], not an EIS, so we may never know the full impacts. Helicopters have been already landing on Mauna Kea for seven years with little public oversight. Helicopters expand military training beyond Pohakuloa Training Area into the State Conservation District.
The EA says crashes are “unlikely” [p. 4-12] and “…the CAB (Combat Aviation Brigade) has had zero accidents related to flight at high altitude, both in theater and at garrison” [p. 2-7]
There is no mention of three fatal military helicopter crashes in fifteen years on O’ahu
2009– two pilots died in a Kiowa crash and fire. 
2001– six soldiers died when two Black Hawks crashed at night. 
1996– two soldiers died when a Cobra crashed. 
The EA describes no plans for
- Releases of fuel or other hazardous substances
- High winds, clouds, or fog
- Landings outside of LZs (landing zones) due to mistakes or emergencies, such as the landing near the adze quarry, inside the Natural Area Reserve, in November 2003
People hike and camp at some of the pu’u that will be used as LZs. How will they be warned about helicopters, especially at night?
The Army says noise and visual impacts on cultural practices and recreation will be insignificant. Would they say the same it was Machu Picchu?
An EA map shows a high density of cultural and historic sites–but only inside the Science Reserve boundary. There may be a similar density of undiscovered sites outside the boundary. [map D-8]
Team to investigate Kiowa crash that killed 2, Honolulu Advertiser, 5-29-09
 Six die in crash of Army copters, Star-Bulletin, 2-13-01
There are four mounds about 100 feet from LZ-6 believed to be prehistoric Hawaiian features. (And a fifth nearby.) The EA should have a thorough survey, a literature review, and oral history documentation.
Mounds and rock enclosures near the LZs appear on Google maps, but not the EA maps.
The Humu’ula trail and other trails are missing from EA maps. The EA does not describe present day use of these trails.
Kepa Maly’s extensive cultural/ oral history review for Mauna Kea is not referenced.
There is no mention of the illegal takeover of the nation of Hawai’i in the cultural overview. [p. 3-29]
There are seven listed wildlife species, and eight plants, that are confirmed, may occur, or have potential habitat in the project area. [p. 3-23 to 3-24]
The EA admits there is no information on wildlife population densities near the landing zones and flight paths. [p. 3-22]
The EA says studies would be needed to evaluate wildlife reactions to helicopter noise, but mentions no plans for studies.[p. 4-12]
“Information on the range of the Hawaiian hoary bat or ‘ope‘ape‘a…was not available at the time of this assessment, but the USFWS biological opinion for PTA states that the Hawaiian hoary bat does occur on PTA…” [p. 3-26]
Flight paths are over palila critical habitat and over hammerhead bird habitat. Both species are on the Federal and State endangered list. Effects of noise and vibration on breeding and rearing success is not analyzed, and mitigation is not described in detail. [p. 4-10 ff]
Wekiu bugs live in loose cinders without dust. Rotor wash will probably blow dust into cinders, and landings will probably compact cinders.
Helicopters will land on pu’u with fragile ecosystems.
A helicopter hovered too low over critical habitat in early 2006. [p. 2-7]
The EA says cleaning and mitigation measures will minimize impacts from invasive species, but gives no specifics. [p. 4-12]
Noise is only analyzed as averages over 24 hours. [p. 4-24] Effects of intermittent loud noise, plus vibration, are not analyzed.
The EA says impacts would not be significant partly because the area isn’t “used by…large numbers of people.” [p. 4-25] By this logic, it’s acceptable to flood wilderness areas with helicopters.
Day training would impact views. Night training would impact star-gazing for locals, tourists, and perhaps observatories.
There are no viewplane maps showing where people will see helicopters.
11 of the 17 people on the consultation list are military.
One person on the list apparently was not consulted (Stephanie Nagata).
One never formally commented (State Historic Preservation Division) [p. 4-19, pp. 7-1 to 7-3]
Cultural practitioners, lineal families associated with the area, hunters, hikers, and others who use the area were not consulted.
The EA cites numerous projects with serious impacts—observatories, Strykers, adding Keamuku to Pohakuloa, Saddle Road construction, the current Pohakuloa Modernization project—but says cumulative impacts with helicopters added would not be significant. [p. 5-10 to 5-12]
The EA does not go into detail re. impacts on air tours from closing airspace. [p. 4-31 to 4-32]
The EA does not say when training will occur, except for sometime between February and August 2011, and perhaps through February 2012. [p. 2-7 to 2-8]
The EA does not identify the type of permit used in past, nor the State department that issued it. [p. 2-6]
The EA does not specify mitigations requested by DLNR (State Department of Land and Natural Resources) after the 2003 landing in the NAR.
Photos of LZs don’t show all of them, and don’t identify which LZs are shown. [pp. B-9 to B-13]
The EA quotes the UH (University of Hawai’i) CMP (Comprehensive Management Plan)—but the CMP covers a different geographical area.
PO Box 10265
Hilo, Hawai’i 96721