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University of Hawaii at Ma.noa. Environmental CenterMaile. Bldg. 10. 2540 Maile Way

Honolulu, HawaU 96822Telephone (606) 946·7361

Ollla. of the DINotor

July 11, 1975

Mr. R. L. O'Connell, DirectorEnforcement Divisionu.s. Environmental Protection Agency100 California StreetSan Francisco, California 94111

Dear Mr. O'Connell:

We have received for review the revised Dredge Spoil Disposal Criter'la­Revision I, pertaining to the proposed site changes for dredged material disposalsites in Hawaiian waters. We were pleased to note your attention to many of ourearlier recommendations (January 13, 1975) concerning modifications to thepreviously proposed Hawaiian waters disposal sites.

Members of the University of Hawaii who contributed to the earlier review andwho are presently on campus have been 'contacted for their evaluation of thecurrently proposed changes in site locations. The following comments have beenprepared with the assistance of:

D. C. Cox, Environmental CenterH. Gee, Water Resources Res. Ctr.R. Grigg, Hawaii Inst. of Marine BiologyJ. Miller, Environmental CenterM. Morganstein, Oceanography

In general we are in agreement with the proposed new site locations. However.we would appreciate clarification of the following points:

We note that the proposed sites carry a number system i.e. Hon 1, Han 2,Hon 3, etc. We similarly note from your earlier documentation (10/21/74) thatcertain existing dredge spoil disposal sites carry numbers Han 1. through Hon 3.If this number system is meaningful beyond the present correspondence thenattention should be directed toward eliminating the ambiguity of similar numbersfor the 3 existing disposal sites as compared to the first 3 new sites.

,-

Mr. R. L. O'Connell 2 July 11. 1975

Proposed Sites

Hon 1. Kauai -Nawil iwili 21 0.. 55' N, 159 0 .11'

Hon 2. Kauai-Hanapepe. 21 0 SOIN, 159°Q2.1~ ~ /Jic,-j)-t.,u-:>

These sites were previously approved in our review and we have no additionalcOl11l1ents.

Hon 3. Oahu-Honolulu and Pearl Harbor 21° 13'N, 157 0 56 1 05"W

The proposed new location for this site will increase the distance offshorefrom 3.3 to 5.3 nautical miles. The depth will be increased to 280 fathoms, only30 fathoms over the previously proposed site. Since there is already an existingdredge spoil disposal site in this vicinity at 21° 14'N and 157° 54 1W(Han 1. onthe Dredge Spoil Disposal Site document of 10/21/74) we do not see the need forthis additional site.

Hon 4. Molokai-Kalaupapa Harbor 21° 18' 24"N, 1560 59' 48"W

The proposed new location for this site will increase the distance offshorefrom 3.1 to 5.3 nautical miles and the depth from 350 to 1000 fathoms. Recentobservations on the northeastern tip of Molokai at 200 fth. by R. Grigg fromStar II have shown the shrimp resources in this area to be too sparse to be ofcommercial value. Hence the original dredge spoil site at 21 0 15 1 OON, 157 0 02' OO"Wseems reasonable. Please note correct spelling of Kalaupapa and Molokai.

Hon 5. Molokai-Kaunakakai Harbor 21 0 01' 30"N, 1570 09' 24"W

We had previously recommended that this site be situated in water of atleast 290 fathoms so as to avoid possible damage to a known black coral area.This new site will probably be satisfactory.

Hon 6. Lanai-Manele 20 0 37 1 OO"N, 156 0 57 1 48"W

The proposed new disposal site, Hon 6., for Lanai-Manele is indicated asat a depth of 300 fathoms. We wonder about the rationale for the selection of asite off Manele Bay? This site is very close to a volcanic pinnacle lying at adepth of 167 fathoms (20 0 36 1Nand 156 0 59 I W). This pinnacle provides a uniqueIlabitat for Bamboo and gold coral. The protection and preservation of such aunique feature and its accompanying biota should be seriously considered. Thepotential dispersal of discharge material due to currents or slight errors indisposal site location could destroy this unique habitat. We strongly urge youronsideration of an alternate disposal site off the commercial harbor of Kaullialapau

on the west side of Lanai. The depth at approximately 5 miles westof Kaumalapauappears to be about 350 fathoms. The distance from Manele Bay to a disposal sitehere would not be greater than that to the proposed site. On the basis of dredgehauls in similar location it seems improbable that precious corals are present atthe site off Kaumalapau.

Hon 7. Maui-Kahului Harbor 21 0 04' 42"N, 156 0 28 1 48"W

The latitude and longitude given for this site place the site at a slightlyshallower depth than the 200 fathoms indicated. Commercial shrimp and crab

Mr. R. L. O'Connell 3 July 11, 1975

fisheries are known to exist in this general area. Extending the site approxilMte1yan additional 3° N latitutde .to 21 0 07' 42 11 N. would assure its depth in 200 fathoms.Unfortunately, our origjnal concern as to harm to existing shrimp and crab fishel';asseems still quite valid.

Hon 8. Kawaihae Har'bor 20 0 02 1 OOIlN, 1560 00' OOIlW

The latitude and longitude given place this site in approximately 250 fatlltJlllsnot 300 as indicated. Our previously stated concerns regarding black, gold, andpink coral areas at the site remain valid. Coral reef,s which occur within theKilwa1hfle Bay and along the whole west coast of the Kawaihae area are the 111 w(~l1

developed and pristine reefs in the Hawaiian islands. Their preservation should hegiven the highest priority. Disposal sites would be as far removed as possibl~.

Recreational use of this entire area for bottom fishing. trolling and marlin fish~ng

is of great value and importance to tho people of Hawaii. A disposal s1L~ in "lidarea is not recommended due to the great potential for severe negative envirorllllclltalimpact. An alternative site 02' farther north at 20° 04' OOIlN latitude would beroughly the same distance from Kawaihae Harbor but would lie in'330 fathoms. Thepotential negative impact should be somewhat reduced at this greater depth.

Hon 9. Hawaii-Hilo Harbor 19° 46 1 OOIlN, 154 0 55 1 42 11 W

The proposed new location will be satisfactory.

We appreciate the opportunity to have reviewed these proposed dredge spoilsites. Please keep us informed of any action taken in these matters.

Yours very truly,

J~ ~ e'v/MPDoak C. CoxDirector

cc: Col. F. M. Pender, Corps of Engr.H, GeeR, GriggJ • MillerM, Morganstein

bee: A. H. BannerL. S. LauJ. MaragosJ. Rutka