A quick review of the letters commenting on the most recent draft environmental impact statement for taking koa from some 12,000 acres of forest north of Hilo discloses some of the more serious concerns that David S. DeLuz Jr. and his partner, Kyle Dong, will need to address if the project is to move forward:
Endangered species. Loyal Mehrhoff, director of the Pacific Island Ecosystems Research Center of the U.S. Geological Survey’s Biological Resources Division, noted that the DEIS mentioned one species of Hawaiian picture-wing fly listed as endangered, but does not address the fact that at least two other species might occur in the area. Mehrhoff pointed out that two rare damselflies might also be in the area. “It is also unclear how controlling strawberry guava in areas immediately around harvested trees is going to significantly enhance native plant survival in the overall forest,” he wrote. Dong and DeLuz have maintained that, by controlling strawberry guava, their forest management plan will actually protect the native forest they are proposing to log.
Patrick Leonard, field supervisor of the Fish and Wildlife Service’s Pacific Islands office, said two endangered plants, five bird species, and one mammal, the Hawaiian hoary bat, are likely found within the area to be logged. Leonard suggested the applicants would need an incidental take permit before their logging plan could be implemented.
Economic viability: Hawai`i County planning director Chris Yuen wrote, “The koa resource is the only economic incentive to fund forest improvement. If it is removed without reforestation being successfully implemented, there will not be a second chance to do it right. Koa removal should not be allowed at a pace where the economically valuable resource will be gone before restoration has been successfully accomplished.”
Also, Yuen wrote, the original plan called for harvesting “dead or dieback trees,” those with less than 20 percent live crown, a 100-year rotation, and third-party certification of sustainability. “The current application appears to call for the harvesting of most of the koa trees on the property within a very short period, less than ten years, and apparently does not include third-party certification,” he wrote. “The long-term commitments of the applicant should be secured by a bond or some other method so that the permittee cannot just cut trees, make money, and leave before restoration has been accomplished.”
The DLNR’s Division of Forestry and Wildlife voiced skepticism about the very basis for the aggressive logging plans. The DEIS, wrote DOFAW administrator Paul Conry, “has inadequately covered the division’s prior stated concerns regarding their timber cruse, stand, and stocking tables, koa regeneration and weed control monitoring, a general harvesting schedule, a clear discussion of how harvest versus leave-tree selection will be conducted, clear and credible budget analyses, among others. Many of the division’s previous concerns were not addressed at all. The enormously complex and untested scope of the proposed project is repesented in the subject draft EIS document in a manner that is often disorganized, incomplete, and in some cases directly conflicting.” The timber data in the current draft EIS “are based almost entirely on educated guesses,” Conry wrote.
Dick Wass, manager of the Fish and Wildlife Service’s Hakalau Forest National Wildlife Refuge, struck a similar chord. “We are concerned,” he wrote, “that the koa harvest will produce less than the projected income, which, in turn, could cause the owner to reduce or abandon the expensive weed control and forest restoration objectives.” Wass then quoted a passage from the DEIS, which stated, “operational costs to institute sound forest management practices and ecological measures cannot exceed or affect profit levels to the point where the plan would be rendered infeasible.” “Under this scenario,” Wass wrote, “the koa trees will be removed and the landowner makes a profit. However, invasive weed populations will increase and the native forest ends up in poorer condition than if the project was never permitted.”
Inappropriate restoration. Julie S. Denslow, a botanist with the U.S. Forest Service’s Institute of Pacific Islands Forestry, criticized the proposal in the management plan to control invasive species for no more than two years in the vicinity of logged areas. “While this action may provide koa seedlings with improved early establishment conditions,” she wrote, “it will not halt the spread of shade-tolerant invasive species… There is no evidence that such action will improve the health of the forest and a high risk that it will contribute to increasing the density of exotics. Canopy disturbance and human traffic will also facilitate the spread of Miconia calvescens; the site is within the potential habitat range of Miconia and the Hamakua Coast above Hilo supports high populations of this bird-dispersed and highly dangerous species.”
General confusion. The OCCL comment on the draft EIS, contained in Lemmo’s letter to Dong, lists numerous problems with the document – everything from sloppy proofreading and abundant typographical errors to illegible and poorly reproduced appendices, duplicated appendices, and confusing pagination. “The DEIS seems to raise more questions than it answers [and] … does not provide a full disclosure of the proposed project.” Information is presented piecemeal and is “often disorganized, incomplete, and conflicting…. Critical elements regarding the proposed project appear to be lacking in the body of the EIS…”
Although professional planning firms had been involved in preparation of earlier disclosure documents (PlanPacific, Wilson Okamoto & Associates, and others), the most recent DEIS was attributed to Wade Lee, a biologist who also prepared the very first draft environmental assessment, in 2001, and Mark D. Hee, formerly a stock broker with Morgan Stanley who has been involved with Dong in several ventures and who once owned a koa furniture business. Lee told Environment Hawai`i he did not have a hand in writing the latest DEIS; those who did were DeLuz, Hee, and Dong, he said. Sidney Fuke, an environmental planner and former planning director for the County of Hawai`i, is revising the document in light of comments received, Lee said.
— Patricia Tummons
Volume 18, Number 1 July 2007
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