Testimony to BLNR to REJECT (not Accept) the Final EIS on Pogakuloa

[jim albertini]

Testimony to BLNR to REJECT (not Accept) the Final EIS on Pogakuloa

email -- blnr.te...@hawaii.gov

May 6, 2025

From Jim Albertini, President of Malu 'Aina Center for Non-violent Education & Action

P.O. Box 489 Ola'a (Kurtistown) Hawai'i 96760
Phone 808-966-7622 Email j...@malu-aina.org Visit us on the web at www.malu-aina.org

Aloha BLNR members,

Our organization, Malu 'Aina, is strongly opposed to any further bombing and desecration at Pohakuloa.  We urge you to REJECT the Final EIS on Pohakuloa that is extremely deficient in a number of areas.

1. Pohakuloa is classified as a State Conservation District, the highest protected land status.  Bombing, shelling and military pollution are not  compatible land uses in a conservation district.  It's a no brainer!  The full extent of military destruction at Pohakuloa has not been thoroughly investigated.

2.  The Final EIS inadequately addresses concerns for protection of endangered plant and animal species at Pohakuloa, and with Trump's environmental budget cuts it appears protection of endangered species will be further trashed.

3.  The military record of environmental contamination and failed cleanup in Hawaii is staggering.  Tens of millions of live rounds from a wide variety of weapons systems have been fired from the lease lands firing points into the Federally seized (not owned) lands of the 51,000 acre impact area.  The military didn't even pay 1 cent for the 84,000 acres of Hawaii crown and government lands seized by a Presidential executive order in 1964 under President Lyndon B. Johnson.  Our organization has documented 57 present or former military sites on Hawaii island totaling more than 250,000 acres of military contamination.  The present PTA commander LTC Timothy Alvarado has the gall to say " We (the military) are stewards of the land."  Please list all the various weapon systems fired into the PTA impact area and the number of rounds fired over 80 plus years.

4.  The military cultural impacts and environmental assessments are superficial and insufficient.  The US military has been bombing and shelling Pohakuloa for more than 80 years, and yet more than half of Pohakuloa hasn't had an assessment survey of cultural and historic sites.  What does that tell you?

5.  The increasing fire risk at PTA is inadequately addressed.  Pohakuloa is a dry windy area in the center of Hawaii Island.  The Final EIS says that military bombing and shelling has started 1261 wildfires at PTA since 1975.  It also notes that prior to 2012 data is incomplete so the number of fires could actually be higher.  The final EIS also says that the wildfire risk will only be increasing in the future due to  more and more extremes of climate change. One fire started on PTA in 2022, a year before the Lahaina fire, burned more than 12,000 acres off the base destroying endangered species habitat.

6.  The Army completely understates the quantity of Depleted Uranium (DU) weapons fired at PTA and the Hazards.  The EIS states 400 DU spotting rounds for the Davy Crockett Nuclear weapon system.  Army Hawaii Garrison Colonel Howard Killian testified before the Hawaii County Council in 2008, that based on the number of people certified to fire the Davy Crockett weapon system at PTA, TWO THOUSAND DU spotting rounds were fired at PTA.  This is after years of denial by the Army that any DU was fired at PTA.  It is likely that additional DU penetrating rounds were also fired at PTA.  Col. Killian testified that DU was not prohibited from being used in training until 1996.  DU has a half life of 4.5 Billion years and when DU metal is hit with high explosives it burns and turns into DU oxide particles that can be carried long distances in the wind.  Dr. Lorrin Pang, MD, listed in the top 3% of America's best doctors, who spent 25 years in the Army medical corps has stated that inhaling DU oxide particles is the most deadly form of radiation.  It can travel through the lymph system causing various cancers.  It also causes birth defects and even genetic damage passed to future generations.  Dr. Pang has said that Pohakuloa should be ringed 360 degrees with proper air filters for a full year to really see what toxins are coming off the base.

7.  DLNR Staff  K. Tiger Mills of Office of Conservation and Coastal Lands notes in a letter dated April 30, 2025 (HA 25-173) additional information the Final EIS should address, including --

A.  A response to the Hawaii County Council regarding Resolution 639-08 based upon comments our organization and others raised in the draft EIS process

B.  Additional discussion on the rare environmental setting on the high-elevation sub-alpine tropical dryland ecosystem.

C.  A complete inventory of archeological sites that have been or may be impacted by military training.

8.  Comments by DLND staff Ryan Okano, Division of Aquatic Resources, April 29,2025 about impacts to aquatic resources that need to be addressed.

9.  PTA base commander LTC T. Alvarado has refused to participate in public town hall forums on Pohakuloa.  See press release below of Oct. 1, 2023

An invitation to PTA Commander LTC Tim Alvarado to speak and answer questions at a public meeting

FOR PUBLIC RELEASE  Oct. 1, 2023

Mailed to:

Pohakuloa Training Area (PTA) Commander

LTC Tim Alvarado

PO Box 4607, Hilo HI 96720

also emailed to 

Amy Phillips 

PTA PAO to be delivered to LTC Alvarado

Phillips, Amy CIV USARMY USAG (USA) <amy.phil...@army.mil>

Aloha LTC Alvarado,

Our organization hosts public community meetings on the 2nd and 4th Mondays of the month at the Kea'au Community Center from 6-8 PM.

We would like to invite you to come and make a presentation about PTA and respond to community concerns. Our proposed possible meeting dates for you are Monday Oct. 23rd or Nov. 13th.  If neither of these dates are good for you please propose a better date (2nd and 4th Mondays of the Month).

Some community concerns expressed about PTA include the following:

1.  What possible toxins are blowing in the dust, wind, and smoke off PTA from more than 75 years of bombing and shelling, including the use of Depleted Uranium (DU) radiation rounds at PTA?  It has been suggested that an independent authority install air filters 360 degrees surrounding the base at government expense to see what might be coming off the base.  What is your evaluation of PTA's lack of response to Hawaii County Council's resolution 639-08 passed in July 2008 by a vote of 8-1 calling on 8 actions to be taken by PTA.  (Copy enclosed with letter sent to PO Box 4607, Hilo HI 96720)

2.  There are growing concerns about spreading wildfires started at PTA from bombing and shelling.  Is PTA, located in the dry, windy center of Hawaii Island, our "Lahaina" fire waiting to happen?

3.  There are growing concerns, in light of Military Red Hill fuel contamination of the the aquifer on Oahu about toxins from PTA possibly contaminating the drinking water of Hawaii Island.  Were military toxins found in the two water wells drilled at PTA 10 years ago?  Were the water wells tested for a wide range of military toxins? Why aren't those wells being used by PTA instead of paying $2 million yearly to haul water to PTA?

4.  What are the military plans for clean up of all the Unexploded Ordnance (UXO) and other toxins on the entire 133,000- acres of PTA?  I note that maps of PTA say "All of PTA should be considered a Dud Hazard Area."

5.  It's been reported that less than half of PTA has been surveyed for cultural sites.  Why the delay in doing cultural surveys for the entire base?

6.  There are growing community concerns about not renewing or canceling the State lease of 23,000 acres for 65 years at a total cost of $1 and the rescinding of the US presidential executive order in 1964 that seized 84,000 acres of Hawaiian crown and government lands indefinitely for zero costs.

7.  What are the current number of live-rounds, and listing of all the various types of rounds, fired at PTA.  Is it 15 million, 20 million, 25 million?  The last figure I believe released about 20 years ago noted 14.8 million live rounds fired annually at PTA. What other rounds, besides live rounds, have been fired at PTA?

The above are just some of the concerns I have heard expressed in the community.  There will no doubt be many others, but these are starters.

We will be grateful for your attendance and addressing these questions and others in a mutually respectful gathering.  Mahalo.

Sincerely,

Jim Albertini, president of Malu 'Aina

cc: general public, elected officials, news media

10.  On page 11 of the 32 pages of the DLNR staff executive summary Discussion, it states: The final EIS does not "fully declare the environmental implications of the proposed action," and that the Board has not been given the "full range of responsible opinion on environmental effects."  It further states that this issue has been consistently raised since the first draft EIS.

I rest my case. Bombing and shelling desecrates cultural and historic sites at PTA.  Polluting the air, land, and water with deadly toxins is Desecration.  Make the military clean up its toxic mess and return the lands to the Hawaiian people.

Reject do not Accept the Pohakuloa Final EIS

Jim Albertini

5/6/25

-- 
Jim Albertini Malu 'Aina Center For Non-violent Education & Action P.O. Box 489 Ola'a (Kurtistown) Hawai'i 96760
Phone 808-966-7622 Email j...@malu-aina.org Visit us on the web at www.malu-aina.org