October 7, 2020
Subject: Comments of the Surfrider Foundation on the Department of Land and Natural Resources’ Kāʻanapali Beach Restoration and Berm Enhancement Draft Environmental Impact Statement, Lahaina, Maui, noticed August 23, 2020
To Whom It May Concern:
On behalf of Surfrider Foundation and the Maui Surfrider Foundation Chapter, we submit the following comment letter regarding the Draft Environmental Impact Statement (DEIS) for Kāʻanapali Beach Restoration and Berm Enhancement (“Project”). The Surfrider Foundation is a non-profit grassroots organization dedicated to the protection and enjoyment of our world’s ocean, waves, and beaches for all people. Surfrider Foundation maintains 90 active chapters worldwide, including 5 chapters within the Hawaiian Islands Region.
While the Surfrider Foundation appreciates that this project is not proposing shoreline armoring, we have a number of concerns with the proposed beach restoration. Given the size and scope of the project, we are furthermore concerned about the precedent that this type of project will set for other high-erosion coastal areas throughout Hawaii, particularly without the proper evaluation and inclusion of a managed retreat plan. Without more careful consideration and analysis of the following concerns, Surfrider Foundation cannot support the proposed Project.
Concern #1: Lack of evaluation given to the alternative of “Managed Retreat”
The DEIS section 5.2 No-Action Alternative and Deferral of Action Alternative outlines the No-Action Alternative and includes the alternative of “Retreat”. We take serious concern with the minimal evaluation of the “Retreat” option within the Project’s DEIS. For example, of the Project’s 427 page DEIS, only one page was dedicated to evaluating the option of “Retreat” and fails to present the long-term benefits of managed retreat. A more careful and detailed analysis of managed retreat (e.g. costs, benefits to the environment and community, and potential impacts) needs to be developed before this project moves forward. If large-scale beach renourishment is to occur, it should only occur in conjunction with (not in favor of) a holistic, managed retreat plan.
Furthermore, though Surfrider Foundation gives preference to beach renourishment (e.g. “soft armoring”) over “hard armoring,” the acceleration of sea level rise and chronic erosion events warrants that the state of Hawaii and this Project provide a more formal evaluation of managed retreat options. To clarify, coastal erosion is NOT a problem for beaches – it is a problem for buildings. As the state of Hawaii has recently acknowledged:
“Stated frankly, beaches and coastal development may not be able to coexist in a future with sea level rise. Now that we’re beginning to see this first-hand, perhaps it’s time to step back and consider where we are going, what we are doing, and what is really at stake.”
(Office of Conservation Coastal Lands Staff, https://climate.hawaii.gov/hawaii-beaches/, July 17, 2020)
The Project DEIS additionally fails to adequately acknowledge that beach renourishment is not a long-term solution to beach erosion. While the proposed project has an estimated lifespan of up to “20 years” (DEIS pg. 12), beach renourishment often needs to occur as often as every two to ten years. Simply stated, beach renourishment is a short-term “band-aid” rather than a long-term, holistic solution. For example, in referring to a 2008 storm event, the Project DEIS itself states:
“… damage occurred quickly, with no time to implement an emergency response, further highlighting the Kāʻanapali shoreline’s vulnerability to extreme wave events.” (Project DEIS pg. 6)
It is disingenuous to acknowledge Kāʻanapali shoreline’s vulnerability to extreme wave events on the one hand, while proposing a short-term project that will in no way reduce the long-term vulnerability of shoreline structures. The ongoing situation at Waikiki Beach on Oahu further highlights the variable nature of beach renourishment projects.
“The beaches in Waikiki have been maintained only through semi-regular nourishment and construction of a myriad of erosion control structures, including groins and breakwalls.” (Beach Restoration in Hawaii: Challenges and Opportunities, 2014 https://bit.ly/3jAL1dC)
Chronic erosion and sea level rise are both clearly documented along Maui’s shorelines, particularly along Kāʻanapali Beach. To propose that a one-time sand renourishment project will mitigate either of these issues for the long-term is short sighted and provides a false sense of security. The situation at Kāʻanapali also raises serious questions regarding the validity of the proposed project’s estimated 20 year lifespan and, again, requires a more thorough review of a managed retreat option.
Without a holistic plan to relocate the coastline structures (e.g. boardwalk and resorts) further from the ocean, we will be in the same situation in the near future. The lack of fully evaluating a managed retreat option within the Project’s DEIS furthermore prioritizes tourism and short-term solutions over community interests and long-term concerns. Lacking a comprehensive plan to relocate the shoreline structures, Surfrider Foundation finds serious fault with, and cannot support, the currently proposed renourishment project.
Concern #2: Lack of comparison between the proposed project and other large-scale beach renourishment projects
Currently, the DEIS only evaluates 3 alternatives: 1. Temporary Shore Protection, 2. Permanent Buried Shore Protection, and 3. Adaptation. The DEIS basically presents an all or nothing approach, and does not include a “middle-of-the-road” alternative that would assess a smaller scale version of the renourishment proposal, nor does it fully evaluate a managed retreat alternative (see Concern #1 above).
In terms of cubic yards of sand, the proposed Project (~75,000 cubic yards of sand) would be the largest beach renourishment project on Maui and second in the state only to the Iroquois Point restoration project on Oahu (~100,000 cubs yards of sand). It should be noted that the Iroquois Point project also required the construction of nine T-Groins to stabilize the sand that was dredged from the Channel at Pearl Harbor. In comparison, the 2012 Waikiki Beach Restoration Project recovered 27,000 cubic yards of sand from a channel on the nearshore reef using a hydraulic suction dredge. A smaller, privately funded project in 2010 nourished Sugar Cove on Maui with 2,886 cubic yards of sand hydraulically dredged from an offshore sand field.
Needless to say, the proposed Project at Kāʻanapali represents a significant dredge-and-fill project, not only for Maui County, but for the entire state of Hawaii. The environmental, cultural, and recreational impacts of removing and relocating 75,000 cubic yards of offshore sand are likely understated in the DEIS and there are few – if any – similar projects in terms of size and scope in Hawaii. Not only should a more thorough comparison be completed between the proposed Project and other similarly sized projects, but the DEIS should further evaluate an alternative that is smaller in both size and scope.
For example, a middle-of-the-road approach may include a smaller-scale renourishment project that is only implemented at “emergency level” erosion hotspots. In the meantime, DLNR could reallocate some of the project construction funds to develop a proactive management plan and seek federal funding opportunities for transitioning development out of the coastal zone. The DEIS needs to carefully consider other alternatives before determining that the current Project proposal is the best solution.
Concern #3: Failure to fully evaluate the project’s impact on ocean recreation activities, specifically surfing and bodyboarding.
Surfing and wave sports are not only a public resource that should be protected, but also native Hawaiian traditions and customary practices. It should additionally be noted that within the framework of the National Environmental Policy Act (NEPA), a “surf spot” is considered a “natural cultural resource.” Given the above, and due to the fact that every beach is not a suitable surf-break, it is imperative to protect Maui’s existing surfing and bodyboarding breaks, including year-round breaks at Hanakaʻōʻō Point and seasonal spots at the north end of Kāʻanapali Beach.
The DEIS recognizes surf breaks located on the reef offshore Hanakaʻōʻō Point and the north end of Kāʻanapali Beach, which is also used as a bodysurfing, bodyboarding, and skimming site. (DEIS pg. 113). Additionally, there is a “short-lived” winter swell surf spot that may form along the outer edge of the sandbar with waves extending as far south as the Kāʻanapali Beach Hotel that is in the project area (DEIS pg. 113).
The DEIS states there is “the potential for the proposed project to initially have some impact on surfing at Hanakaʻōʻō Point,” (DEIS pg. 117) but maintains that “the beach restoration and berm enhancement project are expected to have no effect on surfing after the first southern swell season.” (DEIS pg. 117).
However, massive dredge-and-fill projects have been demonstrated to do serious and sometimes irreparable harm to beaches, surf-breaks, and reefs. As described by a 2018 research paper, beach nourishment projects have been found to:
“…adversely affect the quality of surf breaks by (1) compression of the surf zone, (2) an increase in the occurrence of “close-outs,” (3) a shift in breaker type toward collapsing breakings, particularly during high tide, and (4) an increase in wave reflection.” (Dally & Osiecki, 2018).
Dally & Osiecki further conclude that at the New Jersey study site, it will take (at a minimum) 21-22 months for the surf-break quality to return to pre-project conditions.
While the DEIS acknowledges that the Project will “initially have some impact on surfing at Hanakaʻōʻō Point” and acknowledges undesirable wave reflection for the “first few swells of summer surf season,” it fails to detail the modeling that was used to reach this conclusion or to compare the Project’s impact on surf-breaks to other, similarly sized renourishment projects in surf-break areas. Furthermore, just because the DEIS concludes that a wave will continue to “break” at Hanakaʻōʻō Point post-renourishment does not mean that the wave will retain characteristics of a “surfing wave” (e.g. does not “close out,” etc.).
Suitable surf-breaks are dependent upon specific bathymetric and sand transport requirements. Due to these specific requirements, not every beach or every wave is suitable for surfing. In addition, surf-breaks can change quickly in response to large storm waves or the influx of a large quantity of sand as occurs with a beach nourishment project. These spatial and temporal variations can improve or degrade the surfing conditions along a reach of coastline.4 While in theory, time and normal storm activity will eventually equilibrate the nourished beach to the shape of the natural pre-nourished beach, the adjusted profile is based on many factors that are still unknown – including how the sand used to renourish the site will behave in response to wave, wind, and tide forces. The American Shore & Beach Preservation Association additionally stresses the need for renourishment projects to assess the long-term morphological changes associated with increased (in the case of beach nourishment projects) sediment transport into the surfing area4.
With these factors in mind, we find the DEIS lacking in both its short- and long-term analysis of the impact of 25,000 cubic yards of offshore sand on the Kāʻanapali surf breaks, along with the additional 50,000 cubic yards of offshore sand deposited along a mile stretch of Ka‘anapali Beach. We therefore request a more detailed modeling and analysis of the full impacts of the proposed Project on surfing and bodyboarding breaks along Kāʻanapali Beach.
In addition, the American Shore & Beach Preservation Association highlights that an integral part of beach renourishment projects is “…the inclusion of surfing interests early in the project evaluation and planning.”4 Though Surfrider Foundation is acknowledged in Appendix C., to the best of our knowledge, no surfing interest, including Surfrider Foundation, have been contacted with respect to this Project. We did not receive email communications or outreach from project consultants. Our concerns have therefore not been reflected within the DEIS nor in scoping meetings. We request a more inclusive process, one that more fully incorporates the surfing, bodyboarding, and ocean recreation communities.
Concern #4: Failure to fully evaluate environmental impacts and detail post-project monitoring
The current DEIS fails to fully evaluate the Project’s environmental impacts. For example, the DEIS states that “the documented structure of the marine communities indicates that within the nearshore area where waves regularly break, the physical habitat is either sand or a flat barren limestone bench with essentially no benthic community, with no corals present” (DEIS pg. 99). On the contrary, the high energy surf zone and intertidal wave environment is a well known and important habitat for various marine animals, including ghost crabs. Knowing the importance and reality of the intertidal surf zone’s ecology, a more robust evaluation and documentation of intertidal biology should be conducted and presented.
In addition, the DEIS incorrectly states that “none of the Hawaiian sea turtles is known to nest in the project vicinity” (DEIS pg. 103). Local marine biologist Cheryl King, however, has documented green sea turtle hatchlings in the area, indicating that nesting could be present in the area. Furthermore, there is a lack of sea turtle monitoring in the area. Therefore, the more accurate conclusion to draw is that additional monitoring (both pre- and post-project) is required to ensure that impacts to green sea turtles and other sea turtle species are truly minimized. This monitoring should be included within the DEIS and as a condition of the project.
The DEIS also fails to recognize that in addition to humpback whales and Hawaiian monk seals, dolphins (odontocetes) are present in and around the Kāʻanapali Project area. Odontocetes, including Hawaiian Spinner Dolphins and Pacific Bottlenose Dolphins, are federally protected through the Marine Mammal Protection Act (MMPA). And while the Project monitoring plan outlines how trained observers will be used to monitor endangered species (e.g. whales and turtles) in the area during construction, it seems to limit observers to “30 minutes prior, during, and 30 minutes post daily activities” (DEIS pg. 184). However, owing to the highly transient nature of turtles, dolphins, whales, and monk seals in the area, observers should be permanently stationed during the Project’s construction, including at nighttime when wildlife may enter potential hazardous construction areas. Observations for ESA listed animals and other wildlife should not be limited to set increments of time.
Finally, there is no detailed plan for post-project monitoring of ecological impacts. In fact, post-project monitoring is limited to a single page and only details monitoring of the beach profile. The monitoring does not detail monitoring of benthic communities, endangered species, coral reefs, marine mammals or beach ecology. A monitoring plan that documents local marine and beach ecology before, during and after the proposed Project needs to be clearly detailed and outlined, especially given the fact that the proposed Project will span nearly one mile of sandy, intertidal beach.
In conclusion, Surfrider Foundation and our supporters have serious concerns about the short- and long-term impacts of the proposed project, as well as the kinds of minimization and mitigation measures proposed.
However, as a final note, we were especially pleased that the public scoping meeting included a question and answer session during which DLNR’s Office of Conservation and Coastal Lands Administrator provided substantive responses to community concerns. Too often such hearings are one-sided presentations or merely provide a platform for concerned persons to speak without receiving any responses. We hope the Administrator’s effort to respond to public questions will be repeated in DLNR’s future environmental review meetings as well.
Thank you for considering our comments. We look forward to a fuller disclosure of the environmental and surfing impacts of, and alternatives to, the proposed project in future environmental review documents.
Hawai‘i Regional Manager