Does current practice in Hawaii reflect best practices?
Current practice in Hawaii does not reflect best practices. ()
- Consultants needlessly bulk up documents “to be thorough.” ()
- Agencies, preparers in general, do only what is required.
- Documents are recycled for different projects. “Just change the title and you’re good to go.” ()
- Point-by-point comparison of project with various existing plans (development, community). ()
What are best practices for preparing environmental review documents?
Clarify rules, guidelines, process, and content requirements. (3: 1, 2)
- The greater the ambiguity, the more likely the process will be manipulated. ()
- The general public should understand the process and information.
- Consistency in standards for review, determinations, and acceptance by all agencies. (3: 1, 1, 1)
- Clarify through case law, much like NEPA and CEQA.
- It is already the standard resource for most preparers.
- Regularly update the Guidebook to standardize best/latest methods and content. (15: 5, 1, 9)
- It should include a standard outline for EAs/EISs and examples of preferred methods. (10: 7, 3)
- Checklists for impacts, significance, and environmental justice would be useful. (3)
- Do a thorough process and avoid controversy.
- The federal level requires “reader friendly” documents.
- For NEPA, each federal agency has its own manual, some with good technical guidance. ()
- Make a State version of CEQ’s “40 Most Asked Questions.”
Certify preparers for EIS work. People should lose their license if they misrepresent information in the EIS process. (7: 6, 1)
Comments and Concerns
- It is hard to imagine best practices that would fit all circumstances.
- Mainland best practices may not be appropriate for Hawaii. ()
- Manuals inhibit the evolution of higher and better standards.
Are climate changes issues adequately addressed in the current EIS system?
Uncertainty and lack of methodology prevent addressing climate change. (2: 1, 1)
- No agreement exists on what the impacts will be.
- Research exists, but decision-makers do not use it.
- Standard indicators, baselines, and metrics are necessary to measure impacts. ()
- The precautionary principle should guide our actions when knowledge is insufficient.
- The State and Counties should establish a database of likely climate change impacts and make this available to EA/EIS preparers. (6: 2, 3, 1)
- The coastal zone management (CZM) process is effective.
- Experienced consultants understand the issue and address it appropriately.
- It will just be another barrier to prevent development.
- It would just add cost to the project.
- Do not add another layer. If there are no consequences for not doing it, why require it?
- The EIS process is too late. It should be addressed in master planning.
- Is it fair or practical to ask developers to evaluate these issues?
- This should be addressed through strategic environmental assessment (SEA). (2)
How best can climate change impacts to Hawaii be incorporated into the EIS process?
The best way to address climate change is still undetermined.
- The science exists, but it is not widely accepted by the public.
- Change the rules to be more specific about what should be addressed.
- Approach the EIS through the lens of sustainability.
- The 2050 plan should be a template for addressing climate change.
- Address how a project will affect climate change; and how climate change will affect a project. (10: 2, 8)
- California is currently addressing this. Hawaii should look there for guidance. ()
Climate change in Hawaii is best addressed another way, not through EIS. (15: 9, 1, 5)
- Assess climate change through established agency policies and guidelines.
- The State and local levels are too small scale. Leave this to NEPA to address.
- It should be addressed at the long-range planning level. (5: 4, 1)
- Should secondary and tertiary impacts be considered?
- Agencies, developers, and the public do not want to acknowledge it.
- Global warming will be a boilerplate statement stuck into the EA/EIS. (2)
Should the EIS process examine whether actions adequately address disaster resiliency?
Addressing disaster resiliency in the EIS process is unnecessary. ()
- It is a permit issue and should be subject to a strategic environmental assessment (SEA).
- This would duplicate Civil Defense, Disaster Management, and Planning responsibilities. (3)
- Solutions and mitigation are beyond the scope of the EIS or the project.
- It is not the developer’s responsibility to build a new road or hospital.
- To justify the purpose and need for a project.
- For projects greater than a certain threshold or in certain areas/zones.
- It would be too onerous for every small project to address this.
- Guidelines and standards must be developed.
- It should only address certain impacts and evacuation procedures.
- Including this in EISs creates political continuity and ensures consideration in decision-making.
- After Iniki, plans were prepared but put on a shelf and no lessons learned.
- Include resiliency in mitigation measures for likely hazards. ()
Should the EIS discuss impacts on response, recovery, and preparedness?
EIS documents should discuss project impacts on these when appropriate (scale, type and significance of impact of project). (4: 1, 2, 1)
- Do scenario analysis of certain events (hurricane, tsunami, earthquake).
- The discussion should be for information, not regulation.
- Fit the project into existing emergency plans.
- Government should establish standards and do risk assessments for preparers to use.
- The consultation process (e.g. with fire and emergency) already gets comments as needed. (1)
- Disaster planning changes too rapidly to discuss the relationship to a project in an EIS.
- These are not environmental issues.
- This is an unnecessary burden (time, cost) on the proponent.
- It should be part of a strategic environmental assessment (SEA).
Should the EIS process be modified in the event of a state-declared emergency or disaster?
The governor should be able to suspend it for an emergency. (8: 7, 1)
- The system must have flexibility for rapid action when necessary.
- Public health and safety must not be delayed or compromised.
- Agencies are conscientious of environmental impacts and act appropriately.
- An emergency justifies suspension for repair, recovery, and reconstruction.
- Disaster management plans should already be in place and subject to a programmatic EA.
- The federal system has an emergency response program permitting restoration of access and roads, but permanent fixes still need NEPA clearance. (3: 1, 2)
- After-the-fact review for action during an emergency would be good.
- OEQC should have an oversight role during an emergency.
- The distinction between emergency response and recovery is blurred in emergencies. Recovery actions should be subject to 343, but not response. ()
- Emergency declarations should have a high threshold—only for health and safety.
- Limits on the duration or scope of state-declared emergencies are necessary. ()
- Declarations have a history of misuse (“disaster capitalism”).
- The definition should include economic cycles, not just natural disasters.
- Add disaster management aspects to the list of significant effects.
- “Today people are allowed to build anything they want anywhere they want and then throw the disaster management problem to the municipality.”
- Past attempts at emergency oversight (i.e. the Office of Emergency Permitting) did not work.