Dear Mr. Apoe,

EnviroWatch requests an immediate halt in Cyanotech expansion, so a complete assessment of environmental impacts can be made. This assessment should include a survey of the shoreline caves, particularly the caves and shoreline in the region known as the Hale Naia, to determine if there are burials in the caves and if the dynamiting has caused cracks in these caves. There should also be a survey and mapping of the lava tubes and a determination whether the explosions may be causing these to collapse. If this is the case, there should be no further explosions, or limits should be placed on the amounts and types of charges to be allowed to prevent further shoreline impacts.

A survey of marine mammals should be conducted, including a summary of available information from whale watching and dive/snorkle tours. These tours may also be able to provide information on the shoreline caves and marine communities affected by the pipeline installation and current Cyanotech expansion.

A task force should be set up to evaluate environmental, cultural and historical impacts. The evaluation should begin with a full disclosure of available data from the monitoring program from 1979 to the present. The task force should include members of the community, and people with historic and cultural expertise, as well as ecological and geological background. It should include staff from the Office of State Planning; DLNR's Divisions of Historic Preservation, Water Resources Management, Conservation Enforcement, Land Management and Aquatic Resources; and the Office of Hawaiian Affairs.

Their task would be to examine current or recent environmental impacts of the NELHA complex over the last 20 years, with special emphasis on the current expansion of Cyanotech. They should recommend/design a new system of monitoring and oversight for the NELHA, to include periodic reassessment of environmental, cultural and historic impacts; standardized environmental monitoring; and a well defined process for impact assessment, community input and approval of activites of new tenants prior to construction. They should evaluate examples of success or failure to protect conservation land from negative impacts and provide benefit to the community by existing tenants and the existing approval process.

This task force, or a special team of DLNR Historic Preservation Divison, OHA and Hawaiian cultural representatives, should be asked to revisit the definition of historic preservation and consider whether there is a need for an expanded definition to adequately protect burials and cultural sites.

Based on their review, the DLNR should be asked to work with the Counties, and State and Federal agencies to restructure the SMA/CDUA approval process and incorporate adequate checks and balances to protect Hawaii's historic sites and it's fragile ecosystems.

Sincerely,

Carroll E. Cox

Investigative Reporter