UH Environmental Center Review ATST Supplemental DEIS

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 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.


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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