After the September 1 hearing before the Hawaiʻi County Council’s Committee on Legislative Approvals and Acquisitions, consultant to Waikoloa Green John Pipan wasted no time in revising its water demand. He obtained a new will-serve letter from Hawaiʻi Water Service, bearing the same date as the council committee hearing (September 1), that reduced the total projected daily demand to 362,000 gallons a day, a reduction of 72 percent from the 1.29 mgd originally proposed for the project.
The largest savings came in the category of the 10-acre lots. The earlier will-serve letter estimated that 26 10-acre lots would potentially be developed at a density of five units per lot, for as many as 130 housing units. Each unit was projected to consume 6,000 gallons a day, for a total allocation of 780,000 gpd. The new will-serve letter projects that the 10-acre lots will have just 25 units, each with a water demand of 600 gallons a day.
Pipan included the new will-serve letter in a 22-page filing submitted to the council September 14, one day before the scheduled hearing of the Legislative Approvals and Acquisitions Committee. In the covering letter, he suggests that “public comment has combined several different figures (the state’s adopted sustainable-yield planning benchmark for the aquifer, aquifer-wide reported pumpage, Hawaiʻi Water Service’s own system demand, and Waikoloa Green’s ultimate project demand.)” The documents he was forwarding were “meant to help the Council sort those figures out.”
“The 362,000 gpd figure is itself a conservative, unadjusted planning ceiling,” Pipan writes. A proposed “water conservation plan commits the project to water-efficiency and conservation practices consistent with the U.S. EPA’s WaterSense Specification for Homes, enforced through HOA conditions binding on all residential units.” This, he suggests, would further reduce by roughly 30 percent the 362,000 gpd planning figure.
In addition, he states that Waikoloa Green “will seek to use reclaimed and non-potable sources for its own irrigation needs,” similar to the way HWS incorporates those sources into its distribution system. He acknowledges that this is more hope than fact: “The creative relationship between those sources and future system operations can continue to be evaluated with HWS and CWRM as development proceeds,” he writes.
Pipan claims that the Water Commission “is considering combining the Waimea and ʻAnaehoʻomalu aquifer system areas,” and as the source for this statement, he refers to CWRM’s “FY2025 report to the Legislature (published 2026),” which “lists continued study of these boundaries and yield estimates as an ongoing objective.” What he is likely referring to is the Act 100 report submitted by the Department of Land and Natural Resources on agency goals and objectives. Year after year, since 2019, this required report has included as a goal to “continue to study and refine hydrologic unit boundaries … and estimates of ground water sustainable yields and surface water IFS [instream flow standards] (ongoing).” The boundary between ʻAnaehoʻomalu/Waimea is one of the boundaries listed.
Pipan then refers to past discussions, the most recent in 2019, about altering the 16 mgd sustainable yield of the Waimea aquifer. None of those discussions resulted in any CWRM action.
In any case, Pipan says, the concern over hitting or exceeding 90 percent use of the sustainable yield is a “state regulatory consideration,” having nothing to do with the county and its zoning authority. “Nearing the 90 percent level may reinvigorate the broader discussion around refining the aquifer’s boundaries … a process unrelated to whether this project is approved,” he writes, going on to say that under the Hawaiʻi Supreme Court’s Kauaʻi Springs decision, placing on all governmental agencies, at every level, the obligation to protect public trust resources, the county has satisfied its obligations.
In a section titled “Waikoloa Green: The Water Facts,” Pipan repeats the statement that the revised water use is now 362,000 gallons per day, describing the earlier estimate of 1.29 mgd as a figure “used in opposition commentary.”
— Patricia Tummons
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