Hope Kallai's comments on the Act 2 Pseudo-'EIS' (1)

The following are Hope Kallai's of Kauai comments on the Act 2 Pseudo-'EIS'. Hope probably spent more time on this than anyone I know. I think she did at least 4 and maybe more letters on this, each of different in-depth substance. Will start with the first letter:

19 February 2009

Hope Kallai
Address
Email

Katherine Puana Kealoha, Director
Hawaii Office of Environmental Quality Control
235 S. Beretania St., Suite 702
Honolulu 96813
fax: (808) 586-4186

cc: Mike Formby, Director DOT-Harbors

RE: Request for preparation of Supplemental EIS Hawaii Superferry

I am hereby requesting the preparation of a Supplemental Environmental Impact Statement on the large capacity, high-speed wave-piercing catamaran known as the Hawaii Superferry Inc. (HSF) project, due to significant changes in the project, as proposed. The original proposal supports harbor improvements (including ramps) and related impacts of large-capacity RO/RO PAX ferry travelling between the main Hawai`ian Islands of Kaua`i, `Oahu, Maui and Hawai`i Island. In the DEIS, it states ramps will be used, that all wastewater will be hauled away daily from the ship while docked in Honolulu Harbor. Water tanks will be filled daily from the dockside water supply. Rubbish is scheduled to be separated for recycling.

In Proposal to United States Department of Defense for the outfit of National Defense Features (NDF) on Hawaii Superferry’s High Speed Catamaran “A616” Now Building at Austal USA, by Hawaii Superferry, Inc., dated March 11, 2008, HSF requests approximately $5 million federal funding for three modifications on the second ferry being built for the operational autonomy and self-sustainability requirements of the mission objectives of military authorities. At that point in time (March, 2008), the second hull, A616, was about 50% completed at the Austal shipyard in Mobile, Alabama. Proposed refits included:
1. Stern-mounted folding ramp system
2. Reverse osmosis desalination seawater plant
3. Wastewater treatment and disposal system (15,000 gallons/day)

The modifications will add 20-23 feet to the overall hull length of the ship and an additional 60 tons and require some structural alterations. The ramp system, with the desalination and wastewater plant, will have complete independence from shore-side support.

According to the proposal, vehicle load capabilities are expected to be similar to the Alakai except the new ship A616 will have slightly larger vehicle decks (4000 square feet each) which can accommodate a different range of loads:

· 38 Stryker-type vehicles on main deck (with more room above and below)
· 14 MRAP III vehicles in the center section of main deck with 20 lighter vehicles outboard
· 7 or 8 up to 50 feet long rigs in the center section with space outboard

Or 230 regular cars. After Hull 616 starts business, HSF may retrofit the Alakai with the similar features, with minimal impact expected to the vessel’s commercial service.

These alterations are significant and must be considered through the Supplemental EIS process for both the new hull, A616, and the retrofit of the Alakai. There are different impacts that must be discussed. These alterations, if performed with federal funding, should be considered under NEPA and ESA.

There have been changes to the anticipated startup/delivery time of the second Superferry that also merit preparation of a SEIS.

In the October 28, 2008 issue of Marine Log, headlines state “Hawaii Superferry to delay deployment of second vessel - Hawaii Superferry today said that it is postponing the introduction of its second ship and start of service to the Big Island for approximately one year. The company anticipates the financial and economic climate will by then be more conducive to starting the new route.

The second of Hawaii Superferry's two 113 m catamarans was launched at Austal USA's Mobile, Alabama, shipyard in Sept. 2008. The company is expecting to take delivery of it in Mobile in late February 2009 and says it "will look at short-term opportunities for use of the ship prior to its induction into service in the islands."

“Postponing the introduction of our second ship will defer over $10 million in start-up costs and enable us to maintain our sound financial position” said Superferry President and CEO Tom Fargo.

This deference of $10 million in start up costs needs to be explained. Will it be deferred from HSF to the state of Hawai`i, like the ramp costs? Where will this ship be before coming to Hawai`i? What will it be used for?

Many alterations of the original project proposal and additional significant impacts must be considered in a SEIS. Thank you in advance for requesting preparation of a SEIS for this project ASAP.

Mahalo for your time and consideration,

Hope Kallai

MarineLog photo included with this comment letter from Hope Kallai