Here We Go Again: Another Faulty Army EIS Threatens Oʻahu Lands

Last month, the Board of Land and Natural Resources (BLNR) rejected the US Army’s Final Environmental Impact Statement (FEIS) for continued use of public lands at Pōhakuloa Training Area on Hawaiʻi Island. Their decision cited numerous serious flaws — including a lack of cultural surveys, outdated or missing biological data, and no meaningful analysis of environmental impacts on surrounding areas.

Just weeks later, the Army submitted another FEIS — this time for lands it leases on Oʻahu in Mākua Valley, Poamoho, and Kahuku. This kicked off a 30-day countdown for the BLNR to accept or reject the report, with the final decision coming up this Friday, June 27.

Disappointingly, but not surprisingly, this Oʻahu FEIS is also replete with legal flaws—so much so that nearly all of the Department of Land and Natural Resources' divisions (Water Commission, Aquatic Resources, Forestry of Wildlife, Conservation and Coastal Lands, Historic Preservation, Land) found it deficient. As a result, the Land Division is recommending that the BLNR REJECT this faulty document. 

What’s Wrong With This FEIS?

Here are just a few of the many serious concerns raised:

• Reliance on outdated biological surveys, with no current baseline information; 

• No standards or status updates for impacts to native and endangered species and any needed mitigation work;

• No stream surveys as requested by the Division of Aquatic Resources;

• A lack of needed surveys for historic sites and cultural resources;

• The omission of published moʻolelo in the EIS' cultural impact assessment;

• A lack of consultation with key cultural knowledge keepers;

• A lack of sufficient information to conduct a Ka Paʻakai analysis of impacts to constitutionally protected Native Hawaiian traditional and customary practices;

• Insufficient information on potential contamination sources to determine impacts to groundwater;

• Inconsistency of planned uses with conservation district and forest reserve regulations, and no plan to pursue compliance with Hawaiʻi's land use laws; and

• A lack of concrete proposals to remediate and clean up lands that may be relinquished back to the "state."

Most of these concerns are not new — they were raised repeatedly by DLNR staff and the community, and many are substantially similar to those cited by the BLNR in its rejection of the Pōhakuloa FEIS. Yet the Army still submitted this FEIS in blatant disregard of the feedback of DLNR staff and the community as well as Hawaiʻi’s environmental and land use laws.

Now’s the Time to Speak Up

The BLNR has a clear choice: Reject this inadequate EIS and uphold their responsibility to protect Hawaiʻi’s lands, waters, and cultural heritage consistent with the public trust. You can help.

Submit testimony this by Thursday, June 26 and attend the BLNR meeting this Friday, June 27 at 9am — either in person or online. Make sure to spread the word for others to do the same!

How to Submit Testimony:

Written Testimony:
Email your statement to: blnr.testimony@hawaii.gov
Subject line: Testimony on Agenda Item D-1

To testify live (via Zoom or in person):
Request a Zoom link by emailing blnr.testimony@hawaii.gov, include your name and email
Or show up in person: Kalanimoku Building, Conference Room 132
1151 Punchbowl St., Honolulu, HI 96813

Sample Testimony:

To: blnr.testimony@hawaii.gov
Subject: Testimony on Agenda Item D-1

Aloha Chair Chang and Members of the Board of Land and Natural Resources,

My name is ______ and I strongly urge you to REJECT the Army’s legally deficient Final Environmental Impact Statement (FEIS) for the retention of lands on Oʻahu.

Many of the same concerns the Board raised in its rejection of the Pōhakuloa FEIS — including the lack of cultural and biological surveys, inadequate cultural consultation, and unaddressed land use compliance issues— are found again in this document. This FEIS also fails to address stream impacts, potential groundwater contamination, and necessary land remediation plans.

Accepting this FEIS would signal that our environmental laws, the public trust, and Native Hawaiian rights can be disregarded with no consequence. 

Please uphold your trust responsibilities, the mission of your department, and the laws that protect our ʻāina and our future. Reject the FEIS.

Mahalo nui for your consideration.

Sincerely,
[Your name]