If you’re on Oahu, please show up. Wear black and red and request that the BLNR REJECT THE FEIS!

To: Board of Land and Natural Resources
RE: Testimony for Agenda Item D-1, scheduled for May 9th 2025
From: Former Hawaiʻi OEQC Director, Gary Hooser

Aloha Land Board Members
I am writing to urge you to reject the Army’s FEIS relating to the proposed retention of leased lands at Pōhakuloa Training Area.

According to the EIS: “Because the Army’s Proposed Action involves retention of State-owned land, this EIS also must fulfill the Hawaiʻi EIS statute and implementing rule, codified in Hawaiʻi Revised Statutes (HRS) Chapter 343…”

As the former Director of the Hawaiʻi Office of Environmental Quality Control (2011 – 2012), my job was to manage the administration of HRS Chapter 343, and to educate State agencies on its key elements.

I am keenly aware of the requirements of HRS Chapter 343, Hawaiʻi’s EIS statute and am testifying without reservation whatsoever, that the Army’s FEIS and related documentation are totally inadequate.

The Department of Land and Natural Resources own staff report states,

“Throughout the EIS process, Staff had and continues to have concerns with the following;
1) That the contents of the draft/final EIS do not fully declare the environmental implications of the proposed action and does not discuss all reasonably foreseeable consequences, and
2) The data and analysis do not commensurate with the importance of the impacts.”

The FEIS analysis of “direct impacts” falls far short of a complete analysis and I encourage Land Board Members to closely review the comments provided by the Sierra Club of Hawaiʻi and other environmental stewards who have closely examined the EIS and submitted testimony.

The lack of a complete and proper analysis of the “direct impacts” is by itself sufficient reason to reject the FEIS.

Another huge concern is the almost non-existent review, documentation, and/or research on “indirect, secondary, and cumulative impacts” that are absolutely required for any HRS Chapter 343 compliant FEIS.

For example there is minimal discussion on the type of “ordinance” that will be deployed such as – explosive size and types, uranium tipped, chemical weapons, laser and or magnetic cannons now under development – and others.

What are the anticipated direct and long term impacts from the various weapons systems? How will the “residue” from the use of these weapons be “cleaned up”? Where will the “clean-up” materials (possibly toxic) be deposited? What materials will go into landfills located in Hawaiʻi County? What materials will be shipped outside of Hawaiʻi, and to where?

All weapons listed must be transported to and from the subject area. What are potential impacts of incidents that may occur at the harbor, airport, or along the highways during such transportation?

The entities listed as possible users and beneficiaries of the Pōhakuloa Training Area include foreign and “multinational” entities. What are the secondary impacts of training foreign or multinational armies on Hawaiʻi soil? Will the adversaries of these foreign countries consider Hawaiʻi now their adversary because of our support and assistance to their enemies?

These questions and more, must be asked and examined as legitimate “secondary and indirect” impacts.

The U.S. Army’s FEIS for Pōhakuloa is woefully inadequate and I strongly urge the State Board of Land and Natural Resources to reject it.

Gary Hooser
Former OEQC Director
Former Hawaiʻi State Senator
Kapaa, Hawaiʻi