Pōhakuloa - What’s Next?
May 15 update:
Last Friday, more than 1,300 written testimonies and seven hours of public comment were presented to the Board of Land and Natural Resources (BLNR), nearly all in opposition to the US Army’s deficient Environmental Impact Statement (EIS) for its proposed “retention” of state “ceded” lands at the Pōhakuloa Training Area on Hawaiʻi Island.
In response, the BLNR voted 5-2 to reject the EIS.
This is a major victory—for our ʻāina, our public trust, our communities, and our future. And it would not have been possible without people like you speaking out and taking action. Mahalo nui to everyone who submitted testimony, activated your friends and family, and stood in solidarity—whether in person or on Zoom—for a long and important day.
The BLNR’s motion to reject the EIS included a long list of deficiencies the Army must address, if it chooses to resubmit a revised EIS to “retain” these lands, including:
A Ka Paʻakai analysis and consultation log of cultural experts consulted
A full biological opinion on endangered species impacts
An unexploded ordnance and depleted uranium inventory
Greenhouse gas data
An analysis of cumulative impacts
A detailed inventory of the disposition and future disposition of iwi kūpuna and moepū
A clarification of whether section 106 consultation is required by law
A justification for narrowing the area of influence (to only state lands) or an assessment of impacts for the total impacted area, including adjacent federal lands
Serious consideration of the “no action” alternative
A consideration of conservation district land use restrictions and regulations
So what happens next? That largely depends on what the Army chooses to do. If it wants to continue pursuing “retention” of these lands, it could appeal the BLNR’s decision, or try to address the deficiencies identified by the BLNR with a revised EIS. Beyond that, the Army would also need to petition the BLNR to change its conservation district rules or ask the Land Use Commission to remove the area from the conservation district. A valuation of the lands at issue, a mechanism for retention (e.g., lease or fee acquisition), and negotiations with the BLNR are also among the steps the Army will need to take.
Notably, we can also anticipate the submission of additional EIS for land “retention” proposals on lands leased to the Army on other islands, including at Mākua Valley, Poamoho, and Kahuku Training Area on Oʻahu, and at the Pacific Missile Range Facility on Kauaʻi.
Want to learn more about what may be happening with regards to Pōhakuloa, and the expiring military leases for lands across the islands? You’re in luck! Mark your calendars for next week Thursday, May 22 at 6:00 pm, when we will be hosting a virtual panel of legal experts to unpack the BLNR decision, and answer questions about the “next steps” described above.
In the meantime, take a moment to breathe and celebrate this victory — and know that your voice helped to uphold the integrity of our bedrock environmental review law, the public trust, and our beloved ʻāina itself.
Protect Pōhakuloa - Info and Action
May 6, 2025
This Friday, the Board of Land and Natural Resources (BLNR) will decide whether to accept or reject the US Army’s Final Environmental Impact Statement (FEIS) for its continued use of public, “ceded” lands at the Pōhakuloa Training Area (PTA) on Hawaiʻi Island, beyond the pending expiration of the Army’s lease for these lands.
Join voices from across the paeʻāina in calling for the BLNR to reject this sorely deficient FEIS! Sample testimony and meeting details below.
The Army has used the ʻāina at PTA for military testing and live-fire training for 60 years, resulting in well over 1,000 wildfires; destroying endangered species habitat; littering the land with spent munitions, toxic chemicals, and heavy metals - including depleted uranium; and desecrating sacred sites and historic cultural properties, among other impacts. Its current 65-year lease to use the state lands found within PTA will expire in 2029. The Army has accordingly put forward an FEIS, as the first step to “retaining” these lands beyond 2029.
While the FEIS is required to assess and thoroughly document the environmental, cultural, public health, and other impacts that would result from the Army’s continued use of these lands, the document is sorely deficient. Even the Department of Land and Natural Resource’s own staff have raised serious concerns with the FEIS, citing the Army’s failure to follow basic legal requirements and its repeated disregard of clear and specific guidance.
Submit written testimony, and attend Friday’s BLNR meeting in Honolulu in-person or on Zoom, to urge the BLNR to reject this FEIS (details and sample testimonies below).
If the BLNR rejects the FEIS, the Army will be minimally forced to produce a new and more complete FEIS for the BLNR’s future consideration. However, if the BLNR accepts the document, the Army will be allowed to proceed with the next steps to "retaining" the lands it currently occupies. NOTE: If the BLNR is not able to make a decision, or if its votes are tied, the FEIS will be deemed automatically accepted as of May 14.
Testify at the Board of Land and Natural Resources Meeting
Friday, May 9, 9am, DLNR Boardroom, Kalanimoku Building, 1151 Punchbowl Street, 1st floor, makai side conference room (Room 132)
Stream meeting live on YouTube here
Join meeting via Zoom here
Submit written testimony to blnr.testimony@hawaii.gov by Thursday, May 8, 9am (if can - late testimony is better than none!)
Be sure to include “Testimony for Agenda Item D-1” in your subject line.
*If you wish to submit virtual verbal testimony, indicate so in your email.
Sample testimonies:
Feel free to choose one that resonates most with you, or mix and match or draft your own!
Option 1:
Aloha e Chair Chang and Members of the Board of Land and Natural Resources
My name is _______ and I am from _______. I respectfully urge you to do the right thing, and reject the clearly insufficient FEIS in Item D-1.
The public trust doctrine, embodied in our state constitution, requires the BLNR to exercise due diligence and prudence in managing our natural and cultural resources, and in protecting the interests of the present and future beneficiaries of the trust. Without cultural surveys, biological opinions, or a good faith assessment of alternative beneficial uses of the long-abused ʻāina at Pōhakuloa - all things missing from the FEIS - the BLNR simply does not have the information it needs to even begin upholding these public trust duties. I urge the BLNR to reject this sorely deficient FEIS, as an affront to its responsibilities under our constitution and the public trust.
Accordingly, please REJECT the FEIS put forward in Agenda Item D-1.
Mahalo nui for the opportunity to testify.
Sincerely,
[Your name]
Option 2:
Aloha e Chair Chang and Members of the Board of Land and Natural Resources,
My name is _______ and I am from _______. I respectfully urge you to do the right thing, and REJECT the clearly insufficient FEIS in Item D-1.
As the DLNR staff submittal makes clear, the FEIS fails to include needed biological and archaeological surveys, turns a blind eye to environmental impacts on federal lands, and downplays obviously significant threats to endangered native birds and wildlife - among many other issues. Accepting this dangerously deficient document may accordingly result in actions that threaten the permanent and inadvertent loss of native species, iwi kūpuna, and historic properties, among other deep and immeasurable harms to the public interest.
Accordingly, please REJECT the FEIS put forward in Agenda Item D-1.
Mahalo nui for the opportunity to testify.
Sincerely,
[Your name]
Option 3:
Aloha e Chair Chang and Members of the Board of Land and Natural Resources,
My name is _______ and I am from _______. I respectfully urge you to do the right thing, and reject the clearly insufficient FEIS in Item D-1.
Native Hawaiians have long borne a disproportionate burden in witnessing Pōhakuloa's sacred ʻāina be bombed, poisoned, and desecrated - for generations. The US Congress itself, in the 1993 Apology Resolution, recognized the intrinsic and unique relationship between the well-being of the Hawaiian people and their connection to ʻāina. Yet the FEIS fails to account for the deep psychological, spiritual, and physical harms that will continue to be borne by the Native Hawaiian community in particular, should their demands for justice, healing, and reconnection with ancestral (and illegally stolen) ʻāina at Pōhakuloa be ignored for another 65 years or longer.
Please reject this FEIS, to ensure that the Army fully accounts for the harms it has and will continue to inflict with its "retention" proposal, including to the Native Hawaiian community.
Mahalo nui for the opportunity to testify.
Sincerely,
[Your name]
Option 4:
Aloha e Chair Chang and Members of the Board of Land and Natural Resources,
My name is _______ and I am from _______. I respectfully urge you to do the right thing and reject the clearly insufficient FEIS in Item D-1.
This FEIS disregards clear Hawaiʻi law, as even DLNR staff repeatedly point out in the staff submittal. The Army is not above the law, and yet they refuse to address basic legal requirements, such as analyzing the environmental and cultural impacts that will take place on federal lands, and completing basic surveys so that a true objective assessment can be made about the impacts of proposed Army "retention" of ʻāina in Pōhakuloa.
Please uphold the law, and your mission, and reject this incomplete and unlawful document.
Accordingly, I urge you to please REJECT the FEIS put forward in Agenda Item D-1.
Mahalo nui for the opportunity to testify.
Sincerely,
[Your name]
Option 5:
Aloha e Chair Chang and Members of the Board of Land and Natural Resources,
My name is _______ and I am from _______. I respectfully urge you to reject the clearly insufficient FEIS in Item D-1.
By accepting such a shoddy FEIS, the BLNR will make it that much harder to carry out its overall mission. Every subsequent applicant required to undergo environmental review before a BLNR action will be able to point to the BLNR's acceptance of this deficient document to excuse their own shortcomings, and future BLNR members may feel pressured to give in to their demands for deference - at the expense of our natural and cultural resources, and Hawaiʻi’s present and future generations.
Therefore, please REJECT the FEIS put forward in Agenda Item D-1.
Mahalo nui for the opportunity to testify.
Sincerely,
[Your name]