PROTECT OUR MOANA

CLICK TO SUBMIT COMMENTS HERE FOR THE HAWAI'I-CALIFORNIA DRAFT ENVIRONMENTAL IMPACT STATEMENT/OVERSEAS ENVIRONMENTAL IMPACT STATEMENT

2/9/25 UPDATE: If the online submission is giving you problems email your issue to orlando.milanamaya@mantech.com and attach your testimony.

2/10/25 Update: If email not working mail your comments into:

Naval Facilities Engineering Systems Command Pacific
Attention: HCTT EIS/OEIS Project Manager
258 Makalapa Drive, Suite 100
Pearl Harbor, HI 96860-3134

Comments must be postmarked or received online no later than 11:59 p.m. HST on Feb. 11, 2025, for consideration in the Final EIS/OEIS.

DEADLINE TUESDAY, FEBRUARY 11, 2025

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DEADLINE TUESDAY, FEBRUARY 11, 2025 〰️

DRAFT TESTIMONY

COPY AND PASTE

Table of Contents:

1. Introduction

2. No Action Alternative is Misrepresented

3. Endangered Species & Marine Mammals

4. Expansion of Military Activities

5. Lack of Consultation with Kanaka Maoli

6. Cumulative and Global Impacts

7. Climate Change and Coral Reefs

8. Navy Ocean Pollutants

9. Conclusion

Sources for data in draft comments can be found at:  https://www.nepa.navy.mil/hctteis/ https://s3.amazonaws.com/media.fisheries.noaa.gov/2024-12/Navy-HCTT-2025LOA-App-OPR1.pdf

Introduction

To Whom It May Concern,

I am submitting this testimony on behalf of myself, as well as in solidarity with Native Hawaiians, environmentalists, water protectors, and all who care deeply about the health of our oceans, the protection of marine life, and the preservation of cultural and sacred practices tied to the moana (ocean). I am deeply concerned about the inadequacies and misleading statements in the Draft Environmental Impact Statement (EIS) and Overseas Environmental Impact Statement (OEIS) for the Hawaii-California Training and Testing (HCTT) activities.

Here is an outline of some of the issues in the documents, hereafter called the EIS or OEIS. It is not comprehensive, because despite regulations that the maximum size of an EIS is 300 pages, this document is 4 volumes long with the first volume alone being over 700 pages. It is a blatant violation of the regulation and makes the document unreadable to community members, but here are some highlights.

The No Action Alternative is Misrepresented

Under § 1502.14, the alternatives section is the heart of the EIS. The No Action Alternative, where the Navy stops military testing and training activities in our waters, is described in the document as resulting in conditions “unchanged or slightly improved from baseline conditions.” This is a gross misrepresentation. The No Action Alternative should be evaluated based on the BENEFITS of stopping harmful military activities, not just the absence of harm. Currently the NAVY is running 7,432 activities per year under this EIS in Hawaii alone, according to tables G-16 and G-17.

For example:

Endangered Species Recovery: If endangered birds, Hawaiian monk seals, humpback whales, and green sea turtles are not subjected to thousands of harmful interactions with the Navy each year, they have a far greater chance of recovery. The Hawaiian monk seal, with only 1,600 individuals remaining, is highly sensitive to disturbances. In a 7 year period, they would avoid 9,228 instances of harm from the NAVY. Humpback whales, which migrate through Hawaiian waters annually, and green sea turtles, which depend on nearshore habitats, are also at risk with thousands of harmful interactions (see below). Stopping military activities would allow these species to thrive.

Cultural and Community Benefits: For Kanaka Maoli (Native Hawaiians), the ocean creatures are not just a resource but a relative, as described in the Kumulipo. Constant harm to marine life and intrusions on cultural practices, such as fishing and traditional ceremonies, have profound spiritual and community impacts. Ending military activities would restore the ability of Native Hawaiians to malama ocean relatives and practice cultural traditions.

Reef and Ocean Health: Coral reefs, already under immense stress from climate change, would have a chance to recover if not constantly harmed by Navy activities. Healthy reefs support subsistence fishing, wildlife, and the overall health of our oceans, which produce over 50% of the Earth’s oxygen and absorb 30% of global CO2 emissions.

The No Action Alternative should be re-evaluated to reflect these significant benefits, not dismissed as “unchanged or slightly improved.”

Endangered Species & Marine Mammal Harm

We are in a mass extinction event, and Hawaii is one of the epicenters as one of the most biologically diverse places in the world. The NAVY has applied to the government to be allowed to “take” via acoustic or explosive sources, 33.7 million instances of harm to marine mammals in the training area in 7 years. Despite this, the NAVY concludes that their impact on marine mammals is not significant or can be mitigated through their operational procedures.

This includes, in 7 years from NAVY alone:

52,470 “takes” on kohola, humpback whales, including 19,028 in Hawaii alone

9,228 “takes on endangered 'īlio holo i ka uaua, Hawaiian Monk Seals

349,184 “takes” on bottlenose dolphins in Hawaiian waters alone

982 “takes” on endangered False Killer Whales in Hawaii waters, and 25,700 on all false killer whale populations in Hawaii (not all populations are endangered)

63,569 “takes” on spinner dolphins in Hawaiian waters alone

93,784 “takes” on threatened or endangered blue and fin whales across the pacific

These are arguably significant adverse effects to endangered and threatened species, as well as to those who are not listed but are still valuable relatives of our communities. Some of these “takes” are also happening in unique and ecologically critical areas, such as Papahanaumokuakea Marine National Monument and offshore at Kaula Island.

These areas are also home to endangered birds such as ʻAkeʻake (Band rumped storm petrel), Uaʻu (Hawaiian petrel), Aʻo (Newell Shearwater). Regular disturbances for training and testing have and will increase disruption for the protected birds for generations, the impacts are likely significant. Despite receiving testimony about it previously, the NAVY did not discuss the abandonment of eggs when startled as one of the impacts of their exercises. This needs to be included, as well as the impacts on the birds being subject to disruptions in all stages of life across generations.

For a discussion of the harm the NAVY does to honu (turtle) that is not addressed adequately in this OEIS, see “Navy Ocean Pollutants and Their Environmental Impact.”

Impacts on endangered species and marine mammals are discounted in the OEIS in completely inappropriate ways and need to be reevaluated for their significance determination under paragraphs (d)(vi) and (d)(ii).

Expansion of Military Activities

In Hawaii waters under this OEIS, the NAVY is currently conducting 7,432 activities annually. Under Alternative 1, they want to increase that by 43% to 10,641 activities annually. Under Alternative 2, they want to increase it by 49% to 11,104 activities. (Tables G-16 and G-17). 24%, or 1,812, of current activities happen in the near shore, at 0-3 Nautical Miles (nm). This includes almost all of the mine warfare testing and training. This is where our reefs are, and where honu feed and pull out to rest. Under Alternative 2, that would increase to 2,708 activities annually. This is unacceptable, and there's no way that it has an insignificant long term impact.

The website states that “Nearshore areas, such as Kaneohe Bay or Marine Corps Training Area Bellows, are proposed to be used more frequently or for new training or testing activities, such as mine warfare training.”

On Oahu this includes Naval Defense Sea Area, Puuloa Underwater Range, Ewa Beach Training Minefield, Barbers Point Underwater Range, Barbers Point Harbor to Lighthouse Training Area (potential), Kaneohe Bay (potential), Bellows Beach (potential).

On Maui it includes Kahoolawe Sub Training Minefield, Penguin Bank, Pailolo Channel, Maui Basin, Alalakeiki Channel, and Kalohi Channel.

On Kauai it includes the PMRF Training Area (potential), Waiapuaa Beach (potential), and Niihau Kingfisher Range.

The use of active sonar, underwater explosives, and live-fire exercises will have devastating impacts on marine life, including marine mammals, endangered birds, and coral reefs.
communities. Some of these “takes” are also happening in unique and ecologically critical areas, such as Papahanaumokuakea Marine National Monument and offshore at Kaula Island.

Lack of Consultation with Kanaka Maoli

When considering a significance determination under paragraphs (d)(vii) and (d)(ii), the EIS does not significantly account for tribal sacred sites or the degree to which the action may adversely affect communities with environmental concerns. As many comments during the public scoping meetings reflected, the NAVY has a profound misunderstanding and misalignment with the Native Hawaiian community on their abuse of sacred spaces, relationship with aina and moana. The EIS and presentations demonstrated a profound lack of consultation with Kanaka Maoli and a failure to understand the significance of marine life to Native Hawaiian culture and values. The ocean is not just a resource to be sacrificed for “military readiness”—it is a sacred space that sustains life, culture, and spirituality. The Navy’s activities disrupt traditional practices, such as fishing, navigation, and ceremonies, and violate the rights of Native Hawaiians to care for and protect their ancestral waters.

The Navy must engage in meaningful consultation with Kanaka Maoli and incorporate their knowledge and values into the decision-making process. This includes recognizing the cultural significance of marine mammals, reefs, and other ocean resources and ensuring that military activities do not infringe on Native Hawaiian rights.

Cumulative and Global Impacts

The EIS/OEIS fails to adequately address the cumulative and global impacts of military activities. It regularly dismisses NAVY impacts as insignificant to the scale of the global issue, but that argument is a classic example of the fallacy of trivialization. The NAVY and US armed services consistently use this argument in EISs to avoid responsibility for climate impacts. This argument is not acceptable, particularly when talking about ocean impacts. The EIS needs to be rewritten to accurately account for this harm without dismissing it.

The oceans are Earth’s lungs, producing over 50% of the planet’s oxygen and absorbing 30% of global CO2 emissions. Billions of people rely on healthy oceans for food, livelihoods, and cultural practices. Military expansion threatens this delicate balance, prioritizing war over the health of the planet.

Additionally, prior pollution of chemicals being dumped into the ocean like DDT barrels persist in the environment, accumulate in marine life, and exacerbates the harm caused by military activities.

Additionally, the proposed operations in Hawaii are taking place on Hawaiian Kingdom waters. The US military has no right to be here in the first place, as it is illegally occupying the Hawaiian Kingdom and has no treaty with the Hawaiian Kingdom to use the waters for this purpose. It is a dangerous erosion of international norms for the US to be doing military operations in Hawaii without a treaty.

Increasing military operations also decreases the safety of the world at large. This perspective is not considered at all in the EIS.

This OEIS also includes increasing international exercises. Militaries participating in previous exercises, including Israel and Indonesia in the 2024 RIMPAC war games, are actively breaking international law by committing genocide. This has substantial normalization impacts on the global community, that rogue states are allowed to participate in US led training, degrading the value of international law and making everyone less safe. These impacts also need to be considered.

Climate Change and Coral Reefs

The EIS/OEIS must address the intersection of military activities and climate change. Coral reefs are already under immense stress from rising ocean temperatures, acidification, and pollution. The use of explosives, sonar, and other military stressors will further harm these critical ecosystems, which are essential for biodiversity, coastal protection, and cultural practices.

24%, or 1,812, of current activities happen in the near shore, at 0-3 Nautical Miles (nm). This includes almost all of the mine warfare testing and training. This is where our reefs are, and where honu feed and pull out to rest. Under Alternative 2, that would increase to 2,708 activities annually. This is unacceptable, and there's no way that it has an insignificant long term impact. Placing and moving the targets for the mine activities, exploding ordinance, laying and relaying cable, and many other listed activities will disturb these ecosystems that are heavily disrupted by ongoing military use and other stressors, and therefore at higher risk.

The Navy must take responsibility for its role in exacerbating climate change and prioritize the protection of coral reefs and other marine ecosystems.

Navy Ocean Pollutants and Their Environmental Impact

The Navy’s Overseas Environmental Impact Statement (OEIS) downplays its role in major ocean pollution events, shifting responsibility to municipalities and industry. Unmentioned in the report are three major Navy pollution events in Hawaiian waters. The 5-million-gallon underground oil plume beneath Joint Base Pearl Harbor-Hickam, resulting from decades of Navy fuel storage failures, is described by the Navy as a "historical release of petroleum products" rather than an ongoing contamination crisis. Similarly, the recent 1.89-million-gallon wastewater spill into the ocean near Pearl Harbor is attributed to "heavy rains damaging a transformer," ignoring the Navy’s history of regulatory violations, including a $9 million fine for prior infractions. Also not considered are the implications of the jet fuel leaks at Red Hill, which can affect the ocean quality because the underground aquifers and water sources are connected to the ocean. These recurring pollution events violate federal and state environmental standards and threaten Hawaii’s fragile marine ecosystems.

The OEIS fails to adequately assess the long-term ocean impacts of these spills, particularly their effect on endangered species. Research from the University of Hawaiʻi and NOAA links nitrogen pollution from wastewater to the proliferation of invasive algae, which elevates arginine levels and fuels fibropapillomatosis (FP), a tumor-causing disease devastating Hawaii’s green sea turtles. NOAA has credited this as the leading cause of death in endangered green sea turtles. By neglecting the full context and intensity of these impacts, the Navy’s OEIS does not meet the standard for significance determination and fails to acknowledge the long-term harm posed to Hawaii’s marine life.

Conclusion

The Draft EIS/OEIS for the Hawaii-California Training and Testing activities fails to adequately address the significant and substantive concerns of Native Hawaiians, environmentalists, and water protectors. By neglecting the full context and intensity of these impacts, the Navy’s OEIS does not meet the standard for significance determination and fails to acknowledge the long-term harm posed to Hawaii’s marine life and people. Additionally, the No Action Alternative must be re-evaluated to reflect the benefits of stopping harmful military activities, and the Navy must prioritize the protection of marine life, cultural practices, and the health of the oceans over military readiness.

The US military, and itʻs destruction of people and the environment, is the largest ongoing threat to Hawai‘i for decades. This report is another instance of that threat and real, ongoing damage to Hawaii and her people, being dismissed as insignificant when it is actually extremely significant.

The health of our communities and our oceans, the survival of endangered species, and the rights of Native Hawaiians depend on the people holding the Navy accountable as they attempt to deceive and mislead us about the harm they do. We will hold you accountable. Stop prioritizing war over the planet’s health and choose a path that honors and PROTECTS OUR MOANA and all who depend on it.