Wednesday, February 25, 2009

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

The following are Hope Kallai's of Kauai comments on the Act 2 Pseudo-'EIS'. This letter is of comments regarding significant impacts on air and water quality:

23 February 2009

Hope Kallai

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

Michael Formby, Deputy Director
Hawaii Department of Transportation, Harbors Division,
79 S. Nimitz Highway,
Honolulu 96813
Fax: (808) 587-3652

RE: Comments on Draft Environmental Impact Statement
Large Capacity High Speed ROPAX ferry Alakai, Hawaii Superferry, Inc.
Significant impact to Air Quality resources
Significant impact to Water Quality

Aloha Director Kealoha and Deputy Director Formby:

Mahalo for the opportunity to comment of the preparation of the Draft Environmental Impact Statement (DEIS) on the Hawai`i Superferry, Inc. large capacity high-speed RO PAX ferry. Though I’ve written many comments on this project, I am still very confused on this process. This appears to be a programmatic environmental impact study (PEIS), considering state-wide impacts, yet Hawai`i Superferry, Inc. operations and vessels are discussed throughout the DEIS, including vessel-specific air emission impacts and marine mammal impacts determined on vessel type and speed, so my comments must refer to the Alakai and sister ship now known as Hull A616. If the projected start-up dates for Hull A616 have been changed, alterations must be included for the air emissions charts based upon 209 2009-2010 projected trips.

The Alakai currently burns marine diesel fuel with a sulfur content of 500 ppm. Cars and buses have become 97 percent cleaner in recent decades due to strict air quality standards. But fast ferries have become far, far dirtier due to increased fuel consumption associated with higher speeds combined with a lack of emissions regulations. Modern diesel fast ferries spew more dangerous pollutants into the air than either cars or transit buses – as much as 4 to 9 times more per passenger mile. Hawaiian Airlines is twice as fuel efficient as HSF at transporting people interisland because HSF burns 15 times the diesel that a Hawaiian Airplane (jet fuel) burns to cover the same route.

The pollution disparity between ferries and other modes has been documented by the Bluewater Network and confirmed by studies conducted by state and federal agencies, independent researchers and industry. See Bluewater’s “Air Pollution from Passenger Ferries in New York Harbor” (July 2003) and “Bay Area Transit Options Emissions Report” (July 1999) at on the Bluewater Network Organization Fast Ferry Campaign Page.

Exhaust from marine diesel engines contribute significantly to air pollution that damages the environment and harms public health. Exposure to diesel exhaust can cause coughing, tightness of the chest, bronchitis, reduces immune systems and can cause respiratory distress in people with asthma and allergies. Hawai`i has a high incidence of asthma; approximately 11.8 % of Hawaii’s children have asthma. Childhood asthma rates in Honolulu are much higher, where an estimated 13.3% or more than 27,000 children have asthma. In some parts of Honolulu, rates are estimated at more than 15 percent. Rates among native Hawai`ian adults are over 14%, higher in kupuna and those with other medical situations (like diabetes). The DEIS needs to consider the public health impact of marine diesel air pollution...

In 1998, the state of California categorized particulate matter from diesel exhaust as a cancer-causing toxic air contaminant responsible for 70% of excess cancers caused by air pollution.

The DEIS does not include any alternative choice in vessel design. Pollution impacts are determined by vessel design. Hawai`i does not need the largest aluminum vessels in the world. We do not need high speed travel throughout our whale nursery in the Hawaiian Islands Humpback Whale National Marine Sanctuary resulting in increased air pollution with particulate matter falling into the oceans.

The introduction of ultra-low sulfur diesel (ULSD) fuel has dramatically reduced emissions of sulfur oxides (SOx) from engines but at some loss of engine efficiency (as high as 2%). ULSD use is mandatory in California for ferry operators. Catalytic reduction (SCR) systems and diesel particulate filters (DPF) further reduce emissions. The people of Hawai`i do not need to be exposed to the health risks of usage of 500 ppm marine diesel for the next three years. The state of Hawai`i needs to mandate use of 15 ppm sulfur diesel by 2010, as recommended by the EPA, not by 2012.

The DEIS needs to consider the immediate usage of ULSD, weighing environmental impacts to one company’s financial operations determining irreversible pollution levels and potential public health risks. All air included in the DEIS emission charts should include ULSD alternatives.

According to the National Safety Council:
"One person using mass transit for an entire year, instead of driving to

work, can keep an average of 9.1 pounds of hydrocarbons, 62.5 pounds
of carbon monoxide, and 4.9 pounds of nitrogen oxides from being
discharged into the air."

The DEIS needs to include mass transit figures, not just compare to personal automobile usage. Ferry systems should be developed only if they can be operated cost-effectively and without causing more environmental harm than cleaner public transit modes. Putting drivers in ferries increases, rather than decreases, air and water pollution, and does not alleviate traffic congestion in the long-term.

Cleaner fuels combined with engine and exhaust treatments should be required to reduce air emissions. Use of ultra-low sulfur highway diesel, selective catalytic reduction, and particulate matter traps can reduce harmful air emissions by as much as 90 percent.

Alternative energies should have been considered: hybrid systems, biodiesel, solar/wind energy and fuel cells. Biodiesel significantly reduces all pollutants, except NOx, which can be reduced through use of additives and control technologies such as water injection, SCR, oxidation catalyst. High speed ferries can generate low emissions, helping to protect air quality, public health and the global environment, while reducing dependence on fossil fuels. These engineering modifications should be considered in the DEIS.

A round-trip flight from Lihu`e to Honolulu emits 264 pounds of per passenger into the air (via atmosfair: The DEIS forecasts 363,000 HSF passengers in 2010. Total GHGs are estimated at 96,600 short tons). A round trip flight would emit 48,000 short tons, or ½ the emissions of HSF per passenger.

The impacts of this project significantly impact statewide air quality, global greenhouse gasses and global climate change and must be seriously considered. Please correct the DEIS with correct projected startup and trip estimates for the second ferry. The DEIS needs to consider immediate usage of ULSD fuel.

The DEIS needs to consider public health risks to target populations from marine diesel emissions of this project as well as possible acid rain impacts on the ocean.

Thank you for addressing my concerns in the DEIS.


Hope Kallai

No comments: