Dear Mr. Wilson;

Recently EnviroWatch began researching numerous issues relating to the lease and activities of the the Natural Energy Laboratory of Hawai’i Authority (NELHA) at Keahole Point, Hawai’i, and in particular the Ho’ona Historic Preserve. We noted that the Department of Land and Natural Resources handbook, "Sustaining Hawaii’s Resources for the Future" states: "Our goal is to promote a life-sustaining Hawai’i through the protection of our fragile environment, its natural resource base, and the function and viability of natural systems on which all life depends". It goes on to state that "Hawai’i must protect its ecosystem and manage its natural resources wisely in order that a strong foundation be maintained for future prosperity..... Now, more than ever, we need everyone’s help to sustain our irreplaceable natural resources for future generations."

In considering these statements, along with included statements regarding the "Historic Preservation Division" and "Aquaculture Development Program," we are questioning whether the State’s involvement with NELHA, its primary tenant, Cyanotech Corporation, and its other tenants, is not contrary to these goals. A number of ethical, environmental and social questions have been raised during our research and we would appreciate your consideration of these questions and any answers you can provide:

MANAGEMENT:

1. Is it a conflict of interest to have the DLNR manage both the commercial and environmental impact aspects of NELHA??

2. What sources of general and federal funds were used to develop the site?

3. Why did the DLNR give NELHA ownership jurisdiction over the historic preserve? Was this transfer authorized by Chapter 6E of the Hawai’i Revised Statutes? If not, what authority was used?

4. Why wasn’t the United States Fish and Wildlife Service consulted regarding the presence of endangered and protected water fowl found in the area?

5. Has the DLNR conducted any studies to evaluate the impacts of construction and research activities on historical sites, as well as marine mammals and other protected, endangered and threatened species at Ho’ona?

6. Did former State Senator Peter Ushijima, a member of the Board of Directors of Cyanotech, have any influence on the manner in which DLNR manages the area?

7. How are the people of Hawai’i compensated for the destruction of Conservation Lands at Keahole by NELHA and tenants, particularly Cyanotech? How much is the rent? How much of this is going to OHA for the use of Ceded Lands?

8. How much is the State of Hawaii paying for NELHA activities and to what level are we subsidizing Cyanotech and the other tenants.

HISTORIC CONSIDERATIONS:

9. Has the area, including the shoreline caves, been thoroughly surveyed? Are there ancient burials in the lava tubes and caves along the shoreline?

10. Were there burials at Keahole Point which were destroyed by the first pipeline laid by NELHA?

11. Were bones found? Where bones were found, did construction stop immediately as required by HRS Chapter 6?

12. Was the location of these burials known by NELHA prior to construction? If NELHA did not know of the burials at Keahole Point, and did not comply with HRS in response to finding burial sites, what measures have been taken to ensure additional burials will be known prior to their "accidental discovery" and that compliance with the statutes will be upheld throughout the massive construction of the Cyanotech’s ponds to prevent further destruction of burial sites?

THE WATER SUPPLY:

13. What is the normal salinity of the Keahole Point Aquifer? What is its sustainable yield?

14. How much fresh or brackish water is pumped out of the aquifer at Keahole by NELHA and its tenants, including Cyanotech? (average daily pumpage/mgd). How much is removed by other wells within that aquifier?

15. Does the total pumpage approach sustainable yield?

16. How much salt water from the ocean is returned to trenches after cooling Cyanotech’s ponds and serving the needs of other tenants? (Average mgd)

17. How much freshwater does Cyanotech use from the County of Hawaii? (average mgd) How much will they require when the present expansion is complete? What proportion of this will come from underground?

18. Is OTEC formally considered a dead project? If not, how can Cyanotech and OTEC coexist at Keahole?

19. If Cyanotech completes its expansion, more salt water will be needed. This means an additional trench will be needed. How will DLNR ensure that the next trench will not produce a similar ecological and historical/burial disaster?

DYNAMITING THE AREA:

20. How much dynamite is currently being used, per day, by Cyanotech to break through the pahoehoe rock from the lava flow of 1801?

21. What is the underlying structure of lava tubes under the region of Keahole Point occupied by NELHA and tenants.

22. How much seismic force does each charge generate? Is this enough to collapse lava tubes or produce cracks which run to the shoreline?

23. What is the status of the coral that was destroyed in 1979 when NELH first put in their pipeline? Has the area destroyed by the original pipeline trench ever recovered?

24. How was dynamiting and destruction of the area for additional construction justified when the agreement with the park curator stated that even weeds had to be carefully removed so that damage would not be inflicted on the underlying ground structure? The "Ho’ona Historic Preserve Curator’s Responsibilities", dated 12/20/95 and 12/29/95 states: "The Curator will keep the Ho’ona Historic Preserve area cleared of unwanted vegetation, debris and litter. This shall be done without ground disturbance, to prevent damage to the structural integrity of Ho’ona and to subsurface archaeological deposits. Weed-eaters, machetes and other hand tools must be used. Plants must not be pulled up by the roots as this can displace rocks and damage subsurface deposits."

MANAGING SUSTAINABILITY:

25. What species and environmental conditions (salinity, water table, nutrient levels, etc) were registered in the anchialine ponds at Ho’ona Preserve in 1985? What species were found in 1990? 1995? 1996? What factors do you think are responsible for any changes in species composition and environmental parameters?

26. What were the results of studies in the anchialine ponds by students visiting the historic preserve? What do the students think about the changes taking place?

27. Why is it that the DLNR Youth Conservation Corps was refused entry to NELHA during their visit to Keahole Point on July 27, 1997?

28. What is the DLNR YCC’s memory of their visit to Ho’ona Historic Preserve?

29. Which vision of sustainability do you want to emphasize for these young people - the one where coastal ecosystems and history are honored and preserved by State government, or the one where Conservation Lands are destroyed so that private aquaculture can profit?

30. Can these two visions coexist at Keahole Point? Do you think they should coexist within one agency or is the economic drive more appropriate with DBED&T which houses NELHA?

31. What is your vision of sustainability for Keahole Point?

We look forward to hearing from you regarding this matter. You may contact us by fax or phone at 623-4399, or at the above address.

Sincerely,

Carroll E. Cox

Investigative Reporter