Tell BOEM no wind farm development in the waters off Ka‘ena Point on the North Shore of Oahu.  Protect our Kānaka Maoli,  North Shore Surf,  Fishing, Views, and Wildlife.  GO SOLAR INSTEAD

RE:  Comments on Hawaii EA; Oahu North Site, Due September 7, 2016.  TO:  Regional Director, BOEM Pacific OCS Region, 760 Paseo Camarillo, Suite 102, Camarillo, California 93010

Submit comments digitally via: https://www.regulations.gov/searchResults?rpp=25&po=0&s=BOEM-2016-0049&fp=true&ns=true

Or via the Change.org petition:  https://www.change.org/p/due-sept-7-2016-no-ka-ena-point-wind-farm

Dear BOEM Regional Director:

Our Mālama Nalu ‘Ohana is a  group of surfers, clean energy advocates, fishermen, environmentalists, and kānaka maoli organized in August 2016 to address your proposal to consider allowing wind farm development in the waters off Ka‘ena Point on the North Shore of Oahu.  We are submitting this letter during your public scoping period advertised via the Federal Register.  Our letter outlines our concerns with your proposal to consider leasing ocean waters off Ka‘ena Point for wind farm development – our comments are limited to the “Oahu North” portion of your proposed action.  A wind farm at this location would be an affront to our kānaka māoli, bar us from important fishing grounds, ruin our sunsets, rob ocean energy and disturb our world-class west and north swells, reduce our financial net worth, mar our night sky with industrial red blinking lights, contaminate our ocean, kill our wildlife, and cause fear and stress in the dying moments of all O‘ahu kānaka māoli.  We will do everything possible to block wind turbine installation in the ocean waters off Ka‘ena Point.  We also believe any purpose or need you may have for a wind farm in our ocean could be met, without these adverse environmental and cultural effects, by using solar with utility-scale battery storage.  Kamehameha Schools, residents, and businesses in Hawaii are being blocked from installing solar PV by our utility company – while you consider authorizing development of this egregious project – ‘A‘ole!  E mālama nalu.  Include solar with battery storage among the alternatives you fully consider in your NEPA documents so you can help improve our environment rather than destroy it.

On page 6 of your March 7, 2012 Hawaii Task Force PowerPoint http://www.boem.gov/uploadedFiles/BOEM/Renewable_Energy_Program/State_Activities/Task%20Force%20Purpose%20BOEM.pdf%20030712.pdf you indicate one purpose of the Task Force is to coordinate with Federal and local agencies and tribes to ascertain potential conflict areas such as “environmental, fishing, military, navigational, air space, etc.” “as early as possible and throughout the process”.  In August 2015, the North Shore Neighborhood Board voted against the wind farm after a presentation from the developer.  The meeting was attended by over 100 residents from the area.  In addition, your applicant met individually with members of our community and told them if the community opposes the wind farm, they will drop the project from consideration.  As a result of your coordination since 2012, you have excluded certain areas from further at-sea wind farm consideration due to certain criteria while the concerns of Native Hawaiians and the North Shore community do not appear to have been heard.  The North Shore community has voiced opposition to the proposed project – in numerous venues, via a broad diversity of representatives.  We are left wondering why this project is still proceeding through the NEPA planning process – we’d understood the developer would drop the project if the community didn’t support it.  We not only don’t support it – we vigorously oppose it.  At your agency’s July 21, 2016, well-attended public meeting on the North Shore, all speakers and, in two votes, all public attendees, unanimously  voiced opposition of any further consideration of the Kae‘na (Oahu North) site.

In addition to community opposition to the project, the public interest would be better served by any number of alternative sources of energy including on-island solar PV with battery storage. Ensure the project “Purpose and Need” described in your NEPA documents is not limited to the lease applicant’s purported purpose and need (to profit by developing the wind project).  Your Purpose and Need statement must express the proposed action’s underlying purpose and need from a public interest perspective.  In addition, the National Environmental Policy Act of 1969, as amended (Pub. L. 91-190, 42 U.S.C. 4321-4347, January 1, 1970, as amended by Pub. L. 94-52, July 3, 1975, Pub. L. 94-83, August 9, 1975, and Pub. L. 97-258, § 4(b), Sept. 13, 1982) (NEPA) requires you to “objectively evaluate all reasonable alternatives, and for alternatives which were eliminated from detailed study, briefly discuss the reasons for their having been eliminated” and “Include reasonable alternatives not within the jurisdiction of the lead agency.”  Your agency has stated that it is pursuing these projects to help meet Hawai‘i’s clean energy needs.  The significant adverse effects of at-sea wind development must be presented objectively and comprehensively, along with an analysis of other less-invasive alternatives that would meet clean energy needs.  The public prefers solar PV with battery storage (see next section) to the proposed Kae‘na wind project because the social, cultural, spiritual, and environmental effects of off-shore wind development are so severe.  Unlike Europe, the UK and the Netherlands, where most of the offshore wind energy is generated in the world today, Hawaii is located at a latitude ranging from 19° to 22° North.  This gives us a significantly greater amount of solar energy than what is available to many other countries pursuing renewable wind energy.  We urge you not to proceed with authorizing the proposed wind farm in the waters off Ka‘ena Point for various reasons outlined in this letter demonstrating that implementing this proposal would violate the National Environmental Policy Act because less harmful alternatives such as solar energy are readily available.

If you do continue to pursue the waters off Ka‘ena point within the Oahu North site for wind farm development, please ensure your NEPA documents include a thorough analysis and disclosure of the effects the project would have to the following important aspects of our lives:

       I.            Leina a ka `Uhane, white rock limestone kānaka māoli soul leaping formation

Situating a wind farm offshore from Leina a ka `Uhane white rock limestone soul leaping formation is an affront to Native Hawaiians and to those of us who care for Native Hawaiian rights.  As kānaka maoli of O‘ahu near death, they travel west to Ka‘ena Point where the fate of departing souls is determined. When the person’s brush with death is fleeting, they survive to return another day.  Departing souls would either pass into one of several spirit realms or be returned to the body to continue life.  If the proposed wind farm were to be constructed, dying O‘ahu kānaka maoli would see the wind turbines during the day or, at night, bright blinking industrial lights, as they travel toward the Leina a ka `Uhane.  The Hawaiian’s believe this industrial scene would cause fear and stress – irreparable injury – in the final moments of life of O‘ahu kānaka māoli.

Will the industrial turbine structures be made invisible or removed from sight when a Native Hawaiian nears death on O‘ahu during the day, so they are not frightened by the industrial landscape?  In the night when someone is close to death, can you turn off the bright industrial blinking lights so they don’t feel confused and frightened when they arrive at Ka‘ena Point? Of course you cannot implement these mitigation actions, therefore, out of respect for the Native Hawaiians, this project must not go forward..  If, however, you decide to go forward, ignoring the needs and rights of the Native Hawaiians, by granting the lease to this promoter, then please, in an appendix in your NEPA documents, list the names of all the Hawaiians who will be adversely affected in addition to the names of all of the Native Hawaiians consulted and the dates of the consultations.

Figure 1.  Leina a ka `Uhane, the location O‘ahu kānaka māoli travel to near death; departing souls pass into one of several spirit realms from this limestone rock formation.

Native Hawaiian families with lineages from all aapuaa on O‘ahu would be irreparably harmed by wind farm development in the O‘ahu North site due to the effect to them as they approach the Leina a ka Every native Hawaiian on O‘ahu who will face death during the 50 year term of your wind turbine installation may be irreparably harmed by installation of a wind farm off Kae‘na Point.  Some of these people have not even been born yet, so even if you wanted to, it’s not possible for you to “coordinate” with them to buy their support.

       I.            Ensure NEPA “Purpose and Need” Reflects the Public’s Interest, not just the Applicant’s Interest.

Ensure that the “Purpose and Need” described in your NEPA documents is not limited to the permit/lease applicant’s purported purpose and need (to profit by developing the wind project). Your Purpose and Need statement must express the proposed action’s underlying purpose and need from a public interest perspective.  In addition you must “objectively evaluate all reasonable alternatives” and “Include reasonable alternatives not within the jurisdiction of the lead agency”.

Your agency has stated that it is pursuing these projects to help meet Hawai‘i’s clean energy needs.  The significant adverse effects of at-sea wind development must be presented objectively and comprehensively, along with an analysis of other less-invasive and less problematic alternatives that would meet clean energy needs.  The public prefers solar PV with battery storage (see next section) over the proposed Kae‘na wind project because the social, cultural, spiritual, and environmental and economic effects of off-shore wind development are so severe.  To adequately assess the solar/battery storage alternative, the Department of Energy should be a participating agency in processing your proposal and finalizing your NEPA documents.  In addition, the Government Accountability Office (GAO) may be able to assist as it relates to government efficiency.

The Purpose and Need statement should be fully detailed and describe specific needs for certain MW of energy during certain periods of the day/night on a certain percentage of days. Sideboards on the purpose and need should be explained.  Please be objective and refrain from describing purpose and need so restrictively that it precludes consideration of options other than the at-sea wind development. It is your burden to explain how the Ka‘ena Point Wind Farm alternative serves the public’s interest better than the other alternatives.  Mark Glick listed biofuel and neighbor island renewables as alternatives in his May 2016 Task Force presentation (Figure 2).  Assess the potential for fast-growing trees grown on O‘ahu, Maui, the Island of Hawai‘i or other islands to provide the energy in lieu of this wind farm.  The NEPA requires that you objectively evaluate these environmentally superior alternatives.

    II.            Include Assessment of O‘ahu-Based Solar PV/Energy Storage Alternative

The public interest would be better served by any number of alternatives including on-island solar PV with battery storage, rather than this horrible Ka‘ena Point wind development.  Your NEPA assessments should include an onshore solar with energy storage alternative.  Many, many other alternatives come to mind that would receive more public support and less public outrage than the proposed Ka‘ena Point wind farm project – many are in the news – please coordinate with DBEDT, HECO, and current alternative energy producers in Hawai‘i to develop alternatives to the proposed action, including solar PV with battery storage.

Much of the vehement opposition to your project heard at the July 21, 2016, public scoping meeting seems to be the result of HECO, our utility’s, resistance to allowing grid-connected solar PV installations on our homes and to allowing solar farms to be constructed: http://www.bizjournals.com/pacific/news/2014/01/28/first-wind-plans-to-build-three-large.html  http://www.kitv.com/story/31239004/solar-farm-workers-upset-over-hawaiian-electrics-decision-to-shut-down-sun-edison-projects .  At-sea wind structures, particularly in the most culturally-significant viewshed on the Island, are likely to be wildly unpopular until HECO has allowed build-out of solar PV with battery storage on Oahu. The public, the large and small local landowners, and local solar companies who are missing out on opportunities to fuel Oahu’s energy needs with unobtrusive solar PV, and the many entities that would be harmed by a wind farm at this location prefer solar PV with storage.  Please, let’s consider taking full advantage of the abundant solar energy that Hawai‘i is blessed with.

Mark Glick’s 2016 PowerPoint at the Task Force meeting http://www.boem.gov/Hawaii-State-Administrator-Presentation/ indicates on-shore Oahu energy generation is not going to be sufficient to meet State 100% clean energy targets and HECO’s preferred energy source is 800 MW of offshore wind to meet the shortfall (Figure 2).  800 MW would entail, for example, 100 8-MW wind turbines.  The proposed 400 MW Kae‘na Point offshore wind project could be replaced with solar and battery storage that IS feasible, tested, and proven WITHOUT the adverse effects to the environment addressed in this letter.  We believe the PUC and our County, State, and Federal representatives are intelligent enough to see this Kae‘na project is not in Hawai‘i’s best interest.

Public Support for Clean Energy Was, In Part, Based on Our Understanding It Would Keep Our Money In Hawai‘i:  For context, O‘ahu would like to be 100% renewable energy by 2045.  Based on (https://energy.hawaii.gov/wp-content/uploads/2011/10/FF_June2013_R2.pdf), and the $0.15/kwh of recent Power Purchase Agreements, we estimated HECO pays approximately $1 Billion/year to produce or purchase the electricity we pay HECO $1.8 Billion/year to distribute to our homes and businesses.  That $1 Billion is essentially at stake – who will that $1 Billion/year (that $50 Billion over 50 years) be paid to.  Will much of the $0.15/kwh be paid out to a Danish wind developer or will it be paid to local landowners and businesses producing solar energy?

We are just members of the public – not as knowledgeable and skilled as our members of the PUC, DBEDT staff, and our politicians who we have to assume are also looking for ways to get us out of this bad wind farm deal.  The public supports the Clean Energy Initiative because we thought one of the reasons to move to clean energy was to stop bleeding 10% of our State GDP for the cost of importing crude oil for our generators.  Please coordinate with DBEDT and landowners to develop the alternative that is environmentally superior to this proposed wind farm.  Your analysis and your assistance with implementation will greatly benefit the people of Hawai‘I, helping rather than harming us.

Figure 2.  Mark Glick, DBEDT Director, May 2016 Task Force Presentation indicating wind as current source of energy http://www.boem.gov/Hawaii-State-Administrator-Presentation/.

A year ago, battery storage costs per kWh for Tesla’s Powerpack, Eos Auroura, Imergy ranged from $0.02 to $0.05 per kWh used (Table 1, http://cleantechnica.com/2015/05/09/tesla-powerwall-powerblocks-per-kwh-lifetime-prices-vs-aquion-energy-eos-energy-imergy/).  Eos and Tesla representatives assured us their batteries are ready to go and they could fulfil a $1 Billion battery order.  O‘ahu residents pay rates between $0.26 and $0.36 per kWh; even without a $1 Billion Federal subsidy, such as the one currently proposed to construct the offshore wind farm, this additional cost for battery storage is feasible.  Cost breakdowns for the Eos Auroura, Tesla, and lead batteries are sketched out below with all prices expressed in 2016 dollars.  In addition, the U.S. Department of Energy is funding battery storage and significant cost reductions are anticipated in the next five years.

Table 1. Clean Technica, May 2015, utility battery storage cost per kWh (http://cleantechnica.com/2015/05/09/tesla-powerwall-powerblocks-per-kwh-lifetime-prices-vs-aquion-energy-eos-energy-imergy/ ).

Eos Aurora Battery Option:  Ebram Megally Manager, Sales & Account Management, Eos Energy Storage was very helpful and their batteries appear to be a great option.  Mr. Megally confirmed a 400MW (1,600MWh) DC system would cost $256 million (1600MWh*160/kWh*1000) for the batteries to provide 400 MW of energy for a drawdown period of four hours.  We would need three of these systems to provide 400 MW of power for 12 hours (overnight, a total of 4,800 MWh), for a total battery cost of $786 Million.  Inverters and site hardware would come from and be installed by other companies at an approximate cost of 20% of the cost of the batteries ($153 Million).  Total cost for the Eos batteries plus inverters and site hardware would be approximately $939 Million (essentially the same cost as the 50% of the $2 Billion wind farm construction cost that would be federally funded).

To fill this 4,800 MWh of battery capacity (4.8 million kWh) with solar PV during the day, we would (based on a previous discussion we had with Tesla) need approximately 576 MW of nameplate capacity solar PV.  At 5 MW per 35 acres of solar farm, 576 MW of PV would occupy 4,000 acres.  We have plenty of developed area (rooftops and road beds), grazing land (and agricultural land that lays fallow due to lack of irrigation infrastructure and other reasons) on O‘ahu to accommodate this solar.  To match the wind farm’s 400 MW of power generation during the, 400 MW of additional solar PV could be installed on an additional 2,800 acres; for a total of 6,800 acres of solar PV producing 8,000 MWh/day.  The 2007 Waialua wildfire burned 6,800 acres of fallow agricultural land on the North Shore – land many of the landowners would probably already have in solar PV production with grazing under the panels if solar development were not curtailed due to the lack of battery storage capacity.  These North Shore landowners, including Kamehameha Schools and homeowners have been actively pursuing large-scale installations of solar PV, but HECO is not accommodating it because utility-scale neighborhood-level and grid-level battery storage is not available.

At a rate of $130 Million per 100 MW of solar PV installation, this 976 MW of nameplate solar PV capacity would cost an estimated $1.268 Billion to install.  Congress extended the 30% Solar Investment Tax Credit through 2023, so the net cost to install this $1.268 Billion in solar PV would be $888 Million.  Earnings for their production of approximately 8,000 MWh/day (approximately 2.96 Million MWh/year), these solar farms would be approximately $445,000/day ($162 Million/year).  The $888 Million in solar PV installations would pay for themselves in approximately five and a half years and continue producing power for an additional 14 plus years (profiting approximately $162 Million/year over those 14+ years, for an approximate profit of $2.26 Billion for the 20-year period).  Applied to the 50-year timespan of the proposed wind farm, the landowners with the solar installation would NET approximately $5.6 Billion during the 50-year period; money that would stay in Hawai‘i by going to local solar PV and solar farm owners rather than going to Denmark for a 400 MW Kae‘na wind farm.  Fully analyze and disclose the environmental and financial costs and benefits of the proposed action and the solar alternative.  Specify the sources for the wind farm and solar/battery alternatives and the amounts of money expected to stay in Hawai‘i, stay in the US, and be used to purchase items from and take profits out of the State and the US.

Tesla Battery Option https://www.tesla.com/powerpack/design#/ :  Tesla Lithium Ion batteries appear to be a more costly battery storage option.  Based on their online price tool, the $1 Billion in Federal funding (50% of the $2 Billion project), for example, could buy us 2,043 MWh of battery storage for our solar PV (at $489/kwh), (approximately $0.10/kwh – interesting Tesla system pricing has doubled since 2015).  That’s enough to provide Honolulu with 400 MW of power, continuously, at night, for five hours.  The solar PV needed to fill the 2,043 MWh of batteries would be roughly 245 MW nameplate solar capturing sunlight for eight hours a day (with a lot of excess capacity after batteries are topped off on long, sunny, summer days).  Acres of solar PV:  at 5 MW per 35 acres, 245 MW of nameplate capacity would occupy 1,715 acres.  At a rate of $130 Million per 100 MW of solar PV installation, the landowners would pay $319 million for the installation of the panels to fill the $1 Billion batteries.  If you need to match the wind farm’s 400 MW of power generation during the day, installation of 400 MW of additional solar PV would only cost $520,000.  All this solar PV, plus the Tesla battery storage, comes to $1.84 Billion.

Standard Battery Option:  According to Crown Battery Chip Johnson, Crown Battery Manufacturing Company, SLI Products Division – Western U.S. Region, cjohnson@crownbattery.com, $1 Billion would enable the purchase of 5,762,714 kW (5,763 MW) in total storage capacity; or 2,881,357 kW (2,881 MW) in usable energy (50% usage of battery’s total capacity is usable).  This storage capacity would fuel six hours of drawdown at a rate of 400 MW and three hours of drawdown at a rate of 800 MW.  Filling the 2,881 MW of battery would be completed by noon each day 600 MW of nameplate solar PV capacity.  Solar PV with a nameplate capacity of approximately 600 MW would be sufficient to refill the batteries each morning (to afford a rest period for the batteries before drawdown after the sun sets).  Acres of solar PV:  at 5 MW per 35 acres, 600 MW of nameplate capacity would occupy 4,200 acres.  At a rate of $130 Million per 100 MW of solar PV installation, the landowners would pay $780 million for the installation of the panels.  In addition to recharging the batteries before noon each day, the 600 MW of solar PV would feed energy into the grid all afternoon and into early evening.  The 2007 Waialua wildfire burned 6,800 acres of fallow agricultural land and grazing land – on property owned by residents who would like to install solar PV but are not able to because HECO lacks battery storage.  The landowners, local businesses, and homeowners would benefit from profiting from their installation of the solar PV – a win-win, rather than a win (for Denmark)-lose (for Hawai‘I businesses).

This is Hawai‘i, not Denmark – we are at 21 degrees latitude, not 56 degrees North.  It’s sunny here and we have tens of thousands of acres of flat, accessible land that’s being underutilized because we don’t have battery storage.  According to Kamehameha Schools, solar PV is compatible with many agricultural uses – Kamehameha Schools pursued development of solar on their property, but projects were cancelled by the utility.  Vegetation under the solar panels could be grazed by sheep or goats to produce food, like the solar farm near Mililani.  Areas currently grazed could be fully utilized with the addition of solar PV.  With the battery storage option, landowners would net $1,372/month per acre from the sale of the PV electricity, on top of the money they make from grazing.

Counties should institute permit requirements to prevent solar farms from causing fugitive dust impacts.  Solar farms near developed areas, where rainfall exceeds 20 inches per year (climate where guinea grass thrives) should require vegetation to be managed with grazing and mechanical treatments and should prevent landowners from using herbicide to create bare earth.  County planning departments should require solar farms, adjacent to communities in dry areas where rainfall is less than 20 inches, to maintain dust abatement to prevent fugitive dust.

We recommend you invite Kamehameha Schools staff or other skilled planners to help develop the solar PV with battery storage alternative for your NEPA documents.  You should also work closely with Dan Nellis at Dole Foods, Bob Cherry (Flying R Livestock), the State of Hawai‘I, the US Air Force and other DOD installations – all entities owning significant acreages where solar PV could be installed – on O‘ahu and neighbor islands.  Solar farms could be built on developed rooftops, previously-disturbed lands, and grazing lands managed by DHHL and DLNR.  Profits could be used to fund the State’s operating budget so the people would benefit (similar to the way schools are funded by harvesting timber on State lands in Washington and Oregon).  When entities in other states are serious about solar farm development, they reach out to landowners to confirm a list of interested participants – you should demonstrate you are serious about developing a refined plan to provide a solar energy alternative by sending a letter to all landowners inviting them to coordinate with you in the development of solar energy.

A condition of any authorization, permit, or other approval BOEM gives to an offshore or off-island wind developer at the “Oahu North” site should be that the wind developer include assessment of an on-island solar PV plus energy storage alternative in the analysis they assist you with.  Include this land-based PV plus energy storage alternative among those you fully consider in your NEPA documents.  Other land-based, low-effect alternatives you should consider include locally and neighbor-island-sourced biofuel.  Biofuel could be used to fuel energy needs during prolonged cloudy periods, which occur every few years; a combination of solar with battery storage and biofuel would be an even better alternative than a single energy source.

Your NEPA documents should provide Hawaii’s legislators, PUC regulators, and residents with an honest evaluation of the proposed project in comparison to the public’s preferred PV alternative.  Because PV with battery storage alternatives are in their jurisdiction, the Department of Energy should be a cooperating agency in your EA and EIS.  To facilitate Federal Government efficiency and the coordination, appropriations requests, and funding transfers between the two Federal agencies, the EPA and CEQ (Council on Environmental Quality) assistance should be developed and maintained throughout project development.  We believe solar PV with battery storage is the environmentally superior alternative.

       III. Fishing Restrictions, Access Restrictions

Fishermen who’ve heard about this project are furious about your proposed action (Figure 2).  The Oahu North call area is heavily fished for tuna because even though it is much deeper than anywhere in the world a floating wind farm has ever been built, it still receives upwelling from the much deeper water nearby.   As with almost all other offshore and land based wind farms in the world, it is very likely that either the ultimate owners of these windmills (who will not be the applicant-project promoter) or some governmental officials would close the area to public access due to safety concerns.  This will block both an important fishing ground and our canoe and sailing route between the North Shore and Kauai.  Closure of miles of ocean will result in adverse effects to fishermen, canoes, sailing, and other recreational, cultural, research, and commercial users.

Figure 3.  An angry fisherman telling the wind developer no at the July 21, 2016, public scoping meeting on the North Shore.

Provide details in your NEPA documents of the effects the ocean closure will have to these users.  Your PowerPoint indicates the Kae‘na Point area is not frequently used by ocean vessels – however, when one sails or paddles to Kauai for cultural or recreational purposes once a year or once every few years, the frequency of the voyage is not high, but the cultural importance is significant.  Please don’t block our ocean routes to Kauai.  In addition, the wind turbines will reduce the energy in the wind downwind from the development.  This will harm voyaging by our sailing canoes.  Assess the effect the wind farm may have to surface wind speed and humidity in your EA and EIS.  We have noticed the wind farms on land seem to have resulted in adverse effects to wind conditions for kite surfing and wind surfing.

Disclose in writing to 1.) all fishermen holding licenses to fish in the waters of Hawaii 2.) all persons registered during the current year and previous three years on the National Saltwater Angler Registry in Hawaii, and 3.) all registered owners of boats registered in the State of Hawai‘i a map of the area that may be closed to the public should a wind farm be constructed at the site and an explanation of the wind farm project.  Provide this information in writing to these persons whenever any Federal Register Notice is published related to wind energy development of the Oahu North BOEM Call Area.

Your EA should disclose the density of Ahi, Mahimahi, Ono, Marlin, and other ocean fish passing through each grid cell in the proposed lease area each month over two years of study.  Detail how the anchors will be installed and how much ocean bottom they will destroy.  Detail why the anchor system can’t be used farther from shore, in deeper water, where the effects to the ocean environment would be reduced and where turbines would not be visible from shore.  Detail the economics of the nearshore versus farther than 42 miles out projects and explain why it is not situated in a deeper area rather than a productive upwelling area.  Your online PowerPoints indicate it’s not practical, but that assertion needs to be explained in detail. http://www.ewea.org/fileadmin/files/library/publications/reports/Deep_Water.pdf indicates the type of deep water installation you are proposing is experimental.  Explain why you would situate an experimental wind farm in an area that’s so important to fishermen and other ocean users.  Disclose what percentage of the time, during the 50 year period of wind farm development and operation, the wind turbines may not be fully-operational, not feeding energy into the grid, yet still closed to public access.

Development of this important site should not be permitted because it would interfere with important site-specific research.  Development of solar PV on previously-disturbed land would not result in loss of important research opportunities.  A third O‘ahu volcano has just been discovered at the proposed wind farm site (Figure 4).

Figure 4.  Researchers just found a third O‘ahu volcano off Ka’ena Point (J. Sinton et al / University of Hawai’i’s School of Ocean and Earth Science and Technology).

“Much of our knowledge of Hawaiian volcanoes is based on those that rise high above sea level, and almost all of those formed on the flanks of earlier ones. Kae‘na represents a chance to study a Hawaiian volcano that formed in isolation on the deep ocean floor.”  In addition, Scrips Institute of Oceanography researchers just confirmed the existence of “high-mode internal lee waves” was just confirmed in studies of water flow across the “supercritical ridge in Hawaii known as Kae‘na Ridge” http://scrippsscholars.ucsd.edu/malford/content/breaking-internal-lee-waves-kaena-ridge-hawaii.  These two discoveries were made within the last few years – we will never know how much important information will be irretrievably lost due to the permanent disturbance and 50-year closure of the site if the proposed action is permitted.

Floating buoys are vandalized or otherwise taken out of service by ocean users.  How will security issues be resolved?  We would also like to request a through exploration of the down side scenarios of unintended consequences of equipment failures large and small associated with both natural and anthropogenic causes. In addition, detail what means of access will be provided to the floating structures for use by boaters during emergency situations.

     V.            Viewshed Analysis

A wind farm in the waters off Ka‘ena Point would obstruct views of the open ocean that are used by Native Hawaiians, O‘ahu residents, and tourists for spiritual rituals, relaxation, and contemplation.  Turbines located closer than 42 miles from shore would be visible during the day; bright high-visibility lights (required by FAA) would cause the open ocean viewscape to appear to be an industrial area at night.; we recommend you situate all wind turbines beyond 42 miles from the Ka‘ena Point shoreline to be out of view of the Ka leina a ka uhane white rock limestone soul leaping formation and residences. Many of us have worked our whole lives to protect and enhance the beauty of our environment for our residents and our visitors and you’re proposing to ruin it for a 50-year period.  Your EA, EIS and other NEPA planning documents should address the following adverse effects to viewshed:

First, please provide us with two maps:  1.) a map with shading on the land, beaches and ocean landscape where any portion of a wind turbine structure will be within view/in line of sight and 2.) a map with shading on the areas of land, beaches, and ocean where a portion of the wind turbine’s base/stem will be visible (so excluding areas where only the taller rotor-swept area would be within view).  Second, assess effects of the proposed wind farm to views (as detailed below) at the following locations:  North Shore: Kahuku Point, Turtle Bay Resort, Sunset Beach, Ehukai Beach Park, Pu‘u o Mahuka Heiau State Historic Site, Laneakea Beach, Puaena Beach Park, Hale‘iwa Alii Beach Park, Kiaka Bay Beach Park, Polo Beach, Mokulē‘ia Beach Colony Seawall, Mokulē‘ia Beach Park, Mokulē‘ia Crag rock climbing area, Hidden Beach, and the Ka leina a ka uhane white rock limestone soul leaping formation; West Oahu: Yokohama, Mākua Beach, Kea‘au Beach Park, Lahilahi Point, Maili Point, Ka‘ula and upper floors of a resort at Ko Olina.  These locations don’t encompass all areas where view is a concern, but renderings from these locations will enable us to imagine the changed view from locations important to the public.  Disclose accurate viewshed renderings from these above locations using high-resolution 100mm and 200mm lenses to produce renderings of the wind structures under the following light conditions and sun angles: mid-morning, at sunset on the Summer Solstice, Winter Solstice, and Equinox, and at night.  In addition, provide video renderings using a 100mm lens view, to disclose how the wind farm will look at night – with its large, bright, industrial blinking lights. For each time of year, camera zoom angle, and time of day, provide separate assessments of the viewshed effect if wind turbine development was restricted to distances greater than 16 miles offshore versus effects if wind turbines are permitted closer to shore.  Address the following view-related concerns in the analysis:

• The construction of even one wind turbine within the “Oahu North” portion of the within the Oahu North area would visually desecrate our Native Hawaiian’s centuries-old cultural and spiritual practices conducted viewing the night sky over the ocean, viewing the open ocean, and viewing the setting sun over the unobstructed ocean and taking a last view on earth go to the Ka Leina a ka ‘Uhane white rock limestone soul leaping formation.   Analyze and disclose the adverse effect the obstructions will have to Native Hawaiians.
• In so many wind farm projects, developers provide the public with wide-angle photographs with grainy, tiny little wind turbines that are not visible in the rendering. When we view and photograph sunsets on the North Shore, we use 100mm and 200mm lenses, so your renderings must show with wind turbines mocked up in sunset photographs using the crisp clarity of 100mm and 200mm lenses we would see in our photographs.  We have a history, on the North Shore, with this sensitive topic so we are vigilant to errors in your disclosure of this aspect of project effects (Figures 5-7).

Figure 5.  Present renderings of the wind turbines as they would look to the human eye or green flash photographer.  This photo of the Sunset Beach Surf Break with Ka‘ena Point in the background was taken with a 100mm lens.

Figure 6. Our concerns related to viewshed analysis are based in our local experience (top photos); the photograph at the bottom is a wide-angle photograph of the Sunset Beach Surf Break, with Ka‘ena Point itself barely visible.

Figure 7.  BOEM Oahu North section of the Oahu Call Area – Sunset Beach photo point is equidistant from Ka’ena Point and the area open for wind farm lease applications.

• • Because the effect to view will be significant, we recommend you divide your planning and any future permits by distance-from-shore zone so wind turbine development farther from shore is not held up in law suits because the Permit includes turbines in a zone or zones closer to shore. Separate your analysis for viewshed into the following three zones to enable the public to understand effects of each: 1.) closer than 16 miles from shore; 2.) 16 to 42 miles offshore; and 3.) greater than 42 miles offshore.  Turbines within sixteen miles of shore have the greatest effect on view and will be fought by the greatest number of people and groups.  Turbine locations 42 miles offshore are not visible from the shoreline so these locations are likely to be the most palatable because the industrial day- and night-time red blinking lights effects will not be a blight to most residents.
  • List the addresses of all properties on the North Shore, West Oahu, and Kauai the wind turbines could be visible from during the day, at sunset, or at night. Include all of these addresses in your list of affected parties and send notifications to them by mail when the Federal Register publishes information related to wind development in the waters off Ka‘ena Point.
  • Assess the effect the industrial at-sea structures will have on North Shore tourism including effects to Turtle Bay Resort, effects to small businesses, effects to rental income, effects to weddings (Figure 8), and changes in visitor numbers. Research the numbers of North Shore weddings that historically have occurred and disclose the anticipated effect to local people and visitors of loss of this scenic wedding location.

Figure 8.  This iconic, unspoiled, best of Hawai‘i, Ka‘ena Point ocean scenery should not be littered with at-sea windmills (Top left photo by Jenna Leigh Photography; other three photos by Hawaiian Barefoot Weddings).  Provide renderings of what the wind farm would look like using these four photos in your NEPA documents.  Contact us for .jpgs.

• • Analyze the annual number of times the green flash at sunset will be obstructed to a viewer by a wind turbine. For example, Sunset Beach, on the North Shore of Oahu is so named because it is the western-most point on the North Shore where the sunset is visible year-round.  Tourists visit Sunset Beach to photograph the unobstructed sunset over the ocean.  Sunsets are often accompanied by a green flash of light as the sun clears the horizon – view of the green flash, and photographs of the green flash a sought-after.
  • Disclose the annual number of photographs of surfers, beach users, and recreational users including boaters, mountain bikers, rock climbers, and hikers the wind turbines may clutter in their otherwise clear ocean views.
  • Assess and disclose the effect the proposed project will have to viewshed of ocean users including Humpback whale and evening cruises out of Hale‘iwa and Waianae Harbors, shark tour boats, and recreational and commercial boaters offshore on the North Shore and West side of Oahu during the day and at night. Include all registered owners of boats docked at Waianae Harbor and Hale‘iwa Harbor in your list of affected parties.
  • Either include a “farther than 42 miles offshore” alternative to the proposed action or, in your NEPA documents, include a thorough explanation of why your project can’t be situated in water deeper than 1,100 meters. The wind turbines would not be visible from shore if they were situated farther than 42 miles from shore.  Your 2016 Task Force PowerPoint indicates that although it is feasible to install at-sea wind turbines at depths greater than 1,100 meters, it is not “practical”.  Without this explanation, we don’t understand this otherwise arbitrary cutoff.
  • It is hard to explain the importance our residents place on walking out to the shoreline or to another prominent point to watch the sun set. Others can see the sunset from their homes.  It’s a moment of relaxation – it’s a moment to view nature, undeveloped, unaffected by man – we just don’t have many moments like that here.  We feel like this unobstructed area is our Wilderness – because we have it, we (O‘ahu residents) have a place to escape to on weekends – because we have it, we don’t need to travel to outer islands or to the mainland to experience nature, to be in view of Wilderness.  Keep our wild scenic area undeveloped so we don’t need to travel and waste jet fuel.  We feel our view of sunset would be severely affected by this project.  Please find an alternative to this at-sea wind project, provide us with information about the cost of the better alternative; please give us options other than this egregious project that would meet your needs.

  VI.            Disclose decreased property values on the North Shore, West Oahu, and Kauai resulting from proposed at-sea wind project

Property values would decline in many areas of Oahu’s North Shore, West Oahu, and Kauai during a fifty year period if the proposed Ka‘ena wind farm is constructed because our world-class surf and pristine scenic views of sunset (the reasons people live and visit here) would be harmed by the project.  Realtor.org has compiled information regarding changes in property value due to wind farms (http://www.realtor.org/field-guides/field-guide-to-wind-farms-their-effect-on-property-values).  These property value changes are related to views – they don’t include the effects resulting from your project’s disturbance of our surf (see surf section below for additional surfing-specific concerns).  Detail in your EA and EIS the extent to which property values would be affected.  Provide specific potential reductions in property value, in dollars, for each individual address on the North Shore, West Side of O‘ahu, and Kauai.  Include projections of future property value for all North Shore, West Oahu, and Kauai properties that may be affected by the project.  Provide real estate value projections for the 50 years of wind farm construction and operation.  Include in your assessment of property value that Kawailoa Wind Farm is only permitted to be on the landscape for the next 15 years and then it will be decommissioned.  Explicitly describe assumptions. For each property, provide anticipated estimated value without the O‘ahu North wind farm, the percent reduction in the value of the property due to the wind farm, and the difference.  Express uncertainty in the percent reduction in the property value and the anticipated estimated property value separately and explicitly.

In addition to providing the following information in your EA and EIS documents, also provide the following in writing to every registered owner of all property that may be affected: 1.) the effect the proposed offshore wind project may have to their property value during each year of the 50 years of construction and operation in comparison to what these values would be expected to be in the absence of the wind farm landscape blight.  2.) The effect the proposed wind farm may have at reducing or increasing their electric bill; 3.) the effect the public’s preferred alternative (solar PV with grid-level battery storage) would have on their property value and their electric bill.  When providing each of these three items, include details of your assumptions so your calculations will be repeatable.  You may wish to provide several scenarios, with their various assumptions.  Detail this information in your NEPA documents as well as providing the property-specific analysis to each registered property owner whose property value may decline as a result of the proposed wind farm.  Detail in your NEPA documents and in your individual written notice to all affected landowners the cumulative loss of property value / net worth of the people of Hawaii that may result from the proposed wind farm.  This loss of net worth should also be presented in your EA and EIS in relation to the PV with battery storage alternative.

Our August 21, 2016, review, Zillow, of the 256 most recently sold homes in Haleiwa and the 259 most recently sold homes in Waialua indicates the average home price in Haleiwa was 1,365,089 and the median home price in Waialua is 575,000.  2010 Census data indicates there are 1,318 households in Haleiwa and 1,165 in Waialua.  At a rate of 1,365,089 per property, total residential property value in Haleiwa is approximately $1.8 Billion; at $575,000 per property in Waialua, residential property value in Waialua would be $670 Million (totaling 2.47 Billion).  A reduction in property value of ten percent would reduce the net worth of North Shore residents by $247 Million (an average of $100,000 per household); a twenty percent reduction would come to approximately $500 Million in 2016 dollars ($200,000 per household).  And we wouldn’t want to live with this industrial blight on our once beautiful seascape so we would want to sell and move and we would feel this loss of net worth.  Our point is that cultural sensitivities, fishing, endangered species, social justice, and all other things aside, there are many, many, people in our communities who will fight very hard to prevent construction of even one wind turbine in our North Shore waters to ensure their life savings is protected.  Especially when alternatives to the proposed action appear to be readily available.

The same analysis should be done for West O‘ahu and Kaua‘i.  Based on property value effects alone it looks like families in these areas would be better off if we all took a year off from work to volunteer to help you figure out a better way to get this energy produced and transmitted to urban Honolulu than we would be allowing you to move forward with this Kae‘na wind project.

VII.            Adverse Effects to Business and Tourism

Hawai‘I, O‘ahu, and the North Shore’s number one economic driver is Tourism.  Tourism is a $14 billion part of our economy, accounting for 22% of our GDP.  More than 50 % of O‘ahu tourists tour the North Shore during their stay.  Tourists spend an average of $150 to $400 a day in Hawaii.  These people are here on their honeymoons or on a Hawai‘i tropical island vacation – you can’t replace that with ecotourism to see an industrial facility.  Turtle Bay Resort is a multi-billion dollar luxury oceanfront destination at the northernmost point of the North Shore.  Many North Shore restaurants are situated to view the sun setting over the ocean.  The economy of the residents of the North Shore is rooted in the beauty of our scenery, our clean powerful surf conditions, and our undeveloped country environment.  Tour busses stop at Sunset Beach so tourists can take photographs of the beautiful ocean scenery.  The Hawai‘i Tourism Authority prioritizes “Maintaining the Brand” to assure long-term sustainability of the destination.  Your proposed Kae‘na wind farm would cause irreparable harm to the North Shore brand and because this is a premier destination for tourists from the lower 48 states and international travelers, construction of this wind farm would adversely affect the quality of life for a portion of the World population.

A review of the 2010 Census data indicates the North Shore receives the following total annual value of sales:  Retail $105,649,000; Food: $33,591,000; Rental Real Estate (including Turtle Bay Resort): $5,367,000 for a total annual tourism-related input of $144.6 Million.  A 10 percent reduction to this net would cost our tourist-related businesses $14.4 Million annually.  Your analysis of the effects of the proposed action should include an assessment of changes to the future number of tourists visiting the North Shore and the tourist dollars spent on the North Shore the project may have during its first 20 years of operation.  Your analysis should also include an assessment of the reduction in the reduction in overall O‘ahu visitor arrivals that may result from the injury to the brand and the effect this may have to airlines and the businesses in Waikīkī.  Couple this analysis with your assessments of the other financial adverse effects the project will have to us to provide a cumulative assessment of the injury to the people of the North Shore, West O‘ahu, and areas of Kaua‘i within view of the proposed wind farm.

VIII.            Contaminants, Algae, and Invasive Species

Detail the amount and type of fluids, solids, and particles the wind turbines will leak or fall into the ocean during construction and operation of the wind farm.  Detail the effects these contaminants will have to limu, fish, seabird, monk seal, humpback whale, and human health.  Detail the components of the various turbine components, fluids, anchors, and anchor chains or cables.  Include transmission fluid and oxidized components of the structures.  Iron should not be in the components used in the wind turbine platforms or in-water components of mooring lines and anchors because it causes dramatic loss of corals and increases in invasive species and algae growth.  In the 6,000-ft deep (2,000 meter) waters off the Kona coast, where floating cages submerged just beneath the water surface are installed, the shade from a single cage causes algae to grow on the sand bottom substrate – address the effects shade from the proposed structures will have to cause additional algae growth.  Algal blooms are severely affecting tourism in Florida – how will the proposed action affect algae and invasive species growth in the developed area and on the shores of Kaua‘I where upper-ocean currents would carry the iron-enriched water.  Structures containing iron are being removed from the offshore waters of the Northwestern Hawaiian Islands because the iron causes expansive areas of sea floor around shipwrecks and buoys to be overgrown by the invasive Corallimorpharian Rhodactis howesii (Figure 9).

Figure 9.  Invasion of Palmyra Atoll coral reef by invasive species in areas contaminated by iron (Work et al 2008).

Based on a 5:1 ratio of anchor line length to water depth, 12 miles of anchor line appear to be required for each wind turbine – if iron a component of the lines or structures, even one turbine could significantly modify the ocean floor in this important, productive upwelling area in addition to harming other areas where the currents carry contaminant-tainted water.

Detail the contents of in-water components of the proposed structures and provide a thorough assessment of the effects these structures may have to the species composition of the sea floor.  Provide a thorough assessment of the effects a single turbine structure and its associated components may have – detail zones of severity of change and the number of square miles of each zone.  Map all areas of areas of coral greater than 10 meters wide within the Oahu North Call Area and provide an assessment of the effects the proposed project, at the project-level, may have to these corals.

Provide a thorough assessment of the direct effects the disturbance resulting from the anchors will have to the ocean flora and fauna.  Repeat the above analysis for the 42-miles offshore alternative, where turbines are situated out of sight of the Ka leina a ka uhane white rock limestone soul leaping formation, in deeper, less productive waters.  This Oahu North site is a high-productivity ridge area of our ocean – no experimental wind structures (let alone tested and true wind structures) should be installed at this location.

Climate change is expected to increase sea surface temperatures so 18 years from now, the strong hurricanes (which usually only remain strong when they stay in waters south of Hawai‘i) are expected to track through the Hawaiian Islands instead of staying to our south.  Our sea surface will be more similar to the energy fueling super typhoons in the south Pacific.  Tsunamies are likely to affect the area also.  BOEM should therefore ensure the number of hurricanes and tsunamis that may affect the structures, and the effects those may have to the wind turbine structures be included in the EA and EIS.  BOEM should also require the applicant to maintain funding in escrow to cover the cost of locating and retrieving the pieces of metal, petroleum products, oil, and other contaminants that fall into the ocean during the hurricane.  BOEM should ensure the wind developer retrieve any articles containing iron (see above).  Consult with the US Department of Defense and US Coast Guard regarding anticipated costs associated with detecting and retrieving pieces of similar missing pieces of aircraft.  The wind developer should pay the costs for undersea search and retrieval operations.  BOEM should not allow any component containing iron to remain unaccounted for.  The mitigation cost for loss of coral reef should be applied to any component missing – each pound of metal that goes missing should be assessed a coral mitigation cost if it’s never retrieved.  The cost of retrieval of components torn off by a single hurricane, the anticipated potential number of damaging hurricanes, the potential costs for compensatory mitigation for damages to the environment, and the method by which the applicant will escrow funds, should be included in your EA and EIS documents.  Ensure additional funding for decommissioning, removal, and restoration of the ocean floor back to it’s original state are sufficiently assured in escrow.  Ensure all escrow funding is held by an A-rated American Bank naming NOAA and the DLNR as beneficiaries.

  IX.            Undersea Cable and Transmission Line Electromagnetic Effects to Wildlife and Humans

Detail the various effects the undersea cable may have to fish, corals, seabirds, marine mammals, turtles, and humans.  Detail the strength of the electromagnetic field of the cable and onshore transmission line under maximum electricity loading at the following distances:  1 meter, 10 meters, 100 meters, 1,000 meters, 2,000 meters, and 3,000 meters.  Detail the effects electromagnetic radiation may have to breeding whales and other wildlife and to humans.  Your analysis should extend to the point on land where an existing transmission line is sufficient to handle your electricity/voltage loads.  On the North Shore, such transmission lines may exist at Mililani – on West O‘ahu, such lines are in place at Nanakuli.  Therefore, your disclosure and analysis of the electromagnetic fields and effects to humans and wildlife must extend all the way to Mililani or Nanakuli.  This is a social justice issue.  Don’t piecemeal the project into small components in your analysis – include the effects of the new transmission lines that would need to be constructed to get the wind energy to downtown Honolulu where the power is needed – the North Shore is already energy-independent – don’t curtail the effects analysis – disclose all of the adverse effects of the project to the affected public, legislators, DBEDT, and taxpayers.  Although the effects of the undersea cable are significant, these effects seem to be the only adverse effects that would occur if the purpose and need for the project were met with solar PV on Moloka‘i or Lāna‘i, or wind farms on Lāna‘i or Maui.  The undersea cable from an outer island could come ashore at Nanakuli, so adverse effects to neighborhoods of a new transmission line system would be avoided.

     X.            Federal Government Clouded Title to Right to Lease Hawaiian Ceded Ocean Lands

Native Hawaiians ceded the ocean lands to the Federal Government and those lands were never returned to Native Hawaiians – Native Hawaiians maintain rights to the ocean lands you are considering leasing.  Private landowners on land can lease their lands for wind development but our oceans are not for sale.  The Ocean is not for sale; please go work with willing landowners.

  XI.            Social Justice

We understand your applicant pulled young men out of the public meeting in Waianae to promise them jobs – yet what we actually see once these wind farms get developed is the full-time permanent staff are all skilled staff from the mainland.  If a lease for construction of wind turbines is confirmed for the Kae‘na Point site it could be yet another example of the developer buying (inexpensively) the support of the underprivileged community.  We watched as many members of the Kahuku community capitulated to support a wind farm that directly affects their school buildings at a price of only $10,000 per wind turbine per year.  A wind developer is offering a Maui community the equivalent of $15,000 per wind turbine per year for a proposed development there (http://www.mauinews.com/page/content.detail/id/600616/Testimony–Pros-and-cons-of-Kahikinui-wind-farm.html?nav=10).  In the case of this Kae‘na Point project, with very significant harm to so many people and communities, it’s likely the developer may buy the support of some, but there are too many who will be harmed too greatly – even if they paid us all of their estimated $5 Billion profit, we would be unmoved.  We would not wish a wind farm development on any community that did not want it.  This project, in this location, is unthinkable.  Your developer can pay all the money in the world to every wealthy person and every underprivileged person on O‘ahu – every person on O‘ahu could support this project, but that support will not mitigate the unavoidable and deeply troubling adverse effects this development would have at this location.

XII.            Serious Impacts to the Quality of our Surf Due to Wind Farm Structures Dissipating and Disturbing Surf Waves – West and North Ocean Swells

Standing alone, each component of our list of concerns seems reason enough to pursue a less harmful alternative to the proposed wind farm off Kae‘na Point.  The most deeply felt concern of many of our ‘Ohana, including our founder, who is a surfer, wind surfer, and tow-surfer, is the adverse effect the large floating structures will have to the clean powerful west swells that create some of our most epic, sought-after surfing conditions.  The North Shore has many of the very best, most famous, most heavily visited surf spots in the World.  The quality of the North Shore’s surf is of great national and international importance.  Our ideal surf is everything to many residents and visitors to the North Shore – it is the reason many of us live here.  North Shore surf season is driven by storms tracking from west to east across the Pacific Ocean (typically October 1 through May 1) and typhoons in the South Pacific (typically September through December) in combination with offshore winds.  We have worked very, very hard to live here and to protect our surf for our enjoyment and that of the rest of the World.  We are supportive of clean energy, but not if it will adversely affect the quality of our surf.  If you need to anchor large heavy floating structures offshore of O‘ahu, don’t do it in an area where it affects the size and cleanness of the North Shore’s surf.

The North Shore has seven miles of surf spots – the “Seven Mile Miracle” that would be adversely affected by a wind farm off Kae‘na Point.  In addition, Haleiwa, Kahuku, and Mokuleia surf spots on the North Shore, and many surf spots on the West side of O‘ahu would be adversely affected.  The quality and “cleanness” of surf at the following world famous surfing breaks on the North Shore would be among the most adversely affected because their most perfect conditions rely on clean swells from the southwest, west, and northwest direction: Haleiwa, Waimea Bay, Pipeline, Gas Chambers, Off the Wall, Rocky Point Lefts, Sunset Beach, Backyards, Velzyland, Kawela Bay (along with numerous lesser-known surf breaks also being affected).  On the West side of O‘ahu, surf breaks at Makaha and Ma’ili would see deteriorated surfing conditions if the proposed action is allowed because any type of North Swell hitting West O‘ahu would be reduced and disturbed by these many large heavy floating structures at sea off Kae‘na Point.

Pipeline, the most famous surf spot in the world, and one of the most perfect waves in the World, is located due east of your proposed wind farm (see map Figure 7) and the quality of this wave would be seriously affected by the proposed action.  People come to Pipeline from all over the world to surf this wave and to watch surfing.  It’s spectacular because it breaks very close to shore so visitors have front-row seats.  It’s a very special wave.  The December Billabong Pipe Masters contest is the final event in both the Van’s Triple Crown of Surfing and the final World Tour stop for the World Surf League – the winner of this contest crowns the Triple Crown and World Champion.  $500,000 in prize money is awarded at this “Pipe Masters” surf contest.  The Da Hui Backdoor Shootout surf contest and other world-renowned surf contests occur here because surf conditions are so ideal.  Pipeline is beautiful and perfect when it receives powerful long-period swells from the west (Figures 10-16).

The proposed offshore windmills have the potential to seriously negatively impact the quality of the waves we surf. The windmills could not only result in a decrease in the size of surf, but their floating features will result in a very large decrease in the quality of surf at many of the premier surf breaks on the North Shore of O‘ahu and the West side of O‘ahu.  The Oahu North portion of the “Oahu Call Area” for the proposed windfarm off Kae‘na Point extends many miles north of Kae‘na Point.  For Haleiwa, swells from the west all the way to the northwest would have to pass through the wind farm “call area” in order to reach Haleiwa.  For Waimea Bay and Pipeline, swells from the west-southwest to west-northwest would have to pass through the windmill farm “call area” before reaching those surf breaks.  For the Westside surfbreaks, such as Makaha and Ma’ili, almost all winter swells would have to pass through the windfarm “call area” before wrapping around Kae‘na Point into the Westside.

Figure 10.  West swell hitting Pipeline (Photo by Duncan, Surfing Magazine).

Figure 11: Local Pro surfers John Florence (Currently Ranked #1 in the World), Dusty Payne (Photos by Zak Noyle), and Derek Ho (Photo by Surfline) surfing perfect Pipeline.

Figure 12.  Pro surfers Nathan Fletcher (Photo by Zak Noyle) and Kelly Slater (local homeowner) and local Pro surfer Jamie O’Brien (photos by Brent Bielmann) surfing perfect Pipeline.

Figure 13.  Perfect Pipeline on a west swell (Photo by Mike Cianciulli, Surline).

Figure 14.  Members of Hui O He’e Nalu (Da Hui), a 300-member family of watermen founded in 1976 to work to assure local people’s rights to the ocean are not infringed upon.

Surfline.com explains the mechanics of Pipeline’s wave here:  http://www.surfline.com/surf-news/the-mechanics-of-pipeline_63340/.   See Figure 15.

Figure 15.  Pipeline surf break: west swell and typhoon swell from the southwest create Pipeline’s classic long, rideable “left” “tubes”; northwest swell offers wave faces on both Pipeline lefts and Backdoor rights; and north swell is ideal for Backdoor rights. (Photo by http://www.surfline.com/surf-news/the-mechanics-of-pipeline_63340/).

Figure 16.  Pipeline is perfect location for spactators (Photo by Sean Davey for Quicksilver and Surfline:  http://www.surfline.com/surf-news/the-mechanics-of-pipeline_63340/).

The ocean lease applicant for the northern “call area” (an entity called AW Wind Hawaii, LLC which is led by a Danish citizen, Jens [pronounced Yens] Peterson) proposes to build at least 51 floating windmills, and is clearly trying to reserve the option to build many more, possibly 100 or more.  Each floating windmill is proposed to be built on a patented “Wind Float” platform similar to the photo shown on the applicant’s application.  The photo on the application is of a single demonstration Wind Float windmill that was built in northern Portugal. The in-water portion of a floating wind structure is shown in Figure 17 (in shallow water, without anchors).

Figure 15: Diagrams of the under water portion of the Wind Float (shown in shallow-water example, without anchors) (Alpha Wind).

The Wind Float platform that was built in northern Po is anchored in water that is only 40 to 45 meters deep.  In contrast, the waters in much of the northern “call area” off Ka‘ena Point are about 1,000 meters (3,300 feet) deep.  That is 5 to 6 times deeper than anyone anywhere in the world has ever successfully anchored floating windmills, and more than 20 times deeper than the applicant’s demonstration Wind Float in Portugal.

The demonstration Wind Float in Portugal is anchored by four steel-cabled anchor lines that spread out in four directions.  The Wind Float itself consists of three large steel semi-submersible cylinders that have a diameter of 10 meters each (33-feet diameter each), and extend down more than 70 feet into the water.  The three cylinders are set in a triangle held together with various steel tubes and cross braces, and the windmill tower sits on one of the three cylinders.  The single demonstration Wind Float in Portugal has a 2.4 MW (megawatt) Vestas brand wind turbine.  For Hawaii, the applicant is proposing to use wind turbines in the 6 to 8 megawatt (MW) range.  As a result, the size of the Wind Float cylinders that would be needed in Hawaii will be even larger than the ones used in Portugal.

Even with the smaller size of the Wind Float in Portugal, the total cross section of steel for each Wind Float will be 99 feet (three times the 33-foot diameter for each cylinder). Each cylinder would extend more than 70 feet down into the water, and then connect to the anchor cables.  Even if only that smaller-sized Wind Float were built, and even if the applicant only built 51 of the windmills, that would mean a total metal cross section that waves will have to hit of about 1 mile.  (51 times 99 feet equals 5,049 feet, and there are 5,280 feet in a mile.)  If the applicant ends up building 100 larger sized Wind Float windmills (to accommodate the 6MW to 8 MW wind turbines it plans), then the total cross section of metal, that waves will have to hit, would be more than 2 miles.

Perhaps even more important than the one to two miles of total metal cross section that waves will run into, is the shape and configuration of the metal.  The portion of a wave hitting and passing through a single Wind Float will have three large 33-foot-diameter metal cylinders (or larger) in a triangular shape in relatively close proximity to each other.  As the waves hit a metal cylinder they will ricochet off in both directions laterally, and portions of the ricocheted wave energy will hit the other 33 foot cylinders almost immediately.  As a wave hits and passes by the cylinders, the interactions of the deflected energy will be very complex.  The deflected wave energy will soon move laterally (on an angle) enough to interact with deflected wave energy from the adjacent windmill in that row, as the diffracted waves wedge into each other (Figure 18).  In addition to at least some net loss of swell energy reaching the world famous North Shore surf breaks and the Westside surf breaks, there is likely to be a very a significant increase in the messiness of the swell energy (in other words, a decrease in the “cleanness” of the swell energy that surfers want) as it hits and passes through the Wind Floats.

Figure 16.  Diffraction of waves as they move past structures (Images NOAA and geology cafe.com).

The problems with the decrease in “cleanness” of the wave energy, and increase in the messiness from the random deflected waves, will further increase as the wave and swell energy passes through the next row of Wind Float windmills.  We support clean energy, but not at the cost of harming our surf.  We are particularly concerned you will pay consultants to try to convince us the effect will be insignificant.  We are also aware of the $Billions in profit your developer stands to make if this project and the lengths wind farms go to buy support from local communities and businesses.  We want to make BOEM aware that the recent commercialization of surfing and the surfing industry’s focus on profit may afford your applicant opportunities to engage with receptive partners who may come to support wind farm development while residents will not.  Please coordinate closely with us in your selection of fluid dynamics engineering consultants and meteorologists to best ensure the framework for your analysis and the results of your analysis are consistent with those of the engineers and meteorologists we will engage to assist us in this effort.

The potential for this project to adversely affect our surf conditions is very troubling to many in our community and if for no other reason than this one, we will utilize every means available to ensure this Kae‘na Point wind farm is not constructed.  If you towed the wind farm structures away and removed the anchor lines so they’re not in the water column October 1 through May 1 period, the project’s adverse effects to our surf would be almost entirely eliminated.  If this mitigation action can’t be incorporated into the project design to protect the quality of North Shore surf, the proposed action must not proceed.  E mālama nalu.

XIII.            North Shore Has Done Our Part – Discussions Regarding North Shore Bid to Secede from Honolulu County

Downtown Honolulu and Waikiki are constructed with high-density commercial and residential structures so they have energy needs that exceed their local production capacity.  The North Shore produces more solar PV and wind energy than we need to meet our electricity needs.  We have done our part – listen to our North Shore Neighborhood Board and our residents – we have had enough and we will not allow another wind farm to blemish our viewplane, our wildlife, our ocean, our surf.  E mālama nalu.  Most of us used to ignore discussions by members of our community who point out that the North Shore would be better cared for if our area were a separate County.  Because of this Kae‘na wind farm, a number of us are now taking this option into serious consideration.  If we were a separate county at least we could pass laws against the gigantic transmission line crossing our lands.  We feel like urban Honolulu could support your proposed Oahu North site because it may be the cheapest solution rather than the solution that is acceptable to all of Oahu.  We want solar with grid-level battery storage.

XIV.            Albatross, ʻIwa Bird, endangered bats, Kaʻena seabirds, and Kauai seabirds

We thought wind development offshore from Ka‘ena Point and Kauai would never receive any type of serious consideration because Ka‘ena Point and Kaua‘i are such important seabird conservation areas.  Some seabird species are protected by endangered species laws, but others, such as the albatross, wedge-tailed shearwater, and ‘Iwa bird (after which Hale‘iwa is named… house of the ‘Iwa) are not – ensure you address adverse effects to all seabirds and ocean life and explain how you will compensate for any adverse effects to all wildlife species.  Because the wind farm will kill endangered birds and bats, BOEM must complete a State of Hawai‘i Habitat Conservation Plan to obtain an incidental take license for take of the endangered animals.  BOEM should not authorize construction of any vertical structure at sea until the Habitat Conservation Plan is approved by the Board of Land and Natural Resources and the Incidental Take License is in hand.  Without the Incidental Take License, the applicant would not be able to bring the powerline into State waters, and would need all components to remain three (possibly 15, depending on interpretation) miles offshore.  But-for the powerline, the endangered species take will not occur – if the powerline were not constructed in State of Hawai‘i waters, the wind turbines have no utility – they would not be built.  Your applicant should be provided with guidance regarding your obligation to not make irretrievable commitments of resources prior to obtaining the Incidental Take License from the state of Hawai‘i.  Habitat Conservation Plans take several years to complete – three years seems a very ambitious timeline.  The BA, EIS, and HCP should detail how the proposed compensatory mitigation will benefit the threatened and endangered species and the species protected under the Migratory Bird Treaty Act.  Explain the evidence you used to confirm the compensatory mitigation assures a “net benefit” to these species; reliance on the methods used by less controversial wind farms on land to compensate for adverse effects to migratory birds, bats, and threatened and endangered species have not been scrutinized with the same level of public concern this Ka‘ena at-sea wind farm will be.  For the Ka‘ena wind farm project, assess and report post-construction mortality of migratory birds and threatened and endangered species with no less than a 90% level of assurance or certainty.  Provide a thorough description of how mortality will be monitored accurately at the offshore wind farm.  These species are important to us, so we would like to know, with 90% certainty, that the level of mortality you are reporting to us is an honest evaluation of the level of mortality occurring.  Ensure the benefits of your compensatory mitigation projects are measured and reported with this same scientifically valid level of confidence.  We recommend the following measures to minimize and compensate for mortality of our threatened, endangered, and migratory bird species associated with the Oahu North Ka‘ena Point wind development:

Compensate for adverse project effects to albatross and wedge-tailed shearwater by ensuring the Kae‘na Point predator-proof fence is maintained and the area is kept predator-free during the 50 year term of the wind development.  Funding for fence replacement should be kept in an escrow account naming DLNR as the beneficiary.  The original fence construction cost approximately $1 Million and the fence may be due for replacement about when your project starts.  Plan to replace the fence every 10 years ($5 Million total for fence replacements).

The Hawaiian hoary bat is likely to be killed by the proposed 50-year wind farm operation in the Ka‘ena Point area where bats traverse the ocean between Kaua‘i and O‘ahu.  The death of a strong bat traversing between islands would have a far greater effect to the Hawaiian hoary bat species than a local bat killed at its territory on land.  The future genetics of the species may be affected by the proposed project.  Install bat deterrent technology on every wind turbine structure to minimize the potential for bat take.  Bat flight is primarily limited to light wind conditions, when wind speeds are less than 6.5 meters/second.  Therefore, the turbine blades should only be engaged when wind speeds are higher.  Curtail (feather blades to not catch the wind) when wind speed falls below 6.5 meters/second to minimize mortality of the endangered bat.  Ensure your studies, during your three to five-year study period, are sufficient to confirm the compensatory mitigation you propose to offset take of the bat will increase bat numbers to offset any anticipated take of the bat.  For example, studies such as research regarding the effects predators have to breeding bats could enable you to propose predator control in bat breeding areas to increase bat numbers to offset at-sea bat take.  Studies of differences in bat numbers in disturbed versus native habitats could enable you to propose habitat restoration to compensate for bat take.

Likewise, during the three to five years of project planning, study the ‘Iwa bird in sufficient detail to understand the level of take you anticipate, in addition to understanding enough about its ecology to design a conservation project to compensate for the take of the species.  In addition, explain why you are situating an experimental at-sea wind project smack in the middle of Kaua‘i (the largest remaining population of Newell’s shearwaters) and Ka’ena Point (the largest albatross population on the main high Hawaiian islands) in a sensitive ocean environment where upwelling of deep ocean waters results in high productivity and high densities of birds.

With respect to the cable construction, we see a risk the project itself could be piecemealed – the developer could reduce their current proposed project and install a small number of wind turbines, maybe just two turbines in the farthest location from shore in the least hated location in the Oahu North area.  Then, once the adverse effects of the power cable’s landing on shore are addressed and the take of endangered species is authorized and the value of property has already been reduced, many additional turbines, which would have much greater environmental impact, could be added with less resistance from the public and possibly without any additional requirements pursuant to HRS 195D.  Therefore, ensure any BOEM permit decision include all future effects from the cable’s development including any wind development within the Oahu North area and any at-sea energy development off the North Shore.  Disclose to us all of the development upfront, rather than allowing additional wind turbines to be added in the future.  Don’t allow the developer to implement an action that could enable implementation of a future action that is not disclosed to the public and the EPA up-front.

XV.            There Are Likely to be Many Other Important Cultural Sites and Rituals Not Addressed Here

We understand Thomas Shirai hoped to bring you out to Ka‘ena during your agency’s July 2016 visit, but your trip was rained out.  We hope you will gain respect for the Leina a ka `Uhane white rock limestone soul passage formation and you will remove sites within in view of the formation from further at-sea wind development consideration.  Most people we talk to about this proposed action are surprised and have not heard about it.  You may have done your legal minimum required outreach to get information to the public regarding the need for them to step up now if they would be affected by the proposed action, but that information has not been widely broadcast on the television or print news – it seems like no attention has been given to this project and most of the parties who would endure significant irreparable adverse effects know nothing about it.  There are difficulties inherent in the Native Hawaiian’s lack of Federal Recognition and lack of unification that complicate your aim to assure information is adequately disclosed and voices are heard.

XVI.            Humpback whales, endangered Hawaiian monk seals, threatened Honu

Include an assessment of the harm the project will do to threatened and endangered ocean life including humpback whales, Hawaiian monk seals, and Honu, and specify the actions you will take to compensate for these effects.  Address the effects of these threatened and endangered species pursuant to HRS 195D in a Habitat Conservation Plan that assures a net benefit to the species.

XVII.            Deterioration of Support for State Clean Energy Goals

We are concerned wind farm development at this site could ultimately result in an uprising in opposition to the State’s clean energy goals.  Assess the effect proceeding with consideration of wind turbine development off Ka‘ena Point will have to the public’s support for Hawai‘i’s clean energy goals.  We are so disgusted you would consider wind turbines in this location that we would rather press our legislators and Governor to reduce Hawaii’s clean energy goals than see this project move forward.  Assess the effect the wind farm will have to climate change factors including sea level rise, temperature, and energy independence.  Tell us how the wind farm would reduce climate change and reduce electricity costs in exchange for disposing of the rights of Native Hawai‘ians, residents, and ocean users.  Detail the carbon footprint associated with construction, transportation, installation, and maintenance of the at-sea turbines in comparison to solar and biofuel alternatives.

If a wind farm in the waters off Ka‘ena Point is necessary to meet the State’s clean energy objectives, then reduce those objectives so a wind farm off Ka‘ena is no longer needed to meet the goals.  If you do ever hope to develop wind energy at this Ka‘ena site, it might be wise for your developer to withdraw their lease application or for you to find a way to withdraw this site from consideration for now, and, years from now, once the reasonable alternatives have been tapped, only then should you come to the public with any development at this extremely sensitive and controversial site.  Attempting to move forward with wind farm development at this site, now, seems to be a lose-lose situation for everyone.

XVIII.            National Marine Sanctuary Nomination

In BOEM’s July 21, 2016, public meeting introductory presentation, your public relations specialist indicated if the waters off Kae‘na Point were designated a National Marine Sanctuary, you would remove it from consideration for wind farm lease development.  We have coordinated with NOAA and we understand we can specify the important existing cultural practices, spiritual rights, fishing, boating, wildlife conservation, unobstructed view, unobstructed surf, and other aspects of the area and the Sanctuary would be managed to conserve these existing rights and uses.  We are coordinating with cultural, environmental, business, and community groups to draft a nomination of the site as a National Marine Sanctuary to assure exiting rights to remain intact.  However we hope your applicant has developed a respect for our people and our environment as a result of the information you have received during this “scoping” period and they respectfully withdraw their lease application.  If the applicant decides to move forward with studies to address the public’s concerns regarding the wind farm, please send us copies of the annual and final reports, data, and information obtained in the studies to help inform our National Marine Sanctuary nomination.

XIX.             Summary

In summary, we strongly oppose at-sea wind farm development in the ocean waters off Ka‘ena Point.  If the proposed wind farm were to be constructed, O‘ahu kānaka maoli would see the wind turbines during the day and at sunset or, at night, bright blinking industrial lights as they travel toward the Leina a ka `Uhane in their last moments of life.  This one harm, standing alone, is reason enough your applicant should respectfully withdraw his lease application.

The proposed Oahu North wind farm would also  bar us from important fishing grounds, contaminate our ocean, and kill our wildlife, whereas our preferred alternative – solar PV with battery storage – would have none of these harmful effects.  Placement of one mile to over two miles total cross-section of these proposed submerged metal wind float cylinders reaching more than 70 feet of water depth will cause ocean waves to ricochet and become less organized as the move across the giant floating structures.  This site selection, due west of the North Shore is completely unacceptable because so many of our people’s lives, in addition to our North Shore economy, center around surfing clean powerful west swells.

The wind turbines will be visible by day; they will ruin our sunsets, and we’ll have to look at blinking red lights in our ocean.  This picturesque view of Ka‘ena Point is one of the most beautiful scenes in the world at sunset – it should not be developed into an industrial complex, especially when there are many less harmful alternatives available.  Harm to our surf and our view will reduce our quality of life and, just when we decide to move because we’ve found ourselves living in an industrial landscape, we’ll find our property values are less than they would have been – because the reasons we want to move are the same reasons others will chose not to move here.

One of the reasons for Hawai‘i to move toward clean energy was to reduce our dependence on imported oil – so we wouldn’t have to lose so much of our State GDP offshore.  The profits from this wind development would go to a Danish company.  All things considered, we would rather burn oil than see this wind farm go up – we care about clean energy, but not at the cost of so much to so many.  We believe any purpose or need you may have for a wind farm in our ocean could be met, without these adverse environmental and cultural effects, with our on-island installation of solar and utility-scale battery storage.  The solar alternative would keep $2.8 to $5.6 Billion in our local economy, rather than seeing profits go to overseas investors.  Landowners including Kamehameha Schools, residents, and businesses in Hawaii are being blocked from installing solar PV – while you consider authorizing development of this egregious project – ‘A‘ole!  We believe solar PV with battery storage is the environmentally superior alternative.

We urge you not to proceed with authorizing the proposed wind farm in the waters off Ka‘ena Point for various reasons outlined in this letter demonstrating that this proposal violates the National Environmental Policy Act, and less harmful alternatives such as solar energy are readily available.  We recommend you partner with the Department of Energy to develop a solar PV with battery storage alternative to the wind farm project or choose from the many other less harmful green energy alternatives. Thank you for this opportunity to provide you with our preliminary concerns about the project. Please feel free to contact us at malamanaluohana@gmail.com if you would like additional information about our suggestions.

XX.            CC and Signatures

CC:  Dr. Ernest Moniz, Secretary of the U.S. Department of Energy, The.Secretary@hq.doe.gov (Thank you for your ongoing efforts to help Hawai‘i meet our clean energy targets.  Please assist BOEM with their development of onshore alternatives to their proposed Ka‘ena Point at-sea wind farm, such as solar PV with battery storage).

CC:  Alexis Strauss, Acting Regional Administrator, US EPA Pacific Southwest, Region 9, 75 Hawthorne St., San Francisco, CA 94105 (Please enforce NEPA).

CC:  Dr. Christy Goldfuss, Managing Director, Council on Environmental Quality, 722 Jackson Place, Washington D.C. 20006 (Please assist DOI/DOE cooperation to address a solar PV with battery storage alternative).

CC:  Our receptive friend in Congress, Representative Tulsi Gabbard, 300 Ala Moana Boulevard, Room 5-104, Honolulu, HI 96850.

CC:  Senator Brian Schatz, 300 Ala Moana Boulevard, Room 5-104, Honolulu, HI 96850.

CC:  The Honorable David Y. Ige, Governor, State of Hawai‘i Executive Chambers, State Capitol, Honolulu, Hawaii 96813

CC:  Our advocate, State of Hawai‘i Senator Gil Riviere, Hawaii State Capitol, Room 217, 415 S Beretania St, Honolulu, HI 96813.

CC: Our advocate, Representative Lauren Kealohilani Matsumoto, Hawaii State Capitol, Room 303, 415 S Beretania St, Honolulu, HI 96813.

CC:  Our advocate, Honolulu City Council Chair & Presiding Officer Ernie Martin, City and County of Honolulu, Honolulu Hale, Room 203 Honolulu, HI 96813.

CC:  Honolulu Mayor Kirk Caldwell, 530 South King Street, Room 300, Honolulu, Hawaii 96813

Appendices:  Our letter summarizes a subset of the concerns our community has with the proposed action and we provide a subset of environmentally superior alternatives to the proposed action.  Opponents of the Ka’ena (Oahu North) wind farm development represented herein include the fifty-five community groups and individuals who have joined us in signing this letter, in addition to over 500 members of the affected communities voicing concerns via facebook and the 317 people supporting our Change.org petition online.  The Change.org petition letter is a previous version of this letter.  Almost all of these opponents expressing opposition to the wind farm on facebook and Change.org are local – from the North Shore and West O‘ahu communities.  Facebook comments and a list of individuals opposing this wind farm on facebook, and the Change.org petition with comments and signatures are appended to below.