Stop the U.S Navy Bombing of Kaʻula Island
Kaʻula Island is around 20 miles west of Niʻihau. Kaʻula Island is designated as a state seabird sanctuary, providing a nesting ground for migratory birds. Hawaiian monk seals, sea turtles, and humpback whales can also be spotted along the shoreline.
The U.S. Navy just released a draft environmental assessment (EA) proposing to increase the number of bombing exercises on Kaʻula Island. Please weigh during the public comment period by Sept. 30th at 11:59 P.M.
If approved, bombs would be dropped more than 30 times every year.
About Kaʻula & Military Presence to Date:
Kaʻula Island is around 20 miles west of Niʻihau. Kaʻula Island is designated as a state seabird sanctuary, providing a nesting ground for migratory birds. Hawaiian monk seals, sea turtles, and humpback whales can also be spotted along the shoreline.
The first admitted bombing by the Navy was in 1952. However, no records show the territorial government, Congress or the President ever granted approval for the destruction.
Kauaʻi residents have been speaking up against the bombings and senseless killing of seabirds since the start.
And because the islands are so close - at night Kauaʻi residents saw the destruction first hand.
The bombing also made headlines in 1965, when military pilots accidentally dropped eight 250 pound bombs on Niʻihau that were meant for Kaʻula.
Concerns with the Current Environmental Assessment (EA)
An environmental assessment (EA) is done to determine whether or not an action is a "major federal action significantly affecting the quality of the human environment. … The EA leads either to the decision to do an EIS or to a Finding of No Significant Impact (FONSI)."
According to the Navy’s draft EA document the Navy is yet again assuring the public that increased bombing on 113 acres of Kaʻula Island will have “minimal” effects on the environment.
According to the Navy - damage to vegetation and wildlife is expected to be “less than significant.”
See sample testimony below for concerns and various potential impacts.
Public Comment Period:
The draft EA is available for public review and comment thru Sept. 30th at 11:59 P.M.
The full draft environmental assessment is available for public review and comment through Sept. 30 at 11:59 p.m., when people are able to provide feedback on the assessmentʻs “accuracy and adequacy.” It also considers a “no-action alternative,” where current activity remains the same.
The Pacific Missile Range Facility’s communications office asks members of the public to email comments or concerns to PMRF-LBT-EA-Comments@us.navy.mil.
Comments are also being accepted by postal mail to the address below:
Naval Facilities Engineering Systems
Command Pacific/EV22
Attention: PMRF LBT EA Project Manager
258 Makalapa Drive, Suite 100
Pearl Harbor, HI 96860
The final environmental assessment is expected to be completed in January 2025. As stated in the draft, if the assessment finds that there are significant impacts which cannot be mitigated to “less than significant,” then an environmental impact statement must be prepared.
Sample Testimony:
To Whom it May Concern,
I am concerned that the current EA for expanded military activities at PMRF and Kaʻula Island does not accurately or adequately assess the impacts that increased bombing of Kaʻula Island and increased military exercises will have on the local environment. Please require a full EIS.
Many ongoing impacts are dismissed because they take place in already degraded areas. Restoration of the sites to culturally appropriate management is what the EA should be the baseline to compare the impacts to, NOT the current status of ongoing Navy degradation.
There has been no EIS since 1998, and now the Navy is proposing increasing activity by 231% also without an EIS. This sets a dangerous precedent for insufficient monitoring and neglect of environmental concerns that could exacerbate the severity of their impact.
The EA ignores the impacts in the water, particularly the ocean, saying that they are already analyzed in previous documents. Those documents are outdated, and additionally do not include the proposed increase in activities. This is an enormous part of the cumulative effects of military operations in the Hawaiian Islands, as well as the affects of these individual land based activities, and is in direct defiance of the regulation defining significance. To reiterate the relevant definition, “significance cannot be avoided by terming an action temporary or by breaking it down into small component parts.”
Navy is proposing increasing Proposed Training and Testing Activities from 78 to 258. That is a 231% increase in activities overall, or 3.3x more activities, which is significant. On Kaʻula it is proposing increasing annual activities from 26 to 55. That is 112%, or more than double the number of activities. These are dramatic and significant increases that need further study.
Eighth, pg 3-26 acknowledges that “PMRF conducts missile launches from land-based launching pads at Barking Sands. Potential hazards associated with missile launches include chemical contamination, non-ionizing radiation, lasers, and wildfire.” Page 3-27 acknowledges the risk of electromagnetic radiation hazards and says that “ the Navy conducts regular radiation hazard surveys every five years.”
The impacts in this EA are also inappropriately separated from the cumulative impact of the associated ocean activities, which are a huge part of the activities that this EA will support. Particularly it is proposing 35 annual launch activities that will be “intercepted” (exploded) offshore and 3 live firing activities that could impact the water.
The designation of Kaula as “uninhabited” is inappropriate and untrue when you consider the wildlife that lives and relies on it. The assertion that “wildlife species have occurred at PMRF for decades during current training and testing activities, and no adverse affects have been observed” (ES-7) is baseless and absurd.
The EA admits that there are ongoing “short term” displacements of wildlife due to base activities; for all species these obviously have a cumulative impact on the wildlife that is likely significant and needs study. Navy use has gone for decades disrupting generational life cycles of protected species.
The conclusion on the impact of special status species dismisses their impacts because they would be “short-term.” This is not allowed as a reason to determine the impact would not be significant. The disturbances may be a violation of the Federal Endangered Species Act, but that is not addressed in this report. The evaluation of these impacts is critical to the EA and itʻs significance, and is inappropriately kicked down the road.
Furthermore Kaʻula is a well known fishing ground, impacts on the local fisheries and potential impacts to fishing/gathering practices have not been examined.
The EA is insufficient in assessing the cumulative impacts to Kaʻula Island. I urge you to require an EIS.
Mahalo for your consideration.
Aloha,
(Your Name)
(Where you reside)
Thank you for taking action!
The HAPA Team
